The wonky but incredibly important changes Biden just made to regulatory policy

In this episode, Sabeel Rahman, former acting administrator of
the federal Office of Information and Regulatory Affairs,
discusses updates to regulatory policy that reflect a positive
new approach to how climate (and other) regulations will be
assessed and crafted.


(PDF
transcript)


(Active
transcript)


Text transcript:


David Roberts


When President Biden first took office, his administration
released a series of "Day One executive actions." Among them was
reforming the way federal regulations are developed and
evaluated. This is not exactly something the public was clamoring
for, or even aware of, but it is foundational to the
administration's ability to achieve its other goals.


The agency in charge of reviewing proposed federal regulations is
called the Office of Information and Regulatory Affairs, or OIRA,
which sits inside the Office of Management and Budget (OMB). It
is a fairly obscure corner of the federal bureaucracy that
doesn't come in for much public scrutiny, but as the gateway
through which all federal regulations must pass, it is immensely
powerful in shaping the space of possibilities for any
administration.


A few weeks ago, OIRA answered Biden's call by issuing updated
versions of two crucial documents: circular A4 and circular A94.
The former contains guidance for agencies on how OIRA will
evaluate regulations; the latter contains guidance for how it
will evaluate public investments.


These guidance documents have not been updated in more than 20
years, so this development is long overdue. The new circulars
contain some fairly technical updates to the way OIRA does
cost-benefit analysis — and the goals toward which it deploys
cost-benefit analysis — but they are incredibly important,
evidence of a generational philosophical shift.


To unpack these changes, I talked with Sabeel Rahman of Brooklyn
Law School, who served as acting administrator of OIRA last year
while its current leader was being confirmed by the Senate.
Rahman was intimately involved in designing the updated guidance,
so I was eager to talk to him about the new approach, how it was
developed, how it reflects Biden's priorities, and what it means
for the future of climate and other regulations.


I know this sounds wonky, but it is worth your time. I promise
you will come out of it excited about cost-benefit analysis.


With no further ado, Sabeel Rahman, welcome to Volts. Thank you
so much for coming.


Sabeel Rahman


Thanks so much for having me.


David Roberts


This is awesome. I'm so excited to talk about this.


Sabeel Rahman


It is wonky, but it is awesome ...


David Roberts


Wonky and awesome. I've had sort of a side obsession with these
issues for a long, long time, and this is really a perfect
opportunity to jump into them. But before we jump into too many
wonky details, I want to do some scene setting just so people
know, kind of have a sense of what we're talking about in
general. So when Biden came in, he issued this sort of list of
"Day One," what they call "Day One priorities." And one of those
was to update regulatory policy, basically how regulations get
assessed and crafted. This is not something I think the public is
beating down the door demanding this.


This is something that has a behind the scenes air about it, but
it's also clearly a political priority. So maybe just to start
with, let's just talk about what is the Office of Management and
Budget, OMB, what is OIRA, which is the Office of Information and
Regulatory Affairs?


Sabeel Rahman


Yes, absolutely.


David Roberts


First try.


Sabeel Rahman


There we go.


David Roberts


What, OIRA is within it, and why what they do seems to have such
political presence in the administration that it made its way to
the top of this Day One priority list just to sort of set the
scene.


Sabeel Rahman


Yeah, absolutely. That's great. And thanks so much, David. And
you're exactly right. This is very much kind of behind the scenes
type of sets of issues, but really, really important for all the
day-to-day stuff that government needs to do, and especially in
this moment when we're thinking about the climate crisis or we're
thinking about trying to address systemic inequality. So the fact
that this was part of the Day One suite of actions from the
present is, I think, pretty indicative. So there was the headline
stuff, the new climate regulations, the Equity Executive Order,
responding to COVID right there's, all of that headline stuff.


And then this regulatory review piece was also there because
that's actually part of the back-end to make all those other
policies work. So we're used to thinking about the President
comes in, president can make all kinds of sweeping policy
decisions or kind of really important policy decisions. The day
to day of how that happens involves the federal agencies. And the
agencies, they can make enforcement actions, they can spend money
or they can write rules. And it's that rule writing part that
goes through the Office of Information and Regulatory Affairs.
And so this office that you talked about, OMB, the Office of
Management and Budget, builds the President's budget every year.


They handle the budget side, but they also do a lot of really
important work in terms of management. So how do agencies manage
their personnel, operate strategically, have the highest impact
for the resources they have. And then there's OIRA, which is the
regulatory part, sort of the third pillar of OMB. OIRA works with
the agencies will review under executive order going back to
Clinton era and a practice actually dating even further behind
that, OIRA will review major federal regulations, in part for the
policy, in part for legal issues, but also, most importantly, to
make sure they're consistent with the President's vision.


And that makes it a really important nexus for all of this stuff,
which is also partly why it can come in the crosshairs at times.


David Roberts


Right? And a question about that, OIRA, what sort of police
powers does it have? If an agency develops a regulation, sends it
to OIRA for review, and OIRA finds a problem, can OIRA just say,
"No, you got to go back and try again"? Or is it suggestions?
What power does it have?


Sabeel Rahman


Right, so it's quite a powerful office, and I should say,
obviously spent the first years of the Biden administration in
OIRA and was acting head of the office until the confirmed
administrator came in a few months ago. But the powers under the
original Clinton Executive Order, which continues to be in effect
to this day, really makes OIRA the kind of last stop in the
policy making approval process. So agencies have to get OIRA
clearance for significant regulations now to get OIRA clearance.
That's not just what does OIRA think, what does that office
think? The wire clearance process is really a kind of
governmental peer review.


So the idea is that through OIRA, OIRA will get sister agencies,
other parts of the West Wing, anyone who might have a point of
view on the policy at hand to make sure everyone's on the same
page. Right? And it's really that coordination that's the biggest
kind of stick in that. If someone's got a problem, if people
aren't on the same page, the rule is not going to go forward
until there's at least an understanding about, okay, here's what
it does, here's what it doesn't do. Everyone's comfortable with
this, right?


David Roberts


So it's sort of like the last stop a regulation goes to before
going out to the public and consequently has enormous gatekeeping
significance, even though it's completely more or less outside of
public view, unless except for a small handful of nerds paying
close attention to these things. And just to mention, you
mentioned this in passing, but just to clarify to listeners, you
were the acting administrator of OIRA for the first two years of
Biden's term while the current administrator was going through
the process of getting confirmed. So these changes we're going to
talk about. You were central in shepherding them through and
shaping them, were you not?


