November 30, 2011TO THE MEMBERS OF THE U.S. HOUSE OF REPRESENTATIVES:The undersigned groups strongly urge you to pass H.R. 3010, the “Regulatory AccountabilityAct of 2011,” which would modernize the 65-year old Administrative Procedure Act andimprove how federal agencies write the regulations that most significantly affect the U.S.economy.We strongly believe that regulations need to be narrowly tailored, be supported by strong andcredible data and evidence, and impose the lowest possible burden while still implementingCongressional intent. When agencies produce regulations that do not reflect these ideals, bettermechanisms are needed to hold them accountable.The “Regulatory Accountability Act of 2011” would enhance the regulatory process by:
Increasing public participation in shaping the most costly regulations before they areproposed;
Requiring that agencies must choose the least costly option unless they can demonstrate aneed to protect public health, safety, or welfare;
Giving interested parties the opportunity to hold agencies accountable for theircompliance with the Information Quality Act;
Providing for on-the-record administrative hearings for the most costly regulations toinsure that agency data is well tested and reviewed;
Restricting agencies’ use of interim final regulations where no comments are taken beforea regulation takes effect and providing for expedited judicial review of whether thatapproach is justified; and
Providing for a more rigorous test in legal challenges for those regulations that wouldhave the most impact.The “Regulatory Accountability Act of 2011” would build on established principles of fairregulatory process and review embodied in executive orders since the Clinton administration.These principles make the regulatory process more transparent, agencies more accountable, andregulations more cost-effective. This legislation would not affect any regulations that are alreadyin effect, nor would it impact enforcement under current regulations.We strongly urge you to support this important legislation.Sincerely,Academy of General DentistryAdhesive & Sealant CouncilAeronautical Repair Station Association