[House Report 104-49]
[From the U.S. Government Publishing Office]



104th Congress                                             Rept. 104-49
                        HOUSE OF REPRESENTATIVES

 1st Session                                                     Part 1
_______________________________________________________________________


 
                 REGULATORY FLEXIBILITY ACT AMENDMENTS

                                _______


               February 23, 1995.--ordered to be printed

_______________________________________________________________________


Mrs. Meyers of Kansas, from the Committee on Small Business, submitted 
                             the following

                              R E P O R T

                        [To accompany H.R. 937]

      [Including cost estimate of the Congressional Budget Office]
    The Committee on Small Business, to whom was referred the 
bill (H.R. 937) to amend title 5, United States Code, to 
clarify procedures for judicial review of Federal agency 
compliance with regulatory flexibility analysis requirements, 
and for other purposes, having considered the same, report 
favorably thereon with amendments and recommend that the bill 
as amended do pass.
    The amendments (stated in terms of the page and line number 
of the introduced bill) are as follows:
    Page 6, line 17, strike the closing quotation marks and the 
final period and insert the following:

          ``(4) Special rule.--Any proposed rules issued by an 
        appropriate Federal banking agency (as that term is 
        defined in section 3(q) of the Federal Deposit 
        Insurance Act (12 U.S.C. 1813(q)), the National Credit 
        Union Administration, or the Office of Federal Housing 
        Enterprise Oversight, in connection with the 
        implementation of monetary policy or to ensure the 
        safety and soundness of federally insured depository 
        institutions, any affiliate of such an institution, 
        credit unions, or government sponsored housing 
        enterprises or to protect the Federal deposit insurance 
        funds shall not be subject to the requirements of this 
        subsection.''.
                                Purpose

    The primary purpose of the bill is to provide and clarify 
procedures for judicial review of agency compliance with the 
Regulatory Flexibility Act, P.L. 96-354, 5 U.S.C. Sec. 601 et 
seq. An additional purpose of the bill is to require federal 
agencies to work more closely with the SBA Chief Counsel for 
Advocacy, who is charged with monitoring compliance with the 
Regulatory Flexibility Act, during the drafting of new rules. 
Finally, the bill contains a ``sense of Congress'' provision 
that the SBA Chief Counsel for Advocacy be allowed to appear as 
amicus curiae in any federal court for the purpose of reviewing 
a federal rule.

                                Summary

    In brief, H.R. 937 is intended to do three basic things.

A. Judicial review

    Section 1 would amend Section 611 of Title 5 to allow and 
clarify the procedures for judicial review of agency compliance 
with the Regulatory Flexibility Act (RFA). Section 611 as it 
currently exists prohibits court challenge of an agency 
determination of the applicability of the RFA, and prohibits 
court review of any regulatory flexibility analysis or 
certification prepared under the Act. In practice, this 
prohibition on judicial challenges has allowed agencies to 
ignore the letter and spirit of the RFA.
    The primary features of the new judicial review provision 
provided by this bill are:
          (1) A small entity can only seek judicial review 
        arising from a final rule;
          (2) The judicial review can be for either a wrongful 
        certification that the rule will not have a significant 
        economic impact on a substantial number of small 
        entities or a flawed or totally absent final regulatory 
        flexibility analysis;
          (3) The small entity seeking judicial review must do 
        so within 180 days of the effective date of the final 
        rule. However, if some other provision of law requires 
        a lesser time for judicial review of a final agency 
        rulemaking action, then the lesser time prevails. This 
        additional feature is designed to avoid multiple 
        reviews of final agency actions by the courts; and
          (4) Agencies will be allowed a short period (90 days) 
        in which to correct regulatory flexibility defects. 
        After that time, a reviewing court can stay the 
        operation of the rule or provide whatever relief it 
        deems appropriate.

