ML20217J950
| ML20217J950 | |
| Person / Time | |
|---|---|
| Issue date: | 08/05/1997 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Bliley T HOUSE OF REP. |
| References | |
| NUDOCS 9708150088 | |
| Download: ML20217J950 (27) | |
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- st August 5, 1997 CHAMMAN The Honorable Thomas J. Bliley, Jr.
- Chairrnan, Committea on Commerce United States House of Representatives Washington, D.C. 20515. 15
Dear Mr. Chairman:
In response to your letter of June 16,1997, I am pleased to provide the information you requested regarding the costs of regulation and other administrative procedures promulgated by the NRC.
If I can be of further assistance, please contact me, Sincerely,
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Enclosure:
As stated
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i, RESPONSES TO QUESTIONS FROM CONGRESSMAN BLILEY
Federal Agency Costs of Regulation and Licensing QUESTION 1.
For FY 1996, please list availab e documentation on all of the costs incurred by your agency to support its regulatory and licensing activities in each of the following areas:
Promulgation of regulations, rules, administrative letters, licensing a.
procedures, and other administrative procedures; b.
Enforcement of regulations, rules, administrative letters, and other administrative procedures including inspections, record keeping, and auditing; c.
Review of license applicatio'1s and renewals; and d
Litigation as the result of regulations, rules, administrative letters, and other administrative procedures.
- 6_NSWER, The NRC submits budget justification materials (NUREG 1100) to the Congress annually in support of the NRC's appropriations as part of the Energy and Water Development Appropriations Act. NUREG 1100 displays the amount of resources estimated to be expended in support of NRC's regulatory and licensing activities. Such resource estimates are provided for each of the NRC's major programs (reactor program, nuclear materials and nuclear waste program, and management and support program). These programs are further subdivided into cost centers (e.g., reactor regulation), and activities (e.g., reactor inspection; investigations, enforcement and legal advice; etc.). Resource estimates for FY 1996, as enacted by Congress, are contained in NUREG-1100, Volume 13, dated February 1997.
With respect to actual cost data, the agency's accountabihty report provides such data at the appropriation account level, There is no published document which provides cost data in a structure and level of detail comparable to NUREG 1100. Expenditure data resides within the agency accounting systr n and would require staff time to analyze that data and prepar.
documentation displaying such data in a structure and level of detail comparable to NUREG-1100.
Federal Agency Costs of Regulation and Licensing i 88iSTION 2.
For years before FY 1996, please list available documentation on all of the costs incurred by your agency to support its regulatory and licensing activities in each of the following areas:
Promulgation of regulations, rules, administrative letters, licensing a.
procedures, and other administrative procedures; b.
Enforcement of regulations, rules, administrative letters, and other administrative procedures including inspections, record keeping, and auditing; c.
Review of license applications and renewals; and d.
Litigation as the result of regulations, rules, administrative letters, and other administrative procedures.
ANSWER.
As noted in the answer to Question 1. although there is no published document with a comparable level of detail for actual costs, the NRC's budget justification materials (NUREG-1100) submitted to the Congress annually display the amount of resources estimated to be expended in support of NRC's regulatory and licensing activities. For FY 1984 through FY 1995, such resource estimates are provided in a different format than that for the FY 1996 data referenced in the arnwer to Question 1. However, a similar level of detail is shown in NUREG 1100 for those fiscal years. Resourc3 estimates, as enacted by Congress for FY 1984, are contained in NUREG 1100, Volume 1, dated January 1985. Resource estimates, as enacted by Congress for subsequent fiscal years, are contained in succeeding volumes of NUREG 1100.
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Cost of Regulation and Licensing to other Federal Agencies i
and to State and Local Agencies QUESTION 3.
For FY 1996, please list available documentation on all of the costs incurred by other Federal agencies and by stato and local government agencies to support the regulatory and licensing activities of your agency:
1 Promulgation of regulations, rules, administrative letters, licensing i
a.
procedures, and other administrative procedures; 4
b.
Enforcement of regulations, rules, administrative letters, and other administrative procedures including inspections, record keeping, i
and auditing; c.
Review of license applications and renewals; and d.
Litigation as the result of regulations, rules, administrative letters, and other administrative procedures.
ANSWER.
