Thursday, June 9, 2011

It doesn't actually matter

I said that how the blackmail project got started was just one problem with it. (No, that's not what I call it in general, but I can't think of anything better right now.) What else is wrong with it?

For one thing, our contacts on that other agency don't know the usual rulemaking process. It's just not their usual job. This leads to us talking past each other about the timeline. Nobody likes to go to their boss and say that they're going to miss a deadline, of course, but despite being told, they seem unable to grasp that the time to do so on this project is right around now. Relatedly, their idea of a quick turnaround time on reviewing a document is measured in weeks, not days. Any instance of that isn't a problem, but a few days of delay over and over again add up.

Another problem is that the economist doesn't know where to start, and at least from where we sit, it seems the people from the other agency aren't helping. Right now he could write an economic analysis which would show moderate costs - not huge, this is basically just a survey, although there's also an ongoing part of it, but significant enough that we have to justify them - paired with absolutely zero benefits. We can't cite the rulemaking that this was the price of because we can't mention the quid pro quo aspect of the rulemaking in public documents. Yes, of course it's all perfectly legal, it's just part of the sausage-making process. And for all I know we actually might mention it, but it can't be part of the legal or economic basis for this rule. The other agency's people are asking him to send them that and then they'll fill in the benefits. This seems nonsensical from our point of view.

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