B. Earlier involvement in the rulemaking process by the SBA Chief 
        Counsel for Advocacy

    While the primary intention of this legislation is to 
strengthen agency compliance with the Regulatory Flexibility 
Act, it is also the intention to require agencies to work more 
closely with the SBA Chief Counsel for Advocacy,\1\ who is 
charged with monitoring compliance with the Act, during the 
drafting of new rules.
    \1\ The Office of Advocacy within the Small Business Administration 
was created in 1976. The management of the Office is vested in a Chief 
Counsel for Advocacy, who is a Senate-confirmed Presidential appointee. 
P.L. 94-305, 15 U.S.C. Sec. 634a et seq. The original Regulatory 
Flexibility Act placed oversight responsibility for implementation of 
the RFA in the hands of the Chief Counsel for Advocacy. 5 U.S.C. 
Sec. 612.
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    Section 2 of the legislation would amend Section 612 of 
Title 5 to require that, when an agency is drafting a new rule, 
the agency must provide the SBA Chief Counsel for Advocacy with 
an advance copy of the rule 30 days before publishing a general 
notice of proposed rulemaking in the Federal Register pursuant 
to the provisions of the Administrative Procedure Act. See 5 
U.S.C. Sec. 553(b).
    The purpose behind this provision of the legislation is to 
attempt to involve the SBA Chief Counsel for Advocacy in 
securing agency compliance with the Act at the earliest 
possible time and to allow agencies to benefit from the Chief 
Counsel's views before the rule is in the public domain. The 
proponents of this provision believe that in certain 
circumstances agencies may be reluctant to retreat from certain 
regulatory approaches once those approaches have become public, 
even if only in the form of preliminary rules.\2\
    \2\ At the Committee's oversight hearing on the Regulatory 
Flexibility Act held on July 28, 1993, James W. Morrison, appearing on 
behalf of the National Association for the Self-Employed and the 
Regulatory Flexibility Act Coalition, stated that this advance 
notification provision would also serve to remedy the relative 
inadequacy of the regulatory agendas provided to the SBA Chief Counsel 
for Advocacy pursuant to the requirements of Section 602 of Title 5 
(the RFA).
    An exception to this advance notification approach is made 
in this provision for draft proposed rules of certain banking 
agencies. This exception or special rule is the result of the 
only amendment to the bill considered by the Committee, which 
was passed by voice vote.

C. Authority of the SBA Chief Counsel for Advocacy to appear as amicus 
        curiae

    The RFA currently gives the Chief Counsel authority to file 
amicus briefs in litigation involving federal rules, which 
allows him to express the views of the Chief Counsel with 
respect to the effect of the rule on small entities. In the 
history of the RFA, this has only been done once, in the 1986 
case of Lehigh Valley Farmers. At that time, the Justice 
Department indicated that this amicus provision was 
unconstitutional because it would impair the ability of the 
Executive branch to fulfill its constitutional functions. The 
SBA Chief Counsel for Advocacy countered this argument with 
legal arguments of his own. The Justice Department also argued 
that Executive Order 12146, section 1-402, prevents the Chief 
Counsel from filing such briefs. Section 1-402 of Executive 
Order 12146 requires that when such a legal dispute exists 
between two agency heads which serve at the President's 
discretion, such dispute shall be submitted to the Attorney 
General for resolution. The SBA Chief Counsel countered with 
case law supporting the principle that an Executive Order 
cannot supersede a statute, and therefore Executive Order 12146 
cannot prohibit the SBA Chief Counsel for Advocacy from 
appearing as amicus curiae since 5 U.S.C. Sec. 612 provided for 
such action.
    After a great deal of debate between the Justice Department 
and the SBA Chief Counsel for Advocacy, the Chief Counsel 
eventually withdrew the amicus brief filed in the Lehigh Valley 
Farmers case. No Chief Counsel has filed an amicus brief 
since.\3\
    \3\ See Appendix D to this report, which is a Memorandum prepared 
by the American Law Division (Congressional Research Service) of the 
Library of Congress, dated October 22, 1993, which provides an analysis 
of the constitutional issue raised by the Justice Department concerning 
5 U.S.C. Sec. 612(b).
    In September of 1994, the SBA Chief Counsel for Advocacy filed 
notice of intent to file an amicus brief in Time Warner Entertainment 
Limited Partnership v. Federal Communications Commission, No. 93-1723 
(D.C. Cir.), but came to an accord with the FCC, thereby avoiding the 
need to file an amicus brief.
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    The ability to appear as amicus curiae is important to the 
ability of the SBA Chief Counsel for Advocacy to represent the 
interests of small businesses in the rulemaking process. 
Furthermore, if this bill should become law, with its provision 
to permit judicial review of agency compliance with the 
Regulatory Flexibility Act, the importance of the Chief 
Counsel's ability to file amicus briefs will be magnified.
    Section 3 of this bill is a ``sense of Congress'' provision 
reaffirming what the Congress had already passed in 1980.