The NRC does not maintain a data base on all of the costs incurred by other Federal, state, and local govemment agencies to support the regulation and licensing activities of NRC.
Under the Atomic Energy Act, States volunteer to regulate Atomic Energy Act materials.
Some State cost information is developed and provided to the Office of Management and Budget as part of the NRC's Agreement State prngram information collection activities under the Paperwork Reduction Act. Resource estimates pertaining to NRC's Agreement States program are provided under OMB Clearance Nos. 3150 0183, 0163, 0029, and -0178.
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QURGTIONA.
For years before FY 1996, please list available documentation on all of.
the costs incurred by other Federal agencies and by state and local government agencies in support the regulatory and licensing activities of i
your agency:
Promulgation of regulations, rules, administrative letters, licensing a.
procedures, and other administrative procedures; b.
Enforcement of regulations, rules, administrative letters, and other administrative procedures including inspections, recard keeping, and auditing; c.
Review of license applications and renewals; and d.
Litigation as the result of regulations. rules, administrative letters, and other administrative procedures.
ANSWER.
1 See above answer to Question 3.
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i The Costs to Individuals and Private Firms of Regulation and Licensing QUESTION 5.
What procedures, if any, does your agency have in place during the promulgation of new regulations and rules to estimate the future costs to the private sector of such regulations and rules?
- 6tiSWER NRC's procedures are contained in NUREG/BR 0058, Revision 2, entitled " Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission." This revision was published in November 1995 and reflects: (1) The NRC's accumulated oxperience with implementing the previous Guidel*es issued in 1984; (2) changes in NRO's regulations and procedures, especially the backfit rule (10 CFR 50.109) and the Policy Statement on Safety C~als for the-Operation of Nuclear Power Plants (51 FR 30028, August 21,1988); (3) advances and refinements in regulatory analysis techniques (4) re0ulatory guidance for Federal agencies issued by the Office of Management and Budget (OMB); and (5) procedural changes designed to enhance NRC's regulatory effectiveness.
Also, more detailed implementation guidance on performing regulatory analyses, and thus in quantifying licensee costs, is provided in " Regulatory Analysis Technical Evaluation Handbook". This handbook (NUREG/BR 0184) was published in January 1997.
The NRC has conducted regulatory value-impact analyses for over twenty years to determine whether an adequate basis exists for imposing new requirements on licensees. The NRC staff performs such analyses whenever the promulgation of new regulations and rules would affect a change in the use of resources by its licensees. These regulatory analyses include estimates of incremental costs attributable to the proposed action on both an annual and total life basis for the entire licensee population. Costs are typically evaluated at both the implementation and operational stages, and cost elements include hardware, structures, engineering, record keeping, procedural changes, administration, waste disposal, health physics, monitoring, maintenance, training, and, if applicable, replacement power.
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The Costs to Individuals and Private Firms of Regulation and Licensing QUESTION 6.
Wnat procedures, if any, does your agency have in place in evaluating ongoing regulations and rules to estimate both the past and future costs to the private sector of such regulations and rules?
ANSWER.
Although the NRC does not have a specific program to quantify or formally estimate the costs to its licensees of implernenting ongoing regulations and rules, we have undertaken several initiatives for evaluating regulations from the standpoint of reducing the regulatory burden and enhancing the efficiency of the regulatory process in May 1994, the Commission institutionalized these initiatives in the reactor area into the " Continuing Program for P.egulatory improvement." This program consists of three NRC initiatives:
1.
The Begglalp_ryjmprqyement Pronram: This program has encouraged the industry to submit petitions involving substantial regulatory burden relief which also are marginal to safety, and provided guidance on how to submit petitions for rulemaking which will receive expedited review by NRC. Costs of implementation and the benefits associated with burden reduction are estimated in the individual rulemakings involved. Since mid 1992, the NRC has issued 30 final rules that are designed to eliminate unnecessary licensee burdens and promote regulatory flexibility, while still maintaining adequate protection of the public health and safety. As a result of theee changes to the regulations, the NRC estimates that licensees are currently realizing cost savings wellin excess of $100 million per ye', and that an annual savings of at least this magnitude will continue to accrue over the next 20 years.
2.