Sabeel Rahman


Yeah, I think that's fair to say. There was an acting
administrator in the first year, and I came in as the number two
and then took over in the second year. But this was very much a
big part of our day to day and a big part of the important work.
Because going back to your first question, you can think about
the individual regulations that are important trying to move good
policy on labor issues or on COVID or on equity or on climate,
but they all have to work through this existing regulatory review
process. And so if we don't update that right.


This process has been in place for decades, then you're trying to
shoehorn kind of cutting edge policy through very old procedures,
right? And it's got to be updated. So this is a big part of the
work for sure.


David Roberts


Yeah, and a final note on staffing, the administrator in question
who has just confirmed is Richard Rivez. Richard Rivez, who is a
law professor at NYU, one time dean of the NYU Law School, and a
longtime heavyweight academic expert in exactly this stuff,
cost-benefit analysis, et cetera, et cetera, which I just think
is sort of an indication you watch staffing to see what
administrations care about. This is, to me, appointing him
indicates that Biden is taking this very seriously.


Sabeel Rahman


Yeah, I think that's right. And Ricky is fantastic. His
leadership has already been tremendous in his first couple of
months. But exactly right. He's certainly an expert in
cost-benefit analysis in the regulatory state. He's done a lot of
work on climate and energy. A lot of his academic work coming in
was also about how to make sure that distributional questions
don't get lost in conventional analysis. And when you look at the
draft, you'll see a lot of those sensibilities woven through.
Now, that's not just Ricky, right? The President, in his Day One
memo calls out specifically climate, equity, distribution, future
generations, human dignity, all these things that we want good
policy to be able to speak to.


The charge was to go look at the review process and make sure
that those values don't get squeezed out, don't get lost, that
they're incorporated in a way that's rigorous and evidence based
and all of that kind of stuff.


David Roberts


Right. One more background kind of philosophical note just to
sort of set the table here also is debates about cost-benefit
analysis go way back and are vigorous and ongoing. And there is a
school of thought that says the process is sort of inherently
conservative, inherently against pro social, long term action,
and it should be scrapped in favor of something else. And then
there's this other sort of school of thought, which I think Ricky
Rivez is a good example of, which says, no, it is possible to
sort of rethink and reimagine cost-benefit analysis in a way that
serves pro-social, dare I even say progressive ends.


And what we're looking at here is that school of thought showing
what it can do. Overall, what we're seeing here is an effort to
make cost-benefit analysis more, let's say, pro social and far
seeing and less of the sort of conservative process that it has
traditionally been. Is that fair?


Sabeel Rahman


I think that's fair. And I would say it's an effort to make the
cost-benefit really the impact analysis because it's not just
costs and benefits, right? There's other stuff that don't fit
into those buckets. So it's really about a more holistic impact
analysis and to make that sort of as strong and robust and
cutting edge as it can be. And this was part of the President's
Day One charge as well, because if you look at that original
memo, that memo sort of reaffirmed the President's commitment to
the enterprise of impact analysis, to the conventional sort of
role that OIRA plays, but set this task that the role needs to be
exercised in this more modern, cutting edge way.


And that's what for me, reading it in context of the other sort
of substantive Day One commitments was really important because
that's the substance that the process has to be in sync with.


David Roberts


Right.


Sabeel Rahman


Because we got big things that we're trying to do on climate, on
equity, on all the crises that were swirling at that time. So I
think you're exactly right about the broader philosophical
debate. I should say this is so important because my own entrey
into this, I'm a political theorist by training I spent before
the administration I was President racial equity advocacy
organization Demo.


So we did a lot of work on these kinds of issues. And it's a very
real debate that I imagine will continue and should continue
about what is the right way to review and analyze public policy.
But what I think is true, sort of regardless, is that we need
something much more multifaceted holistic flexible than what we
had before, even under previous Democratic administrations.


David Roberts


Yeah, what we've got now clearly doesn't work. So let's talk
about then specifically what's happening. So there are two
documents guidances being updated here. The first one is called
Circular A4, which is basically guidance on how OIRA assesses
regulations. And then there's Circular A94, which has to do with
how OIRA assesses public investment. And my understanding is that
the issues and updates in A94 regarding public investment more or
less track what's going on in A4. So I'm going to mostly focus on
A4 we can touch on. If you have specific things to say about A94
later, we can get back to it.


But I think if we cover A4, we'll more or less be hitting the big
issues in A94 too. So A4 is a guidance for what OIRA is doing
when it does this regulatory review. So maybe let's just start
with what is this circular A4? Where did it come from? And how
long has the sort of existing guidance been around? Like, who
wrote the one we're using now?


Sabeel Rahman


Yeah, absolutely. So there's a whole world of government
documents that is not beyond the executive orders, and we're
entering into it now. So Circular A4 has never been updated. It
was first issued in 2003 during the Bush years and has stayed in
place since then. So that, right off the bat, I think tells you a
lot, right, about just kind of how important this update is. The
fact that it's a circular that's really guidance not just for OMB
and OIRA, but it's meant to be guidance for the agencies. The
idea is that the agencies are using it as their sort of
touchstone of here's what we should be striving towards.


This is also the kind of stuff that OIRA, when your rule comes in
to OIRA for final review, this is the stuff that OIRA is going to
kick the tires on. And so it really kind of sets up those
conversations. The other thing that's really important to know
that it's a technical document. I mean, it's technical. If you
read it, it's technical to read. But even its status is as a
technical document, less as a political document because it
actually goes through and the version that's released now is
about to go through public comment and peer review.


And so the idea is that it's supposed to represent a sort of
expert state of the field that is not meant to be kind of
changing every time the White House changes hands. It's really
meant to be. This is what public policy and social science across
the board, people agree that this is a kind of best practice.
Right?


David Roberts


Got it.


Sabeel Rahman


And so the ambition here is to update that old document but
really update it in a way that has that seal of approval from,
you know, the evidence and the research and, and, and the field
yeah. So that it can have some lasting, lasting staying power.


David Roberts


Right. So this is not something that was ever intended to be sort
of updated administration to administration. It's supposed to be
sort of a stable guiding document over time, but maybe like
having it be 20 years old is maybe a little bit longer between
...


20 years is probably too long. And I'm sure we'll get into the
weeds of you can definitely see the drift that has happened
right. As the world has moved on in the last 20 years.


