How not to spend a summer vacation – cleaning out the rule books.

31 May 2011

The State of Michigan Department of Licensing and Regulatory Affairs recently announced the appointment of 12 people to an  Environmental Advisory Rules Committee. The Office of Regulatory Reinvention’s (the ORR) stated goal for this group is to identify duplicative, obsolete, unnecessary or unduly restrictive environmental rules.

The group includes two environmental lawyers from large corporate firms, a representative from each of the State’s largest utilities, a County government official, an environmental engineer from a statewide consulting firm, a representative of the Michigan Manufacturers Association, a Dow Chemical employee, someone from the Attorney General’s office, the DEQ policy director (who last was with the MMA) and the policy director from the Michigan Environmental Council. In short, this is a very pro-business group.

While I agree with the charge to identify onerous rules that hurt job creation without providing significant social benefit, I wonder how much this group can get done in the mere 120 days allocated to it. I also am a firm believer that the issue in Michigan is far less with the rules than it is with the goals and intentions of the MDEQ staff interpreting those rules. I think that you could (not that I’m advocating for this) wipe out all the environmental rules and rather than creating more jobs and lessening the regulatory burdens, the MDEQ staff will (if they want to) find ways to impose even more burdens on Michigan’s economy, often without any commensurate benefits.

The ORR will submit its findings and recommendations to the Governor, based in part on the reports from the various committees appointed.  I’m not saying that this exercise is a waste of time but I think devoting efforts to greater staff accountability to the Legislature’s goals would be a better use of the Summer of 2011.

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