The Eggplatory Review-Group Imotomentation Plan: In.1993, a group of senior Icvel NRC staff conducted a review of selected power reactor regulations and related processes, programs, and practices. Th3 regulatory review group identified areas with significant potential for reducing the regulatory burden with httle or no adverse safety impact. The NRC has implemented some of the recommendations of this group but has not calculated the potential cost savings to licencees. The Commission is considering implementation of additional recommendations, 3.
The 99st-Beneficial Licensina Action Proaram: The objective of this program is to increase the agency's responsiveness to submittals from licensees that reduce or eliminate license requiremants that have an incrementally sr.iall effect on safety but impose a great economic burden. In submitting requests under this program, the licensee sometimes voluntarily provides estimates of potential cost savings. As of July 1997, the staff had approved approximately 240 of these requests, in addition, since 1989, the NRC has conducted various surveys of its licensees to provide a feedback mechanism on the overallimpact of NRC regulatory activities on licensee operations. For its reactor licensees, the NRC staft has a program to solicit continuing information from licensoes through informal surveys during routine site visits and small scope surveys focused on specific aspects of the regulatory program. The staff reports the results of this feedback to the Commission annually.
The Costs to Individuals and Pnvate Firms of l
Regulation and Licensing QUESTION 7.
What procedures, if any, does your agency have in place in ovaluating initiallicense applications to estimate the costs to the private sec or of l
t complying with licensing and related administrative procedures?
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ANSWT,B.
f As a 100 percent fee recovery agency, in general, tl.e NRC directly charges the applicant for the cost of many of the administrative procedures, such as the staff's licensing reWaw sesociated with an application in accordance with fee schedules published in its regulations.
t As such, some historicel data are available to estimate the costs cf various aspects of the i
NRC staff's review assuciated with processing a licsnse application. This information is provided on an ad hoc basis to prospective applicants interested in understanding the i
potential costs associated with an application process.
However, the egency does not have procedures that would estimate the private sector cost of I
preparing an application, Many of NRC's requirements reflect good industry practice and were derived from case by case experience going back to the 1960's, before regulatory analysis guidelines and cost benefit requirements were in place, As noted, incremental changes to the basic licensing framework are subject to this kind of analysis. In 1989, the Commission reformed its initiallicensing process for power reactor licensees to permit the issuance of combined licenses to construct and operate a power reactor. This change was made to enhance the stability and predictabWty of the licensing process and streamline the process, which should also reduce the cost to applicants, I
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Regulation and Licensing QUESTION 8.
What procedures, if any, does your agency have in place in evaluating license renewals to estimate both the past and future costs to the a
private sector of complying with licensing and related administrative procedures?
1 6NSWER.
The NRC estimated the costs to the private sector of complying with licensing and related administrative procedures for future license renewal applicants of power reactor licenses as part of its procedures when it issued the license renewal rule in 1991 and when it made significant revisions in 1995. Limilarly, the estimawd costs of compliance are considereu in establishing generic license renewal requirements for fuel facilities. Further, the NRC Fees Program" includes controls for establishing and allocating the costs of license renewal on each licensee in the private sector to ensure that the fees charged to a licensee reasonably reflect the NRC costs of providing regulatory services to that licensee. The agency also i
performs license renewals of small research and test reactors but does not have procedures to estimate past and future costs.
The cost for license renewals of materials licensees is also estimated every three years as part of NRC's submission to the Office of Management and Budget (OMB). This information is published for public comment prior to OMB approval, in February 1997, a strearnfined licensing process was implemented that extended the license term for most nuclear materials licensees from 5 years to 10 years, reducing the administrative burden of license renewals for both the licensees and NRC. The agency, however, does not have procedures to estimate past and future costs.
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The Costs to Individuals and Private Firms of Regulation and Licensing QUESTION 9.
In preparing administrative letters, what procedures, if any, does your agency have in place tc svaluate costs to the private sector?
ANSWEB.
The NRC has a variety of products that fallin the broad category of administrative letters, ranging from generic communications that require no licensee actions (information notices, i
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' administrative letters) to generic communications that request specific actions of the licensee j
(bulletins, generic letters). The NRC's procedures for issuing generic communications are 4
based on achieving the remired level of safety by the most cost effective means.