                          Need for Legislation

                What is the Regulatory flexibility act?

    The Regulatory Flexibility Act (RFA) was enacted in 1980 to 
force federal agencies to take into consideration the impact 
their regulations will have on small entities before they go 
into effect, and to attempt to minimize that impact.
    As stated in the text of the Act, ``[i]t is the purpose of 
this Act * * * that agencies shall endeavor * * * to fit 
regulatory and informational requirements to the scale of the 
businesses, organizations, and governmental jurisdictions 
subject to regulation. To achieve this principle, agencies are 
required to solicit and consider flexible regulatory proposals 
and to explain the rationale for their actions to assure that 
such proposals are given serious consideration.'' \4\
    \4\ See Congressional Findings and Declaration of Purpose, Section 
2 of P.L. 96-354, now codified in the footnote to 5 U.S.C. Sec. 601.
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    Under the RFA, for proposed rules which are subject to 
publication in the Federal Register and public comment under 
the Administrative Procedure Act (APA), the rule-writing agency 
must also prepare an initial regulatory flexibility analysis 
describing the impact the rule may have on small entities. The 
analysis must also outline alternatives to the proposed rule 
which would accomplish the same objectives with a lesser impact 
on small entities.
    At the time of publication of the final rule, the RFA 
requires agencies to publish a final regulatory flexibility 
analysis, which summarizes public comments on the initial 
analysis, the agency response, and changes made to the rule as 
a result. If the agency did not adopt these less burdensome 
alternatives, an explanation must be provided.
    Proposed or final rules are not subject to these analyses 
if the head of the agency certifies that the rule will not have 
a significant economic impact on a substantial number of small 
entities. This certification must be published in the Federal 
Register and include an explanation of the reasons for the 
certification.
    In addition to these provisions, which function as part of 
the regular rulemaking process, the RFA requires agencies to 
publish regulatory flexibility agendas twice each year, 
outlining rules which the agency believes it may propose in the 
future that would significantly affect small entities. The RFA 
requires agencies to take certain steps to afford small 
entities the opportunity to participate in the rulemaking 
process. Finally, the RFA provides for the review of rules with 
a significant impact on small entities within ten years after 
they have gone into effect.
    The RFA charges the SBA Chief Counsel for Advocacy with the 
responsibility of monitoring agency compliance with the Act.
        why the regulatory flexibility act needs to be amended?

    Currently, Section 611 of Title 5 states in part ``* * * 
any determination by an agency concerning the applicability of 
the provisions of this chapter to any action of the agency 
shall not be subject to judicial review.''
    The RFA allows agencies to certify that their rules do not 
have a significant impact on small entities, and therefore 
avoid conducting regulatory flexibility analyses. The 
prohibition of judicial review allows no legal challenge to 
such a determination nor does it allow a challenge to a flawed 
regulatory flexibility analysis. The result is that compliance 
with the RFA is voluntary and federal regulators do not face 
court action for failure to comply.
    Replacing the current Section 611 is the single most 
important step which can be taken to force agencies to fully 
consider the impact of their rules on small entities. Unless 
regulators face the possibility of court challenge to their 
actions they may not comply with the RFA. The Act needs to be 
amended to provide judicial review so that needed ``teeth'' are 
put into the law.
    The RFA directs the SBA Chief Counsel for Advocacy to 
monitor RFA compliance. However, the ability to do so has been 
limited. The proposed legislation would force agencies to work 
more closely with the Chief Counsel during the rulemaking 
process. Agencies would be required to provide the Chief 
Counsel with copies of rules 30 days before they are proposed, 
and he would have the opportunity to present the concerns or 
opposition of small entities to the proposed rule. The agency 
would then be required to respond to these concerns. It is 
hoped that the proposed provision will give greater 
encouragement to regulators to minimize the impact of their 
rules on small entities before the rules are proposed.
    Finally, the RFA as passed in 1980 grants the SBA Chief 
Counsel for Advocacy the authority to appear as amicus curiae 
in court cases which involve the review of federal rules. 
However, when the Chief Counsel filed an amicus brief in 1986, 
the Justice Department challenged the constitutionality of this 
authority. After much discussion, that brief was withdrawn and 
the question has never been resolved. The ability of the Chief 
Counsel to represent small entity views in court is critical. 
The amendment to the RFA contained in this legislation contains 
a ``sense of Congress'' provision reaffirming the position 
Congress took in passing the original RFA: that the Chief 
Counsel does have the authority to file amicus briefs in court 
cases which involve the review of federal rules.