Yeah. So several changes to A4 substantive changes that I want to
get into, but one just sort of kind of technical change right off
the top that I kind of thought was interesting is because I've
discussed it on Volts before, is what triggers OIRA review. And
so currently the threshold was if the regulation has $100 million
or more of impact, that triggers full OIRA review, which is a
pretty exhaustive process. It's time consuming and staff
consuming and that threshold has been raised to $200 million, as
far as I can tell, just to sort of reflect inflation, et cetera.


But the effect will be fewer regulation, like the number of
regulations that needed OIRA review is sort of piling up and
getting unwieldy and staffing shortages. So among other things,
this will free up OIRA staff a little bit to focus a little bit
more on the truly significant regulations. And I always like
administrative capacity is one of my passions.


Sabeel Rahman


Absolutely.


David Roberts


This is sort of a way of freeing up some administrative
capacities.


Sabeel Rahman


That's exactly right. And the new executive order also puts a
provision that that now $200 million dollar threshold will be
updated automatically every three years indexed to GDP. Which is
...


David Roberts


Makes a lot of sense.


Sabeel Rahman


... technical and wonky, but just removes this problem of like a
number that may or may not have made sense 20 years ago,
definitely doesn't make sense now. Just like make it an automatic
thing. And it is really a capacity management tool to your point.
Like our civil service, I think is incredibly important. They're
a crown jewel of our democracy as far as I'm concerned, and it
takes staff time and attention and resources to make good policy
in service of the public.


You got to focus the efforts right on the most important stuff.


David Roberts


Alright. Okay. So let's talk about we're going to go through
three big changes in A4. The first one is an update of discount
rates. And discount rates are not something I think that are
widely understood or widely discussed in the public. I once did a
long piece on it. It was one of the first sort of super long
wonky things I ever wrote. Just the wildly positive reaction sort
of set me off on my career path. So I have a sort of fondness for
discount rates, but let's just explain briefly, if that is even
humanly possible, what do we mean by a discount rate and what is
its significance?


Sabeel Rahman


So the basic idea is how do we trade-off or weigh impacts that
might happen today versus impacts that might happen a long time
in the future? And in general, if you have a higher discount
rate, you're really favoring impacts that happen right now
because you're discounting impacts that might happen, say, 100
years, 200 years in the future for a lot of day-to-day stuff that
doesn't really matter all that much. But anytime you're talking
about policy, the obvious big one is climate crisis policy. But
anything that is going to have a longer term multigenerational
tale of impact.


If you don't have the discount rate right, you're going to be
systematically off. You're either going to be overweighting to
the present and undercounting the future right in terms of costs
or benefits. And we talked about how long it's been since A4 is
updated. A4 has written into it a 3% discount rate that was
written in in 2003. And so that's been the rate that agencies
have been using for a long time. That's not the rate now. By all
the best science out there.


David Roberts


The way sometimes I try to explain it to people is like, what if
I offered you I made you choose between I could give you $100
today or $105 in a year.


Sabeel Rahman


Totally.


David Roberts


Or how about $106 in a year, $107? How much would it take for you
to delay getting your money? And if you would take $200 a year
from now to compensate for $100 now, you have like 100% discount
rate. Or conversely, if you're like $100 a year from now, $100
now, either one is exactly the same to me that's a 0% discount
rate, like future benefits are worth exactly as much to me as
present benefits. And it's just I think a good heuristic sort of
indicates how much do we value future benefits. So a couple of
things about this.


One thing I want to ask about is the 3% discount rate that's in
the previous A4, the unupdated A4 was developed via a procedure.
And the new I saw Ricky give a presentation on this. The new
discount rate, which is now 1.7%, was developed basically by
using the same procedure, just updated numbers. So what is that
procedure? How do you come to this number?


Sabeel Rahman


It's super wonky. There's a model that OMB and a lot of folks in
the field have been using to basically try to take into account
all the different complicated factors that might weigh into the
kinds of policy impacts that might happen over the long run.
You're trying to factor in changes in human behavior, changes in
market conditions, all the stuff like that. So what the proposal?
The new A4 proposal has actually done is two things. One is it's
done a straight, just keeping the old formula, but updating the
data with the latest data that we have right up to 2022, or at
least through 2021 as far as data was available, and running
those numbers, that gets you on the same model, a much lower
number because it's got more recent data baked into it of 1.7%.


But the new version is also put out for peer review and public
comment. And one of the questions that is being asked of expert
reviewers is, are there variations to the model that should be
considered now? That's a heavier lift, right? Because then you
have to construct a new model. It has to be sort of something
that meets field wide approval in terms of peer review and all of
that. But the advantage of putting both of these out is say,
okay, if we take a kind of small C conservative approach and keep
the old model but just update the data, that already gets you a
much more up to date number.


David Roberts


But the old formula is drawing on it's sort of indexing on market
interest rates, right? Mainly, is that the main sort of indicator
that the discount rate is being derived from?


Sabeel Rahman


There are a lot of inputs. That's one of the biggest ones. And in
fact, one of the debates is basically in terms of the
methodology, how much should one just sort of look to market
interest rates full stop? And that's one of the modeling
questions.


David Roberts


We're calling it a modeling question, but really it's a
philosophical it's a philosophical question because if you're
looking at market rates, you're looking at sort of intra
generational, like how much do individual investors care about
their individual benefits in the future versus their individual
benefits today? But when you're talking about something like
climate change, you're talking intergenerational sort of how much
do I value benefits for my children versus costs for me? Which
might not be the same thing. Market rates might not be a good
indicator of how much we value subsequent generations, right?


Sabeel Rahman


Totally. And it's also not clear how much are market rates, in
fact pricing in the real catastrophic risks of climate or other
types of existential threats. And in the new A4, there's some
nice language sort of framing that the point of discounting is to
really try to also take into account some of those kind of really
hard to quantify really catastrophic dangers that might come down
the line. So it is a broader kind of conceptual and as well as
analytic question.


David Roberts


Yeah, this was sort of the point of my piece that I wrote
originally which is really like moral these are moral and
philosophical debates sort of being waged undercover of math or
undercover of models. So I wonder running the same formula gets
you to a 1.7% discount rate, but then you also put the model out
for comment, and I wonder, is there any sort of room in the
guidance if an agency decides, well, the regulations we're
developing have extraordinarily long time horizons and
intergenerational effects, and so we would like to use a smaller
discount rate? Like is there room for agencies to have sort of
their own initiative here?


