Notice & Comment

Scholars’ Letter in Support of Neomi Rao Nomination as OIRA Administrator

rao_neomi_bannerNext Wednesday, June 7, at 10:00AM the Senate Homeland Security and Governmental Affairs Committee (HSGAC) will hold its hearing on the nomination of Neomi Rao to serve as the Administrator of the Office of Information and Regulatory Affairs — a position which is been dubbed the President’s “regulatory czar.”

This morning we submitted to HSGAC a letter from an ideologically diverse group of scholars of administrative law, constitutional law, and regulation in support of Rao’s nomination. You can download the letter here, and here is the text of the letter:

We, the undersigned scholars of administrative law, constitutional law, and regulation, write in support of Professor Neomi Rao’s nomination to be Administrator of the Office of Information and Regulatory Affairs (OIRA).

As scholars, we hold diverse views on administrative law, constitutional law, and regulatory policy. But we agree that Professor Rao is well qualified to administer OIRA, under the statutes and executive orders that govern the office.

Professor Rao’s scholarship is well regarded within the academy, even by those who may disagree with aspects of it. She is an intelligent, thoughtful, and careful scholar who knows a great deal about how federal agencies function and the relevant laws within which they operate.

Professor Rao has also contributed to public understanding of these issues as an appointed member of two important bodies: the Administrative Conference of the United States, and the governing council of the American Bar Association’s Section of Administrative Law and Regulatory Practice. And she will no doubt bring important experience to the office from having worked in all three branches of the federal government as well as in private law practice.

Finally, the Center for the Study of the Administrative State, which Professor Rao founded and directs, has fostered dialogue among scholars and policymakers, by supporting the development of legal scholarship by scholars from widely diverse viewpoints, by hosting workshops where scholars can debate and collaborate on these papers, and by holding policy conferences open to the public to further explore this scholarship and current issues in administrative law and regulatory practice. Many of us have participated directly in the Center’s work, as authors or discussants, and even more of us have benefited from the dialogue created by her Center’s efforts.

Our nation would be well served by Professor Rao’s open-mindedness, her intellectual seriousness, and her dedication to collaboration and dialogue.

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