                               Background

A. The Regulatory Flexibility Act

    The Administrative Procedure Act (APA) \5\ requires federal 
agencies to promulgate rational rules. The APA provides the 
primary mechanism for accomplishing this task--notice and 
comment rulemaking. The Regulatory Flexibility Act, which was 
signed into law in 1980,\6\ is another tool to assist agencies 
in fulfilling their statutory mandate under the APA. The 
regulatory Flexibility Act (RFA) is based on two premises: (1) 
That federal agencies often do not recognize the impact that 
their rules will have on small entities; \7\ and (2) that small 
entities are disproportionately disadvantaged by federal 
regulations compared to their larger counterparts.
    \5\ 5 U.S.C. Sec. 551 et seq.
    \6\ The Regulatory Flexibility Act was the result of efforts of 
many small businesses throughout this country. The issues of regulatory 
relief and regulatory flexibility were a dominant theme at the 1980 
White House Conference on Small Business, and the participants involved 
in that conference pushed for legislative action. In addition to these 
grass roots activities, the U.S. Congress spent an extensive amount of 
time during the late 1970's examining the need for regulatory 
flexibility. See, generally, Regulatory Flexibility Act, S. 1974, Part 
1: Hearings Before the Subcomm. on Administrative Practice and 
Procedure of the Senate Judiciary Comm., 95th Cong., 1st Sess. (1977); 
Regulatory Flexibility Act, S. 1974, part 2: Joint Hearings Before the 
Subcomm. on Administrative Practice and Procedure of the Senate 
Judiciary Comm. and the Senate Select Comm. on Small Business, 95th 
Cong., 2d Sess. (1978); H.R. 7739 and H.R. 10632, Small Business Impact 
Bill, Part 1: Hearings Before the Subcomm. on Special Small Business 
Problems of the House Small Business Comm., 95th Cong., 2d Sess. 
(1978); H.R. 7739 and H.R. 10632, Small Business Impact Bill, Part 1: 
Hearings Before the Subcomm. on Special Small Business Problems of the 
House Small Business Comm., 95th Cong., 2d Sess. (1978); H.R. 77399 and 
H.R. 10632, Small Business Impact Bill, Part 2: Hearings Before the 
Subcomm. on Special Small Business Problems of the House Small Business 
Comm., 95th Cong., 2d Sess. (1978); Impact of Federal Regulation on 
Small Business: Hearings Before the Subcomm. on Special Small Business 
Problems of the House Small Business Comm., 96th Cong., 1st Sess. 
(1979); Regulatory Reform, Part 3: Hearings Before the Subcomm. on 
Administrative Practice and Procedure of the Senate Judiciary Comm., 
96th Cong., 1st Sess. (1979); Regulatory Reform, Part 4: Hearings 
Before the Subcomm. on Administrative Practice and Procedure of the 
Senate Judiciary Comm., 96th Cong., 1st Sess. (1979); Regulatory Reform 
Act of 1979, Part 1: Hearings Before the Subcomm. on Administrative Law 
and Governmental Relations of the House Judiciary Comm., 96th Cong., 
1st Sess. (1979); Regulatory Reform Act of 1979, Part 2: Hearings 
Before the Subcomm. on Administrative Law and Governmental Relations of 
the House Judiciary Comm., 96th Cong., 1st and 2d Sess. (1979 and 
1980).
    \7\ Under Sec. 601(6) of Title 5, the ``small entities'' intended 
to benefit from the Act are ``small organizations,'' defined to include 
any nonprofit enterprise which is independently owned and operated and 
is not dominant in its field (5 U.S.C. Sec. 601(4)); ``small 
governmental jurisdictions,'' defined to include governments of cities, 
counties, towns, townships, villages, school districts, or special 
districts with a population of less than 50,000 (5 U.S.C. Sec. 601(5)); 
and ``small businesses,'' which are the same as ``small business 
concerns'' as defined in Section 3 of the Small Business Act (5 U.S.C. 
Sec. 601(3)). See 15 U.S.C. Sec. 632 (as amended).
    In the late 1970's, a study commissioned by the Office of 
Advocacy of the U.S. Small Business Administration confirmed 
that scale economies exist in complying with a diverse variety 
of federal regulations. In each case, the study revealed that 
larger firms can comply with various types of governmental 
regulation at a lower cost than small businesses. The 
explanation for this finding is simple--if the cost of 
compliance with a federal regulation is primarily fixed, then 
the smaller firm will suffer a more severe impact since it has 
a smaller output over which to recover the costs of regulation.
    The RFA was enacted to obtain federal agency recognition of 
these effects and consequently to reduce them. The intention of 
the Act is to have agencies approach the entities they regulate 
with an eye to their size and take this into account in 
drafting rules rather than approaching rulemaking with a ``one 
size fits all'' attitude. If the RFA is properly complied with, 
the primary goals of the APA should also be satisfied because 
the RFA should cause agencies to write better rules. By 
mitigating the impact of regulation on small businesses, the 
viability and health of small businesses will be determined in 
the marketplace and not in a distant federal office.
    The RFA requires federal agencies to assess the impact of 
their regulatory proposals on small entities. Agencies then 
have two options under the statute--performing a regulatory 
flexibility analysis or issuing a certification.
    An agency certifies a rule if it determines that the rule 
will not have a significant economic impact on a substantial 