Sabeel Rahman


So there is room for that. And arguably the old A4 had some room
for this too, although you can imagine this was rarely took up on
that offer because it's really hard to calculate this stuff,
right. Agencies often don't have the bandwidth or the kind of
person power to build their own model from scratch. So that's why
the default number is really important. But the new version does
include a discussion about or the new proposal anyway. It does
include a discussion about there might be instance circumstances
where the particular nature of the policy or the issue might have
different dynamics and in those cases agencies can and should
come up with variations and probably just as a best practice like
run it with the 1.7 and then run it with the variation.


So you kind of can show like have some an informed decision. But
that's absolutely in there. And I think a general theme I would
say of this new A4 is creating much more informed flexibility,
right? That where things don't fit. Here's a good default, we've
updated it, but where it doesn't fit, let's talk about how to
make it work because the policy goal should be front and center
and then you should build an analysis that can inform that rather
than trying to shoehorn everything into a straitjacket.


David Roberts


One other question about discount rates is one of the places
where discount rates come into climate policy is the effort to
determine a social cost of carbon. Which is another thing we've
talked a lot about on this pod and another thing that I think
Biden is updating. So just maybe talk a little bit about just
even if you just change from 3% to 1.7% how that might sort of
affect how highly you price carbon, right?


Sabeel Rahman


So it is very big direct effect. Now we can talk in a minute
about sort of the mechanics around the social cost of carbon
update because that's happening in a different process. But
basically this point about discounting future impacts has a big
implication for how we might price the economic costs, the social
costs of a ton of carbon pollution in the air. Basically, the
higher the discount rate, the lower that social cost of carbon is
going to be. Because many of those costs that might arise from
too much carbon are long term costs, right? They're going to
really manifest in the future.


And so for discounting that then the cost can look really small.
Now, this is important because you know this better than me,
David, but in the social cost universe, one of the things that
the Trump administration did, they put out their estimate of the
social cost of carbon as extremely low. And part of how they got
to that low number was to say, well, we're going to have a really
high discount rate, among other things, right? And so if you do
the math, then you get this really low number. Well, okay, but if
that discount rate is not rooted in reality, then of course that
number is kind of meaningless.


David Roberts


And also to get back to the intergenerational thing, you can
derive some pretty absurd results from a high discount rate. All
of humanity goes extinct in whatever 2100 under like a 7, 8,
whatever, percent discount rate. We would hardly care today
that's going to happen. So you can get absurdities on both ends
with discount rates. Okay. So the sort of default 3% discount
rate now has been lowered to a default 1.7% discount rate. And
that is, all things being equal, going to make more regulations
look cost justified as a rule of thumb. It's going to be easier
to justify regulations that have long term benefits under this
new discount rate.


Sabeel Rahman


Yeah, and I would say that's just that it's more accurate, right?
Because a lot of those regulations have those long term benefits.
If we're talking climate, if you're talking lead poisoning, say,
is another example inter-generational, not quite in the climate
space, those benefits are there, we just weren't counting them.
Right, and that's important to your point that regulations,
people care as a policy matter, as a political matter, as a legal
matter, how do the benefits stack up against the costs that we
can put numbers to?


David Roberts


And I think it's intuitive too. I think if you just ask average
people on the street like, do you care a lot about the welfare of
your children? I think this is reflective, I think, of ordinary
intuitions too. Okay, so discount rate is the first big thing
that's updated in A4. But there are a couple of other really big
and interesting changes too. The second one I want to talk about
is distribution, basically. So I think tell me if this is
accurate. I think traditionally OIRA cost-benefit analysis just
looked at aggregate costs and aggregate benefits without
distinguishing among who, what is the nature of the recipients of
those costs and those benefits.


And that has some pretty straightforwardly counterintuitive
results. So, for instance, one regulation would prevent a
disaster in a poor neighborhood. One regulation would prevent a
disaster in a rich neighborhood. The latter clearly has higher
benefits, right. Just because the property on the line is worth
more. And I think it's intuitive to people that there's something
wrong with that. Right? There's something wrong with that. So for
the first time, this new A4 tries to introduce sort of
distributional impact analysis. So maybe just tell us, what would
that look like? What does that mean?


Sabeel Rahman


Yeah, and this is another one of those things that I think under
the old version there are a few sentences about, oh, you might
consider a distributional impact it's not really dwelled upon.
And there are definitely folks in OMB who had been pushing for
this for a long time, just as pure analytic to your point. You
can't really say you're doing a real analytic treatment of a
policy if you're not thinking about those types of very real
impacts. We would all say that, or I hope you would all say that,
like $100 extra dollars for Jeff Bezos is not the same thing as
$100 extra dollars for really anyone else, but in particular
working class folks, right?


So the new version has a much more expanded in depth discussion
about distributional analysis. First, in terms of pressing
agencies to really take it seriously. Second, in terms of giving
just much more detail about how and when one might do that. So
you should pay particular attention to distribution analysis to
the new A4 talks about when you're choosing between different
alternative policy designs. Suppose you have one version that
might score a little better in terms of net benefits, but like,
it's concentrating all the costs on people who are least able to
bear those costs, and another version which is still scoring, you
know, net beneficial, but is a much more even distribution of
those benefits and of those costs.


That's a relevant fact for decision makers before they decide on
what the final policy should be. So that's something that the new
A4 says agencies should look into.


David Roberts


Does it provide a formula sort of telling you how much weight
does income, or is it just sort of like pay attention?


Sabeel Rahman


It does a little bit of both. I think the general charge, as I
read it in the new document is saying that you should look into
this. And here are some methods by which you might do that
disaggregating the impacts by the relevant constituencies,
whether that's by income or taking a racial breakdown or whatever
the right bucketing is. But it also gives a discussion of what's
called income weighting. And this is provided not as a
requirement, but as a like, here's a tool that you could use as a
way to sort of shorthand estimate how much should we weigh a
dollar to a poor person versus a dollar to an ultra-rich person.


The new document has put an estimate of 1.4 as an estimate for
what's called the income elasticity of marginal utility. Meaning
how much more is that marginal dollar worth to you, depending on
where you are in the income level. And so that's a pretty new
important thing to actually have that number crunched and they're
available sort of on the table for agencies to use as a
shorthand.


David Roberts


This is a little bit of an aside, but it's a point that I think
is worth making, which is, I think when people think about at
least people in our world, when they think about federal
agencies, I think, tend to think about like EPA, which has a sort
of staff of dozens and all these sort of PhD economists on staff,
armies of analysts. But most agencies are not that big and don't
have that much administrative capacity and can't sort of sit down
and develop their own models for these things. This is not like a
heavy hand of central wonks here. The agencies need this.


