Interesting scholarly article reviewing the Bush administration's distortions of the regulatory process, particularly the "reforms" championed by OIRA head John Graham: This article is a review of the regulatory process reforms championed by John Graham's OIRA. Rather than attempting to view them as pro-regulation or antiregulation, I believe it is more useful to ask to whom these various regulatory reforms give power in the regulatory process and whether or not they raise the cost of issuing a regulation. This paper will show that many of these reforms empower the President and those with access to the executive office of the President. Many also raise the cost of the regulatory process to agencies. The second of these impacts is clearly anti-regulatory in its results but the first is not necessarily so. This article will argue for a more accurate criticism of the Graham reforms: that they will concentrate rulemaking power in a small group of elites. The reforms have further tipped the balance of power in regulatory policy toward powerful interest groups and away from agency bureaucrats, private individuals, and small businesses. While e-rulemaking in particular has been sold as opening up the regulatory process, it is being implemented in a way that is more likely to render the public comment process meaningless than to increase the impact of public involvement (Noveck 2004). Download Stuart Shapiro, "An Evaluation of the Bush Administration Reforms to the Regulatory Process"