number of small entities. Announcement of the certification 
must be published in the Federal Register and the certification 
must be accompanied by ``a succinct statement explaining the 
reasons for such certification. * * * '' \8\ Simple boilerplate 
statements that the rule will not have such an effect are 
patently inadequate under the RFA. Rather, sufficient analysis 
must be performed to apprise the regulated community of the 
reasons for the certification. Moreover, any doubt as to 
whether a regulatory flexibility analysis should be performed 
must be resolved in favor of performing the analysis.\9\
    \8\ 5 U.S.C. Sec. 605(b).
    \9\ Statement of Rep. Andy Ireland, 126 Cong. Rec. 24585 (September 
8, 1980).
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    An agency determination which reveals that the proposed 
rule in question will have a significant economic impact on a 
substantial number of small entities leads to a requirement 
that the agency prepare an initial regulatory flexibility 
analysis (IRFA) and publish it in the Federal Register. This 
analysis must contain: (1) A description of the reasons why the 
regulatory action is being considered; (2) a succinct statement 
of the regulatory objectives and legal basis for the proposed 
rule; (3) a description and estimate of the number of small 
entities affected by the agency action; (4) a detailed 
description of the reporting, record keeping, and other 
compliance requirements of the proposed rule; and (5) an 
identification of any duplicative, overlapping or conflicting 
federal regulations.\10\
    \10\ 5 U.S.C. Sec. 603(b)
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    More important than any of these requirements is that the 
analysis must describe and examine significant alternatives to 
the proposal which accomplish the objectives of the agency but 
minimize the economic impact on small entities. Significant 
alternatives may include, but are not limited to: (1) the 
establishment of differing compliance or reporting requirements 
that take into account the resources available to small 
entities; (2) the clarification, consolidation, or 
simplification of compliance and reporting requirements under 
the rule for small entities; (3) the use of performance rather 
than design standards; and (4) exemption of small entities from 
all or part of the rule.\11\
    \11\ 5 U.S.C. Sec. 603(c).
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    When an agency issues its final rule, it must either 
prepare a final regulatory flexibility analysis (FRFA) or again 
certify that the rule will not have a significant economic 
impact on a substantial number of small entities. The FRFA must 
thoroughly discuss comments received by the agency from the 
regulated community and others (i.e., trade associations, other 
agencies or Members of Congress) as well as the alternatives 
considered by the agency while preparing the final rule. The 
most important feature of the provision governing final 
analysis is that in the FRFA agencies must give reasons why 
they did not adopt the alternatives which were presented to the 
agency during the rulemaking process.\12\ While the FRFA is 
normally made available at the same time as the final rule is 
published in the Federal Register, an emergency provision 
contained in the Act provides that the public availability of 
the FRFA can be delayed for up to 180 days.\13\
    \12\ 5 U.S.C. Sec. 604(a).
    \13\ 5 U.S.C. Sec. Sec. 604(b) and 608(b).
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    Both the regulatory flexibility analysis and certification 
process are designed to force federal agencies to articulate 
the potential effects of proposed rules on small entities. This 
process should not be viewed in isolation but rather as an 
integral component of the administrative process and as a 
procedural tool for assisting in the goal of rational 
rulemaking.
    Other substantive provisions of the RFA provide for 
regulatory agendas \14\ and the periodic review of rules.\15\ 
However, these provisions are not now the subject of amendments 
to the Act.
    \14\ 5 U.S.C. Sec. 602.
    \15\ 5 U.S.C. Sec. 610.
    During the 1980's, the implementation of the Regulatory 
Flexibility Act was the subject of several reports by the SBA 
Chief Counsel for Advocacy, as required by 5 U.S.C. 
Sec. 612(a). The Regulatory Flexibility Act was also the 
subject of extensive Congressional oversight.\16\
    \16\ See, generally, Oversight of the Regulatory Flexibility Act 
(Part 1): Hearings before the Subcomm. on Export Opportunities and 
Special Small Business Problems of the House Comm. on Small Business, 
97th Cong., 1st Sess. (1981); Oversight of the Regulatory Flexibility 
Act (Part 2): Hearings before the Subcomm. on Export Opportunities and 
Special Small Business Problems of the House Comm. on Small Business, 
97th Cong., 2d Sess. (1982); Regulatory Flexibility Act: Joint Hearings 
Before the Subcomm. on Regulatory Reform of the Senate Judiciary Comm. 
and the Subcomm. on Government Regulation and Paperwork of the Senate 
Comm. on Small Business, 97th Cong., 2d Sess. (1982); Implementation of 
the Regulatory Flexibility Act: Hearings Before the Subcomm. on Export 
Opportunities and Special Small Business Problems of the House Comm. on 
Small Business, 99th Cong., 2d Sess. (1986).
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B. Recent developments which led to the current legislation