They need this guidance, they want help doing these things.


Sabeel Rahman


Yeah, I think that's such an important point and I think this is
also not a flipping of the switch, right? Like having the new
guidance, you also then need to your point kind of to have some
time for the agencies to get used to this, to build some muscle,
to build some capacity. And so I think getting this out now with
a couple of years still left in this first term, to actually then
have some runway for agencies to start using these new
approaches, see what's working, see what's most helpful. I think
that's the kind of work that I would anticipate Ricky and Revesz
and the team to be digging into going forward.


David Roberts


One other question about this. When we're talking about
distributional impacts, are we just thinking of income or are
there other indicators?


Sabeel Rahman


Right, so absolutely income, but also could be broken down in
different ways. And so you have to look at in the guidance
itself, it actually has this whole section saying that the
agency, depending on the policy, should really be thoughtful
about what is the most informative and relevant set of
breakdowns. And it might be more than one income, race,
geography, sexual orientation, there are a bunch of different
ways that one might break it down. You obviously can't do every
category for every policy that would be multiply really fast. But
I think the point of the guidance is to say think about what are
the constituencies and communities who are most likely to be
impacted differently by the policy.


And then devise an approach, ideally quantitative, but if not
even using qualitative assessment of what you can to think about
rigorously, how are those different communities being impacted?
And then having that inform the policy choice. Because at the end
of the day, it's not a make work exercise. Right. The point of
this is are we making good policy that serves the public and that
is attuned to the very real disparities that we have in our
country, right? That's the issue. So this gives a framework to do
that, but it's really going to then be up to the agencies working
with OMB and OIRA folks to make it real.


David Roberts


Kind of already asked this once, but I want to return to it. So
if I'm an agency reading this, do I read this as I have to
convince OIRA that I thought about this? Or is this a gentle
suggestion from OIRA that I can take or not take? Is this now
going to be a sort of a requirement for new regs?


Sabeel Rahman


It's a great question in part because I think different OIRAs
have different styles depending on the administration, right?
When I was there, we very much saw ourselves as working hand in
glove in partnership with the agencies to make good policy,
right? But that said, OMB's role is also to sort of kick the
tires on whether it's the budget or the regs. And so I do think
it's not a you must do this, but it is a very, very strong
suggestion about the kinds of things that one should look into.
And look even now, under the old A4, it's not like every
regulation does every single thing that A4 talks about because
there's so much in there.


So in that sense, there's lots of tailoring, lots of flexibility
on what's needed. But it is very much a like, this is the bar,
this is what we're going to be looking for. And when OMB comes
asking for stuff, the agencies know that they got to pay
attention to that.


David Roberts


Okay. So first, updated discount rate, second, the strong
suggestion that agencies do some distributional impact analysis.
The third thing, which is also quite interesting, I think, for
insiders, because this has been a point of contention for a long
time, is the suggestion that agencies take the international
impacts of regulations into effect. And it was, we mentioned
earlier, the Trump administration's sort of ludicrously low
social cost of carbon. Part of how they came to that ludicrously
low number is very explicitly ostentatiously, even saying we
don't give a damn about how our regulations impact other
countries, that we just don't care.


The only numbers that are feeding into our calculations are how
does this benefit or cost Americans? I think just as sort of
ostentatiously says, no, that's real dumb and also morally
horrific. So what exactly does A4 say about international
impacts? Is it similar to distributional in that this is a strong
suggestion?


Sabeel Rahman


I think of it as opening up the aperture to allow first stuff
that had been squeezed out before. Right? So not every rule is
going to have massive global implications, but many of them will,
and those ought to be taken into account. And so I read this
section for those falling along at home. The geographic scope of
analysis, there's a lot of great language in there about the
different ways in which global effects might come into play. So
it might be that there are non US citizens who are living abroad
and face certain impacts that might have parallels in the US.


So they're good proxies. There might be experiencing an
externality of US decisions. Climate comes to mind there as well.
So there are a lot of different kind of variations laid out in
the guidance. The point is that the guidance says that you should
think about the global effects and incorporate them into your
analysis. It even talks about how, if it makes more sense,
include that as a separate thing, right, that you have your
traditional analysis, but then you could also sort of provide a
separate analysis of the impacts abroad, if that's the more sort
of feasible way to get at it.


But you really should be thinking about it.


David Roberts


And is this similar in that you've provided a formula that
agencies can use or not use? And if there is a formula, I'm
wondering sort of like how much less do we value a foreign life
relative to an American life? Is there a number there on how much
discounting we're doing geographically?


Sabeel Rahman


Right. So not in A4. The discussion A4 is more qualitative in
terms of just guidance to the agencies. And I think, like with
distributional analysis and discount rates, there'll be rules
where there will be trade offs that have to be weighed, I think,
compared to right now, where we don't have consistent analysis of
what those trade offs might even be, it's hard to even make good
judgments about them. Right? And so I think the idea here is
let's take that on, do the analysis, do the work. And then there
are all sorts of reasons why a policy might come down one way or
another.


It's hard for A4 to be prescriptive in that way, but A4 can say
you need to take these issues seriously, right?


David Roberts


At least think about it.


Sabeel Rahman


Yeah.


David Roberts


So those are the three big things. And like I said earlier,
roughly those same issues are reflected in A94. When they're
talking about public investment, I think maybe one thing worth
picking out on A94 and talking about specifically is and this was
a little bit of a mind blower to me A94 as it exists has a 7%
discount rate for investments in public infrastructure. Which
just seems to me crazy, because public investments in particular
are designed for long term benefit. That's the whole point. Like
infrastructure investments and stuff like that are like we have a
whole history in our country of huge investments we made that
paid off handsomely over the long term but wouldn't have penciled
out under a 7% discount rate.


So where the heck did that 7% discount rate come from in our
public investment considerations. And how does A94 change that?


Sabeel Rahman


Big difference between A4 and A94 is that A94 is focused exactly
on, as you said, David, the kind of government's expenditure on
public investments. It's always been sort of related to A4, but a
little bit different. The 7% number in A94 was aligned with A4
originally, and that A4 had a 3% number and then also had as an
upper bound for those types of capital investment related rules,
had that 7% in there. But that also is really in sore need of
updating. And so that's what A94 does. I think what you'll see in
the new version, without getting too deep into the weeds, is that
the new version is more aligned with the new version of A4.