NRC procedures require that for generic communications requesting licensee actions, the staff mak9 a formal determination that the required level of safety is in one of two general i
categoriesi in the first category, which involves compliance with existing regulations or adequate protection of pub!ic health and safety, the cost evaluation will generally consist of 4
(1) an estimate of the licensee's cost to respond to the generic communication and (2) a request that the licensee voluntarily report the subsequent cost of implementation. Most generic communications involving a request for licensee action are in this general category.
This analysis is required by 10 CFR 50.54(f) for reactor licensee generic communications.
The second category of generic communications involves a level of safety that is a substantialincrease in the overall protection of the public health and safety. For that category, for reactor licensees, the staff prepares a formal cost estimate to show that the direct and indirect costs of implementation are justified in view of this increased protection.
These generic communications will also include an estimate of the cost to the licensee to respond to the generic communication and a request that the licensee voluntarily report the
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p subsequent cost of implementation. This analysis is required by 10 CFR 50.109 for imposing requirements on reactor licensees.
NRC procedures aise p'3 vide for intemal and external scrutiny to ensure that both the Svel of safety required and the costs are accurately and consistently considered. Except for urgent generic communications, those communications requesting licensee actions are reviewed by the Committee To Review Generic Requirements, which is a group that is separate from the line _ organization requesting the action.- In addition, before issuance, these generic communications are published for public comment so that the regulated industry and the public can scrutinize the staff's approach and assumptions in addressing a particular safety issue,
. Finally, in January 1996, the Commission requested the staff to review existing licensee costs associated with resolution of several of the most significant generic issues for which licensee
- cost data are reasonably available. The results of this review were published in SECY 96-L 089,? Comparison of Costs of Generic Requirements Estimated by the NRC with those Estimated by Industry; Staff Effort Expended on Generic Activities," on Apri$ 30,1996.
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QUESTION L (Continued) 2-In this paper, the staff worked with NEl to identify new regulatory requirements where both industry and the staff did cost assessments on a reasonably comparable basis during the last five years. The limited detail and limited comparability of the available cost data did not allow i
any definitive conclusions as to why cost differences exist. However, one difference in assumptions is the costs associated with labor. The staff used a marginal labor cost, meaning that labor is available and the cost is just the wage cost for additional hours, whereas industry used a burdened labor cost, meaning that new personnel were assumed to be needed for the hours (with the attendant overhead cost). This may have accounted for some of the cost variance while other differences in analysis assumptions may have accounted for the rest.
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The Costs to individuals and Private Firms of Regulation and Licensing QLifdT10111Q For FY 1000, please list available documentation on both the estimated and actual costs incurred by private sector firms and individuals as a result of the regulatory and licensing activities of your
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agency in each of the following areas; Monitoring and commenting on the promulgation of regulations, a.
rules, administrative letters, licensing procedures and other administrative procedures; b.
Complying with rules and regulations including inspections, record keeping, and auditing; c.
License applications and renewals; d.
Latigation as the result of regulations, rules, administrative letters, and other administrative procedures; Foregone profits from the use of resources, ingredients, e
processes, o' other activities that were banned or limited by regulations, /ules, administrative letters, licensing procedures, changes in, lability rules, and other administrative procedures; f.
Foregone orofits from the production, marketing, distribution, or other use of products or services that were banned or limited by regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures; g.
Foregone profits from the delayed or canceled implementation of business plans as the result of regulations, rules, administrative le".ers, licen. -.;; procedures, changes in liability rules, and other administrative procedures; h.
Foregone profits from the production, marketing, distribution, or other use of products or services whose prices were regulated or controlled as a result of regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures;
QUESTION 10. (Continued) 2-I.
Foregone investments, innovations, and quality improvements that were delayed or abandoned as a result of regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures, and J.
Increased insurance and litigation costs as a result of changes in liability rules.
6t0$E8 The NRC has no available documentation on the estimated and actual costs " curred in FY 1990 by private sector firms and individuals as a result of the regulatory and licensing activities of our agency for items a, d, e, f, i, and J. NRC does not regulate prices or rates (Item h).
Regaiding item b, new rules and regulations, the regulatory analysis for each rulemaking provides documentation on the estimated costs incurred by private sector firms and individuals. Although no documentation on actual costs is available, the cost estimates are published along with the proposed rulemaking, and the public is encouraged to comment on the staff's estimates. In addition, record keeping and reporting burdens for each rulemaking are estimated, published along with the proposed rulemaking, and provided to the Office of Management and Budget (OMB) in accordance with OMB guidelines.
