This comment addresses the efficiency and efficacy of this proposed rule from an economic point of view. Specifically, it examines how the proposed rule may be improved by more closely examining the societal goals the rule intends to achieve and whether this proposed regulation will successfully achieve those goals. In many instances, regulations can be substantially improved by choosing more effective regulatory options or more carefully assessing the actual societal problem.
There is little evidence to support the claim that certificates of need are an effective cost-control measure; and Stratmann and Russ have found that these programs have no effect on the level of charity care provided to the poor. While controlling health care costs and increasing care for the poor may be laudable public policy goals, the evidence strongly suggests that CON regulations are not an effective mechanism for achieving them. Instead, these programs simply decrease the supply and availability of health care services by limiting entry and competition.
In this brief comment, I will focus on the correct framework to use in selecting the appropriate interest rate when valuing public pension sector liabilities. A framework based on economic principles will accurately measure the market value of these liabilities and is superior to the actuarial approach.
The commission should shift enforcement efforts away from stopping private restraint of trade and toward stopping public restraint of trade. In light of George Stigler’s observation that “the state has one basic resource which in pure principle is not shared with even the mightiest of its citizens: the power to coerce,” the commission would be wise to adopt Commissioner Wright’s approach and shift resources toward fighting public restraint of trade.
The argument in favor of implementing the “Electronic Distribution of Prescribing Information for Human Prescription Drugs, Including Biological Products” is flawed and incomplete. The FDA does not demonstrate that the regulation solves a significant problem, and it fails to estimate the benefits of the regulation for patient health. Ultimately, a more complete analysis of both the costs and, particularly, the benefits of the proposed regulation and of reasonable alternatives is needed before the FDA can claim that this particular regulation is in the best interests of the public.
The FAA must carefully consider the potential effect of UASs on the US economy. If it does not, innovation and technological advancement in the commercial UAS space will find a home elsewhere in the world. Many of the most innovative UAS advances are already happening abroad, not in the United States. If the United States is to be a leader in the development of UAS technologies, the FAA must open the American skies to innovation.
In a public interest comment published by the Mercatus Center at George Mason University, economist Feler Bose determines that the DOE fails to consider alternative approaches to its regulation by requiring the use of electronic ignition instead of implementing a performance standard for standby mode. The comment recommends several ways the DOE can improve its economic analysis and proposal.
The NOPR’s analysis of dishwashers is superficially detailed and modern in its research methods. In the areas discussed above and numerous others, the research embodied in it appears to be inadequate as a foundation for a rule that will apply to every dishwasher sold in the United States after 2019. Whatever errors and uncertainties are in the document, it is ultimately just an assertion that the DOE is better than consumers at choosing the energy efficiency and other attributes of dishwashers.
Under the authority of the Clean Water Act (CWA) of 1972, the Environmental Protection Agency (EPA) is proposing new technology requirements for all new and existing dental practices that use dental amalgam, which is the main source of mercury discharges into publicly owned treatment works (POTWs). The proposed rule would require dental offices to use amalgam separators and best management practices (BMPs) for capturing mercury and other metals before they are discharged into POTWs.
This book presents 17 oral histories of Hurricane Katrina survivors from four diverse New Orleans communities. The oral histories explore how these individuals, families, and communities began to rebuild after the devastation.