The numbers are a little bit different to sort of take into
consideration the particularities of what, say, the budget side
of OMB has to take into account when they're dealing with federal
investments in buildings and stuff like that. It's a little bit
different from regulation. So that's where the divergence comes
from. But that old 7% number, I think, is reflective of where we
were with the thinking on this stuff in the early two thousands.


David Roberts


Is there a new number for discount rates for public investments
or is it not that simple on this side?


Sabeel Rahman


Yeah, it's a little bit more complicated for the investment side,
but that's also going for the same kind of peer review and public
comment. So I think we'll know more in the coming months about
where A94 lands. Exactly. But what's exciting and important is
that A94, the last revision was in, I think, 1992, not quite as
old as A4, but still pretty old.


David Roberts


Yeah, that's wild. And A94 also gets into distributional stuff
and international stuff.


Sabeel Rahman


Really important, yeah, really important distributional and
global effect language in there.


David Roberts


And part of this, I think part of the point of all this, one of
the points of all this was to align A4 and A94 better, so we have
some sort of coherent they had kind of drifted apart in a way
that made no sense.


Sabeel Rahman


Totally. And full props to the OMB Chief Economist team who they
sort of are the keepers of A94 in the sort of OMB ecology. I know
they've been working really hard on all this.


David Roberts


So those are the three big changes. Are there other changes in A4
that you think are worth calling out? Like there's something
having to do with risk and risk tolerance and risk assessment
that I don't even know how to create a coherent question about,
but feel free to talk about it.


Sabeel Rahman


Totally. Yeah. No, I appreciate that. I think there are three
other buckets of things that I'll just highlight briefly because
they're important and also, I think really brings this up to
2023. So one is what you were just alluding to. There are a bunch
of things that will mean a lot more to our economist and economic
modeler friends who might be listening, but they really amount to
kind of bringing A4 into line with sort of cutting edge of
economic theory. So how do we take into account uncertainty and
uncertain effects that we don't know with perfect certainty these
estimates, right?


Let's factor that in. Taking into account risk and risk aversion,
right? People are willing to pay more to be protected from the
risk that something might go haywire. It's kind of typical
understandable human behavior, but that's not always baked into
the models. So there's some technical stuff. That's bucket one.
The second bucket is there's a lot of really interesting what I
think of as like macroeconomic structure, things that are baked
into this new version. So normally reg reviews, reg analysis
would be you're looking at the new regulation almost at a micro
level. Like, you're just looking at that regulation and you're
kind of holding the rest of the world kind of constant.


But the new A4, it talks about, for example, business cycles.
There might be regulations that have different benefits and costs
when we're in a recession versus when we're not. If you think
about, for example, social insurance policies, if they're
designed to be countercyclical, those benefits really only kick
in under certain conditions that may not be around when the
regulation is being written, right? So it incorporates that. It
incorporates a lot of great new thinking about market
concentration and competition that's been a big focus of this
administration, being attuned to the ways in which concentrated
ownership of industries can lead to higher prices, less stable
production, kind of all the antitrust, anti-monopoly stuff that
is happening.


So that's baked into A4 much more. So these kind of like big
macroeconomic conditions.


David Roberts


Macroeconomic context, which you would think is like totally like
duh, of course.


Sabeel Rahman


Right. And then the last bucket is also another like you'd think,
of course it's not rocket science, but it's a really important
shift is that the new A4 has a lot more language and guidance
about what to do with those impacts that you can't put numbers to
because they're obviously real. And there and it even talks
specifically about things like civil rights and civil liberties,
democracy, equity. These are goals for good public policy. They
may not have number values and in some cases ought not to have
number values.


David Roberts


Or the welfare of other species. If I can just ...


Sabeel Rahman


Yeah, there's a section there about ecosystems and ecological
impacts as part of the hard to quantify discussion. So there's
tons of really important implications of that that you could
imagine for everything from ecology to equity that I think this
new A4 is much, much better at.


David Roberts


And those, I think, are really sticky to deal with because
there's no formula. I mean, even a candidate formula, right?
There's just no way to come up with a formula for how, like, you
know, how much should EPA weigh beauty or whatever. Or whatever.
But as you say, those things exist and matter. So is this just
basically OIRA saying to agencies, take note of think about these
things, like, take these things into consideration. Is that all
there is to it?


Sabeel Rahman


I think it's two things. One is that take into consideration and
bring those considerations into your analysis. Because a lot of
times agencies are thinking about that stuff, but they've
struggled in the past at times to bring those very real
considerations into an impact analysis, given how narrow the old
A4 used to be. And so then you had this kind of weird, right?
Like, we know that part of what we're trying to do is protect
ecosystems or protect the dignity of disabled persons who a curb
cutout is expensive to have on every sidewalk, but absolutely
critical to just look at basic human dignity if you're a disabled
person of a particular kind.


Let's take that obvious real factors that are in any human
decision about this kind of stuff and let's actually give it a
proper pride of place in the analysis, and then it's up to the
agency to sort of make the all things considered best decision.
And that's something that would be worked out through the review
process with DOT might come to a particular view about what the
rules should be for lavatory access for disabled persons on an
airline. That's going to have costs. It's going to have
qualitative considerations about basic civil liberties, human
life and safety and dignity.


And then if we can get everyone on the same page through the
review process that this makes sense, this is good, then that
should be the way we go.


David Roberts


Right, so this is or saying we're going to give you wide-latitude
to think about these things and incorporate these things.


Sabeel Rahman


Yeah, absolutely. And a lot of times I think people who are more
attuned to the hard sciences might feel like this stuff can be
squishy and amorphous. I always found it very straightforward.
Give us your reasons. Like any good like any good piece of
writing. Give your reasons, give your evidence. And just because
it's qualitative doesn't mean you don't have reasons and you
don't have evidence. So talk about it.


David Roberts


And even if you think it's arbitrary to pick a particular number,
it's quite clear that the number is not zero, right. The default
has been zero, which is clearly against our common values.


Sabeel Rahman


Absolutely.


David Roberts


Okay, so that's a lot of changes. A lot of changes to pack in
this technical circular. One other thing I saw at one point the
term cost-effectiveness analysis. Is there some effort to replace
the whole sort of notion of cost-benefit analysis with something
else? What's the deal there?