Regarde.g item c, license applications and renewals, no actual costs are available, but SECY-95-007, Final Amendment to the Nuclear Power Plant License Renewal (10 CFR Par
- 54)" provides estimated cost for license renewals.
In general, regarding item g, no documentation on foregone profits is available. However, the NRC has long r9 cognized that a potential consequence of NRC regulatory and licensing actions could be temporary reactor shutdowns, and in these instances, the cost of replac.;. 3nt enerDy is included in the regulatory analysis. The basis for the NRC's replacement energy cost estimates is " Replacement Energy Costs for Nuclear Electricity-Generating Units ? *- United States: 1992 1996" NUREG/CR-4012. Vol.3, October 1992.
These estimates are periodically updated, and new estimates are expected to be published this year.
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h The Costs to Individuals and Private Firms of Regulation and Licensing QUESTION 11.
For years prior to FY 1996, please list available documentation on both the estimated and actual costs incurred by private sector firms and individuals as a result of the regulatory and licensing activities of your agency in each of the following areas:
Monitoring and commenting on the promulgation of regulations, a,.
rules, administrative letters, licensing procedures and other administrative procedures; b.
Complying with rules and regulations including inspections, record keeping, and, auditing; i
c.
License applications and renewals; d.
Litigation as the result of regulations, rules, administrative letters, and other administrative procedures; Foregone profits from the use of resources, ingredients, e.
processes, or other activities that were banned or limited by regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures; f,
Foregone profits from the production, marketing, distribution, or other use of products or services that were banned or limited by regulations, rules, administrative letters, licensing procedures, l
changes in liability rules, and other administrative procedures; 9.
Foregone profits from the delayed or canceled implementation of business plans as the result of regulations, rules, administrative letters, licensing prc..adures, changes in liability rules, and other administrative procedures; h.
Foregone profits from the production, marketing, distribution, or other use of products or services whose prices were regulated or controlled as a result of regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures:
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QUESTION 1'i. (Continued) 2 1.
Foregone investments, innovations, and quality improvements that were delayed or abandoned as a result of regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures; and J.
Increased insurance and litigation costs as a result of changes in liabihty rules.
ANSWER.
F The same responses as provided to Question 10 apply to information available in ars prior to FY 1996.
The Total Costs of Regulation QUESTION 12.
What procedures, if any, does your agency have in place during the promulgation of regulations and rules to estimate the total costs (defined as the sum of the costs to your agency, other govemment agencies, and the private sector) of regulations, rules, administrative letters, licensing procedures and other administrative procedures?
ANSWER.
NRC *s procedures are contained in NUREG/DR 0058, Revision 2, entitled Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission." These procedures require that a regulatory analyr8 'nclude the oum r,r value impact results 'Nhich involves the summation of all consequences (i.e., net i alue calculation), and/or the separate summbuon of all values and impacts (i e., value i,5nne, ratio).
Also, these procedures require that all mechanisms used by the staff to establish or communicate generic requirements, guidance requests, or staff positions that would affect a change in the use of resources by its licensees, include an accompanyinp regulatory analysis. These mechanisms include rules (new regulations), bulletins, generic letters, regulatory guides, orders, standard review plans, branch technical positions, and standard technical specifications.
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4 QUESTION 13.
What procedures, if any, does your agency have in place in evaluating I
P ongoing rules and to estimate both the past and future total costs (defined as the sum of the costs to your agency, other govemment j
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agencies, and the private sector) of regulations, rules, administrative j
letters, licensing procedures, and other administrative procedures?
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AN.a M B.
i The NRC does not have specific procedures for estimating the past and future total costs of implementing regulations Costs are considered in many of the NRC's regulatory programs, as indicated in other sections of this response, in addition, costs are estimated if petitio" for rule or other changes are filek t
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What procedures, if any, does your agency have in place in evaluating initiallicense applications and license renewals and to estimate both the past and future total costs (defined as the sum of"le costs to your l
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complying with licensing and other administrative pro edures?
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6NSWER.
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As indicated in our answers to Questions 7 and 8, the NRC maintains historical data which l
can be used to estimate NRC costs in evaluating various types of license applications,-
including initial applicatio" snd renewals. We do not have cost data for other government egencies or the private sector.
