Called the "Paperwork and Regulatory Improvements Act of 2004," H.R. 2432 moved from its subcommittee directly to markup by the full government reform committee May 13. The House as a whole has yet to take up the bill but could do so very soon now that it is being reported out of committee.

H.R. 2432 calls for the following:

• Making the case for regulatory budgeting. The bill would move us closer to "regulatory budgeting," a dangerous concept that treats the vital protections of public health, safety, and environment as though they were gratuitous expenses that must be rationed. The ultimate vision of regulatory budgeting is a world in which the economists have the final say on our public safeguards, as incalculable and literally priceless benefits, such as lives saved, irreplaceable natural resources conserved, and diseases prevented, are turned in cash-dollar figures and weighed against the costs to industry of complying with new protective rules. Our safeguards could then be "budgeted" and subjected to arbitrary caps. H.R. 2432 will bring us closer to this nightmare scenario by having the White House study the feasibility of regulatory budgeting, in the process using taxpayer dollars to create the data that will be used to make the case for turning the vision of regulatory budgeting into a frightening reality.
• Hiding the anti-regulatory agenda. The bill would also require the White House to incorporate its annual report on the costs and benefits of regulation into its annual budget papers. This annual report lays out an anti-regulatory agenda and has been the platform the White House uses to invite industry to nominate public safeguards to be added to a "hit list." Given its important role in anti-regulatory policy, this report should not be buried under the arcana of budget issues. This section of the bill would also advance the regulatory budgeting agenda by re-framing our public safeguards as "off-budget costs."
• Slowing the process. This bill would further slow down the regulatory process by increasing the analysis that proposed rules have to go through. One section would establish that yet another arm of the government, this time Congress' own General Accounting Office, will be required to conduct its own cost-benefit analysis of proposed regulations — even though the agency and, many times, OMB as well have already conducted their own analyses. Cost-benefit analysis takes a lot of time, demands a large investment of resources, and produces very little benefit except to industry, which such analyses typically favor.

The bill also taps into understandable frustrations with IRS paperwork to advance a larger agenda that could limit the collection of information needed to make sure our public safeguards are effective. No one loves "red tape," but the cause of cutting red tape has left us with the Paperwork Reduction Act, a seemingly benign law that calls for mandatory reductions of all federal information collections, including the gathering of data intended to serve the public interest. One section of H.R. 2432 would advance the "paperwork-reduction" effort by studying ways to reduce IRS paperwork "burdens" on small business. Definitions of "small business" would include, in some cases, multimillion dollar corporations that are leaders in their respective fields but have small numbers of employees.