Sabeel Rahman


Yeah, I would put in the theme of much more flexibilities right,
to get the right kind of analysis for the policy at hand. So I
think people are familiar with traditional benefit cost-benefit
analysis where you kind of monetize everything on both sides of
the ledger and then you sum it up and then you're done. But
especially when you're talking about things that might not be
quantified quite as well. Right. There are other variations that
the new A4 talks through in more detail. So cost-effectiveness is
one suppose you have a kind of easy to understand qualitative
goal that may not have an exact number that you can measure, but
you can measure the costs.


Right. So we want to increase safety in the workplace. We can
proxy that in different ways, but the proxies are all kind of
imperfect and we know how much it would cost to increase the
safety requirements or slow down production so that people aren't
hurting themselves in a horrible way. Right. So then you can sort
of do a cost effectiveness comparison of how much boost to your
goal are you getting for some higher cost? And then the
policymaker can say, yeah, that's justified because that goal is
really important. We've done some work to know what the costs
are, and we think this is the overall more cost effective way to
get to that goal compared to some other variation.


David Roberts


Right. This is something that debates over cost-benefit analysis
have been batting back and forth for a long time, which is the
sort of premise of cost-benefit analysis is you let the
cost-benefit analysis tell you what your goal is, whereas
cost-effectiveness is, here's the goal. Now let's work backwards
what is the most cost-effective way to reach that goal, which is
a very different way of approaching.


Sabeel Rahman


Yeah, absolutely. And I think if I could pin down sort of the
ethos of this overall A4, I think you just put it really nicely,
David. The analysis should be informing the policy, not the other
way around. Right. And so there's another variation on this
that's called breakeven analysis that's also talked about in the
new A4. It's a similar kind of idea that let's say we can't
actually put a hard number to the benefits, we can't monetize it
for whatever reason, but can we figure out sort of like, what's
the threshold that if we think the benefits are above that
number, then we know we more than break even.


So even if we can't put a hard number to the benefits, we know
with good certainty that the benefits are above this level of
what the cost might be. And so these are all imperfect, right. I
think for folks who are wary of quantified and monetized
cost-benefit analysis, I think these will not get you all the way
there from that critique. But what it does do is give you a lot
more options to say, let's stop shoehorning good policy judgment
into an old straitjacket process.


David Roberts


Right. Another of the Biden administration's big priorities, big
pushes, is to bring the public more fully into these
deliberations.


Sabeel Rahman


Yep.


David Roberts


And I just wonder, I have a couple of questions about that. One
is just what does A4 say about that? In what way do you recommend
that agencies do this?


Sabeel Rahman


I'm really glad you asked this because this is also something I
feel super strongly about and I think they've done some good work
on this. So alongside A4, the President also issued, when the new
A4 came out, an Executive Order, which included some new
requirements around public participation. So one, it's a much
stronger emphasis for the agencies to do more proactive early
engagements with impacted constituencies as they're designing
their rules. So by the time a rule comes into OIRA review, a lot
of it is I don't want to say cooked already, but a lot of work
has already been done.


And a lot of times it's much more impactful and meaningful to
have robust public participation earlier in the process,
especially if you're talking about underserved constituencies or
impacted groups, right? Those are the voices that you need to
hear early on. So there's a general charge under this
administration in a number of different Executive orders
actually, to press agencies to do more of that proactive early
engagement. Then there is a switch to the OIRA review process
itself to open up that process to more participation as well. So
right now, an interested party could request a meeting with OIRA
when they're reviewing a rule to give their views.


It's kind of a wonky thing. Not that many people know about it.


David Roberts


How is that different from public comment?


Sabeel Rahman


It's very similar to public comment, but it basically takes place
during the OIRA review process before the rule goes out for
public comment. And the rationale is there might be nuances or
details that if you're from an impacted community, you might have
some additional information that might be worth making sure is
emphasized or shared as an input. Those are not backs and forths.
Right. They're basically listening sessions. But the new
Executive Order continues that practice and charges OIRA with
making that much more accommodating and inclusive, especially to
historically marginalized communities, communities whose voices
may not have sort of K-Street lobbyists, right. Easy for them to
go.


And then the last thing that it does, it also puts a lot more
meat on this process that's called petition. So communities,
civil society groups, individuals can petition agencies to push
them to take action on an issue that maybe the agency hasn't
thought about before or hasn't been as proactive on those
petitions, then kind of sit there. The new process creates some
more coordination so that when someone brings a petition, OIRA is
also aware of that.


OIRA can then also sort of check with the agency, like, hey, this
petition, what's the response to this petition? How are we
responding to the needs that folks are bringing to you? So these
are a lot of little pieces here and there but the sum total of it
is to try to improve that participatory and inclusive aspect of
the rulemaking process.


David Roberts


Well, one other question about that, which is I'm sure you're
aware of the sort of larger conversation going on around
liberalism these days which is that it's become slow and that
NIMBYs are stopping everything and it's hard to build anything
and it's hard to move quickly. And basically we've become
sclerotic. And sometimes that critique takes the form of saying
basically like the public has too many ways of inserting itself
and exercising a veto here and we need to streamline things and
do things faster. And this seems intuitively on the surface at
least, to tack against that.


So how do you think about the kind of need for moving
expeditiously relative to the need for public participation?


Sabeel Rahman


Right, it's such an important question. I'm glad you asked it. I
think there are two things to bear in mind. One is just on these
proposals here. These are all very much sort of inputs. These are
not decisional or veto types of discussions. Right. So I think
things still move along and the overall time frame of the
regulation OIRA has a clock under the old Executive Order which
has stayed in place for how long it ought to be taking on rules.


David Roberts


Although can we just say it has frequently exceeded that alleged
clock. I remember all the complaining about OIRA that used to go
on when Cass Sunstein was in charge under Obama. Like OIRA was
frequently charged with slow walking these regulations.


Sabeel Rahman


I wasn't there during that time. But one of the things that I'll
say is when there's a delay, usually it's because there's
actually a dispute as opposed to someone's just kind of holding
it up. But one thing I'm really proud of with this administration
and this OIRA is that if you take ARP, for example, we set an
OMB, a two week cap, a two week ceiling on any this is American
Recovery Plan at the height of the economic freefall right in
spring 2021. All that money had to get out the door because the
economy was in such grave danger.


People were hurting right during COVID, so we set and we kept to
a two week turnaround. Every single piece of ARP policy came
through OIRA, went through OIRA review and was done in two weeks
or less because we had to, right? And I say that to say where
there's will and focus and dedication, the process moves. And one
thing I really like about this administration's approach is that
it has tried to balance we got to get stuff done with. We got to
also kind of have evidence and do things robustly. So to come
back to participation then I think that the critiques are
important and well founded.


