By Michael Tanglis and Taylor Lincoln
The center-right American Action Forum (AAF) attacked the study we recently published showing that regulations completed during transition periods have been longer in development than those finished at other times. This finding rebutted alarmist claims about “midnight regulations.”
The crux of AAF’s critique of us centered on how we calculated the length of rulemakings. We do not agree with the group’s quibbles. However, even if we followed AAF’s recommended methodologies, doing so would affect all rulemaking lengths – both transition period and non-transition period rules. As a result, the conclusions of our study would be the same: that rulemakings finalized in presidential transition periods took longer, on average, than those completed at other times.
Today, we issued a response to AAF. We stand by our study’s methods, findings and conclusions.