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The Total Costs of Regulation 1-QUESTION 15.
Please list the total number of (a) regulations, (b) rules, administrative letters, (d) licensing procedures, (e) other administrative procedures, and (f) licenses that were promulgated or issued by your agency in FY 1996. For which of these procedures can you estimate total costs defined as the sum of the costs to your agency, other government agencies, and the private sector? For which of these procedures do you have insufficient information to estimate total costs?
ANSWER.
Igig_I numbers; Regulations and rules 14 Administrative letters 97 (i.e., generic letters, information notices, administrativo letters, and bulletins)
Licensing procedures -
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Licenses issued:
new applications 297 amendments 4412 renewals 1051 sealed source and device approvals 238 Total 5998 Estimate toteigglig:
NRC can estimate total cost to both the NRC and the private sector for all new regulations and rules. Insufficient information is evallable to estimate total costs for administrative letters.
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The Honorable Shirley Ann Jackson Chairman Nuclear Regulatory Commission i1555 Rockville Pike Rockville, Maryland 20852
Dear Chairman Jackson:
The Hc.'se Committee on Commerce is reviewing the costs of regulation and other administrative procedures promulgated by your agency. The Committee is compiling information on how these costs, including those under one-hundred million dollars, have been documented both in promulgating new regulations and in enforcing and reviewing existing regulations. As part of this effort, I am requesting information on the availability of existing documentation from your agency as specified on the attached
. ages.
I recognize that some informationon the costs of regulationmay not be available,and that there are no legal requirementsunder current statutory law fos such cost accounting. This request pertains only to listing the availability of existing documentation of the costs of regulation. I am not requesting that your agency estimate the costs of regulation where such documents do not currently exist.
So that the Commerce Cortunitice can conipicte its 4 examination in a t'mely manner, please provide all requested informationto my committee staff--or notify us of deficiencies-no later than July 31,1997.
The point of contact on the Commerce Committee,taff is Kristina Tanasichuk White. Please contact her with any questions at (202) 225-8042.
Sincerely, 4
J Tom Bliley Chairman Attachment TB:ktw
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Federal Agency Costs of Regulation and Licensing 1.
For FY 1996, please list available documentation on all of the costs incurred by your agency to support its regulatory and licensing activities in each of the following areas:
Promulgation of regulations, rules, administrative letters, licensing procedures, a.
and other administrative procedures; b.
Enforcement of regulations, rules, administrative letters, and other adminiMtive procedures including inspections, record keeping, and auditing; Review of licethe applications and renewals; and c,
d.
Litigation as the result of regulations, rules, administrative letters, anel other administrative procedures.
2.
For years before FY 1996, please list available documentation on all of the costs incurred by yoiir agency to support its regulatory and licensing activities in each of the following areas:
Promulgation of regulations, rules, administrative letters, licensing procedures, a.
and other administrative procedures; b.
Enforcement of regulations, rules, administrative letters: and other administrative procedures including inspections, record keeping, and auditing; Review of license applications and reaewals; and c,
d.
Litigation as the result of regulations, rules, administrative letters, and other administrative procedures.
Costs of n.oulation and Licensing to other Federal Agencies and to State and Local Agencies 3.
For FY 1996, please list available documentation on all of the costs incurred by other Federal agencies and by state and local government agencies to support the regulatory and licensing activities of your agency:
Promulgation of regulations, rules, admmistrative letters, licensing procedures, a.
and other administrative procedures; b.
Enforcement of regulations, rules, administrative letters, and other administrative procedures including inspections, record keeping, and auditing; 1
0, L,
i c.
Review of license applications and renewals; d.
Litigation as the result of regulations, rules, administrative letters, and other administrative procedures.
4.
For years before FY 1996, please list available documentation on all of the costs incurred by other Federal agencies and by state and local government agencies to support the regulatory and licensing activities of your agency:
Promulgation of regulations, mies, administrative letters, licensing procedures, a.
and other administrative procedures; b.
Enforcement of regulations, mies, adminisuative letters, and other administrative procedures including inspections, record keeping, and eliting; Review of license applications and renewals; c.
d Litigation as the result of regulations, mies, administrative letters, and other administrative procedures.
