01 / belief
I’m not saying I agree with all of these folks, but I do think that, right now, all of our attention on notice-and-comment rulemaking — and for that matter, cost-benefit analysis as concomitant to it — misses the fact that there are people who are close observers of this space — and now a very empirically sophisticated observer in this space, Brian Libgober — who believe that most of the action is actually occurring before notice and comment starts.
“I’m not saying I agree with all of these folks, but I do think that, right now, all of our attention on notice-and-comment rulemaking — and for that matter, cost-benefit analysis as concomitant to it — misses the fact that there are people who are close observers of this space — and now a very empirically sophisticated observer in this space, Brian Libgober — who believe that most of the action is actually occurring before notice and comment starts.”
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