But to my mind it's not a choice between participation or
effectiveness, it's a question about what kind of participation
to make the policies effective. So you're not going to have good
policy if you don't hear from the people you need to hear from.
But b, there's a way to hear from them in a way that is
efficient. Right. This is why that upstream early engagement is
so valuable because you get everyone together, you get all the
inputs you need and then you design the policy right the first
time around and then you don't have to have 50,000 kind of
nipping at your heels types of conversations downstream.


People are going to disagree, that's fine, you can litigate
disagreements at the next election or with the next regulation or
whatever, but that doesn't mean we shouldn't be hearing from
people.


David Roberts


Yeah, and there is a value just to being heard. I think a lot of
people, they might not say this explicitly, but I think a lot of
these groups will feel like there's progress being made just if
they are convinced that they are genuinely having a voice in
this.


Sabeel Rahman


And that's something I saw a lot of in the time I was in
government too, that it is really important the government serves
the people and it's hard to convince people you're serving them
if you're not actually hearing from them or seeing them. Right.
And that doesn't mean that you have to do everything that
everyone says because we have a big country. But I do think
that's an important piece of this.


David Roberts


What's the process now? So this is A4 and A94 have been put out
for both public comment and peer review, which are separate
processes. So what happens next? What's the road?


Sabeel Rahman


So over the next maybe couple of weeks, there's still some time
left in the public comment period. So if you have listeners who
might have views about either of these documents after listening
to this, they should absolutely weigh in, particularly if they
have expertise on some of these issues. So public comment is
ongoing that will close in a couple of weeks ...


David Roberts


Kind of pause there on public comment. I'm just curious if you
have any sense or guesses about how public comment is going to
unfold. My gut instinct is because most of these changes will
have the effect of making it easier to pass big regulations in
the public interest, that industry is just going to knee jerk, be
against them and rail against them in public comment. Is that
sort of how you expect public comment to shape up this sort of
like public interest groups versus industry yet again? Or is
there more nuance to it?


Sabeel Rahman


I hope it ends up being more nuance than that because there's a
lot here. Obviously. I think that's anytime you're talking about
regulation, we live in the world, we have to be attuned to that
dynamic. But I think my hope would be that there's enough here
that is evidence based, empirically, rigorous, and just like
obvious updates, right? Like what you're talking about on
discount rate and on distribution analysis and so on, that I hope
we'll get a range of comments. It'll be particularly important,
too, to sort of get comments from the field, as you were saying,
from economists, but also anthropologists and sociologists and
people who are working it in community on the grassroots level
about what kind of distribution analysis will actually help, you
know, make sure their voices are counted right.


Like, I think we want to cast it open so it's not just the same,
you know, conventional wonks as as much as we do want to hear
from them too.


David Roberts


Industry lawyers.


Sabeel Rahman


Right. I think a bigger set would be lovely because this is some
of the source code of an executive branch that can honest to God
serve the public interest and serve all of us. I really believe
that. So I hope we hear from more people. So first there's
comments. Once that comment period wraps up, the peer review
should be happening. I'm not sure exactly when, but I assume
they'll be doing it in parallel to that because peer review can
take a long time.


David Roberts


And is this peer review just like the same that academics are
familiar with?


Sabeel Rahman


Yeah, exactly. It's meant to be a similar process. So the
government actually has a pretty standard peer review process for
technical documents that this review, I assume, will be
following. And that's modeled on sort of scientific, academic
peer review procedures. So that will go for a couple of months as
well. And then these documents should be finalized. The timeline
they gave was no longer than a year. Basically by play it forward
a few more months, maybe it's a little sooner, maybe it's a
little later, but I think it's going to move pretty quickly,
especially once the comment period closes, just because this is
way overdue and is important.


David Roberts


And you think these will be finalized in time to actually inform
the writing of substantial regulations from the Biden
administration?


Sabeel Rahman


I hope so. I think that certainly is the goal with this charge
coming out on day one and then now the full proposal out here at
the start of year three. So I really hope that's the case.


David Roberts


And once they're in place, I guess I'm wondering how resilient
they are. Like, if there's a DeSantis administration in 2024, is
there anything stopping them from just ripping these up and going
back to something older? Do these have any resilience against
political chicanery or an administration can do what it wants?


Sabeel Rahman


That's a tricky question in a world where when you look at what's
happening in places like Florida and elsewhere. I think what ...
I'd say two things about that. One is that it is meant to have
staying power. And part of the point of making sure this document
goes through peer review and goes through public comment and goes
through all the things that a long lasting, non political
technical document ought to go through. This is that kind of
enterprise. And so the old A4 lasted for 20 years, and this new
version is very much an update to that.


It's not junking the old enterprise at all. So I think the hope
would be that that would continue. Now, that said, when you have
people on the right continuing to organize around things like
Schedule F, the Trump administration's plan to junk most civil
service protections, for example, there's a lot of stuff that is
brewing on the right. Just to say that is really aimed at
destroying a well functioning, evidence based and transparent
bureaucracy. But that's a broader question. That's not an A4
question. That's a broader question for all of us to say that,
okay, yes, we're having a debate about policy and about all sorts
of kind of horrifying other things that are happening too, on the
far-right.


But at some point, we got to say, if we got to have a government
that serves the public understanding that the public doesn't
always agree on a lot of policies, we can do that, right? We can
do that with evidence and with transparency and with good
procedures that allow for participation and evolution of ideas.
There's a way we can do that. It's possible to have a government
in this country that is effective and that deals with our
complexity and our diversity, but not if you have bad actors who
come in with a desire to bring a wrecking ball, right?


David Roberts


If they want to come nuke the administrative state, A4 is not
going to stop them.


Sabeel Rahman


Right. And I think it's sort of for all of us who care about
these issues, I think it's important for us to care about wonky
stuff like A4. But I also think it's important for us to care
about those kinds of existential threats to the project of shared
collective government in the first place.


David Roberts


Yes. Alright, well, that seems like a great place to wrap up
Sabeel Rahman, this has been so helpful, so clarifying, and I
love getting into the wonky guts of stuff because, as you say,
it's a source code. It's going to affect everything that comes
out of the government after this. So it's really great to get a
clear view of it. Thanks so much for coming on.


Sabeel Rahman


Yeah, thanks, David, for having me. This was great.


David Roberts


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