The Costs to Individuals and Private Firms of Regulation and Licensing 5.
What procedures, if any, does your agency have in place during the promulgation of new regulations and rules to estimate the future costs to the private sector of such regulations and mies?
6.
What procedures, if any, does your agency have in place in evaluating ongoing regulations and rules to estimate both th'e past and future costs to the private sector of such regulations and rules?
What procedures, if any, does your agency have in place in evaluating initial license 7
applications to estimate the costs to the private sector of complying with licensing and related administrative procedures?
What procedures, if any, does your agency have in place in evaluating license renewals 8.
to estimate both the past and future costs to the private sector of complying with licensing and related administrative procedures?
In preparing administrative letters, what procedures, if any, does your agency have in 9.
place to evaluate costs to the private sector?
2-
i.,
10.
For FY 1996, please list available documentation on both the estimated and actual costs incurred by private sector firms and individuals as a result of the regulatory and licensing activities of your agency in each of the following areas:
Monitoring and commenting on the promulgation of regulations, rules, a.
administrative letters, licensing procedures and other administrative procedures; b.
Complying with rules and regulations including inspections, record keeping, and auditing; c.
License applications and renewals; d.
Litigation as the result of regulations, rules, administrative letters, and other administrative procedures; Forgone profits from the use of resources, ingredients, processes, or other c.
activities that were banned or limited by regulations, rules, administrative letters, licensing procedures, clianges in liability rules, and other administrative procedures; f.
Forgone profits from the production, marketing, distribution, or other use of products or services that were banned or limited by regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures; g.
Forgone profits from the delayed or canceled implementation of business plans as the result of regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures:
h.
Forgone profits from the production, marketing, distribution, or other use of products or services whose prices were regulated or controlled as a result of regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures; i.
Forgone investments, innovations, and quality improvements that were delayed or abandoned as a result of regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures; and j.
Increased insurance and litigation costs as a result of changes in liability rules.
3-
ll1' 11.
For years prior to FY 1996, please list available documentation on both the estimated and actual costs incurred by private sector firms and individuals as a result of the regulatory and licensing activities of your agency in each of the following areas:
Monitoring and commenting on the promulgation of regulations, rules, a.
administrative letters, licensirg procedures and other administrative procedures; Complying with rules and regulations including inspections, record keeping, and b.
auditing; License applications and renewals; c.
d.
Litigation as the result of regulations, mies, administrative letters, and other administrative procedures; Forgone profits from the use of resources, ingredients, processes, or other c.
activities that were banned orJimited by regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures; Forgone profits from the production, marketing, distribution, or other use of f.
products or services that were banned or limited by regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures; Forgone profits from the delayed or canceled impleu.entation of business plans g.
as the result of regulations, ruits, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures; Forgone profits from the production, marketing, distribution, or other use of h.
products or services whose prices were regulated or controlled as a result of regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures; Forgone investments, innovations, and quality improvements that were delayed i.
or abandoned as a result of regulations, rules, administrative letters, licensing procedures, changes in liability rules, and other administrative procedures; j.
Increased insurance and litigation costs as a result of changes in liability rules. 1
e 1
l The Total Costs of Regulation 12.
What procedures, if any, does your agency have in place during the promulgation of regulations and rules to estimate the total costs (defined as the sum of the costs to your agency, other government agencies, and the private sector) of regulations, rules, administrative letters, licensing procedures and other administrative procedures?
13.
What procedures, if any, does your agency have in place in evaluating ongoing rules and to estimate both the past and future total costs (defined as the sum of the costs to your agency, other government agencies, and the private sector) of regulations, rules, administrative letters, licensing procedures and other administrative procedures?
14.
What procedures, if any, does your agency have in place in evaluating initial license applications and licerse renewals to estimate both the past and fumre total costs (defined as the sum of the costs to your agen.y, other government agencies, and thc private sector) of complying with licensing and other adndnistrative procedures?
16.
Please list the total number of (a) regulations, (b) rules, (c) administrative letters, (d) licensing procedures, (e) other administrative procedures, and (f) licenses that were promulgated or issued by your agency in FY 1996. For which of these procedures can you eatimate total costs defined as the sum of the costs to your agency, other government agencies, and the private sector? For which of these procedures do you have insufficient information to estimate total costs?
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