Omg I’ve been worrying about the cases Ann mentions like Sherley v Sebelius in DC circuit these past few months (holding that agency is exempt from APA when directed by Pres) - so wrongly decided.

OIRA's going to need resources. True, there will likely be fewer rules to review (see the 10-for-1 EO), but implementing this doozy, alongside reg budgets, restarting the review of tax regs all on top of its Paperwork Reduction Act duties is...a lot

Requirement that independent agencies regularly consult with OMB, "the White House Domestic Policy Council, and...National Economic Council" shows an intent to influence agency rules ex ante not just ex post through OIRA review (am writing a paper on this, which now feels kind of quaint)

On OMB budgetary oversight, "adjustments to apportionments may prohibit independent regulatory agencies from expending appropriations...so long as consistent with law." Calling for illegal impoundment while pretending you're following the law is...something

"The President and the Attorney General...shall provide authoritative interpretations of law for the executive branch." Given that provision is aimed at federal "employees," am guessing its meant to rein in staff legal guidance and the exercise of subdelegated authorities

But the carve out for the Federal Reserve's monetary policy functions shows just strong that norm (amazingly) still is

First, on coverage: it goes out of its way to include the Federal Election Commission - very ominous given that Trump just fired the chair. Kind of obvious why we don't Trump anywhere near campaign finance regs

Some wondered whether Trump would extend OIRA review to independent regulatory agencies. While he didn’t do so in this EO, he could still try to use the Congressional Review Act as a hook for oversight as he did in his first term

Also reinstates OIRA review of tax regulations as @khickmanjd.bsky.social observes. Robust debate about how benefit-cost analysis could be sensibly applied here, but more EOP oversight is probably a good thing

No regulation shall be issued unless included in recent version of the Unified Regulatory Agenda. Could amount to a huge drag on new regs because the Agenda is only published *semiannually.* EO says Agenda can be "updated," but will be another procedural hurdle regardless

Calls for revocation of Circular A4, which provides guidance on benefit-cost analysis. Will reinstate previous Bush-era version, which is better than none at all. The Regulatory Right to Know Act arguably requires notice-and-comment for a revocation and reinstatement, but not holding my breath

10-for-1 includes a broader definition of "rules" than the 2-for-1: "regulations, rules, memoranda, administrative orders, guidance documents, policy statements, and interagency agreements." Lots for FAQs to clean up to minimize nonsense (we don't want agencies to cooperate?)