    The current legislative effort to amend the RFA has a 
history which begins almost three years ago.
    On May 1, 1992, a day-long hearing was held before the 
House Republican Research Committee's Task Force on Small 
Business. The focus of that hearing was the impact of federal 
regulations on small business and much of the testimony 
centered on the need to strengthen the Regulatory Flexibility 
Act (RFA). Shortly after that hearing, Rep. Tom Ewing (R-IL), 
having analyzed the materials from the May 1, 1992 hearing, 
began an effort to introduce legislation that would address 
certain problems with the RFA.
    On September 18, 1992, near the end of the 102d Congress, 
Rep. Ewing introduced H.R. 5977, the Regulatory Flexibility 
Amendments Act of 1992. With only a few weeks left in the 102d 
Congress, no action was taken on that measure.
    At the beginning of the 103d Congress, on February 4, 1993, 
Rep. Ewing introduced H.R. 830, the Regulatory Flexibility 
Amendments Act of 1993. This proposal, which was substantively 
identical to H.R. 5977 from the previous Congress, eventually 
garnered 255 bipartisan cosponsors.
    On July 28, 1993, the Committee on Small Business held an 
oversight hearing on the Regulatory Flexibility Act which 
specifically addressed some of the provisions contained in H.R. 
830.\17\
    \17\ Hearing Before the Committee on Small Business on the 
Regulatory Flexibility Act, 103d Cong., 1st Sess. (1993). Serial No. 
103-38.
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    Testifying at this hearing were: Rep. Tom Ewing (R-IL); 
Doris S. Freedman, Acting Chief Counsel for Advocacy, U.S. 
Small Business Administration; William S. Busker, Senior Vice 
President for Law land Finance, and General Counsel and Chief 
Financial Officer, the American Trucking Associations, Inc.; 
Mark W. Isakowitz, Legislative Representative, National 
Federation of Independent Business; Frank E. Lawson, President, 
National Roofing Contractors Association; Leo McDonough, 
President, TEC/Pennsylvania Small Business United, on behalf of 
National Small Business United; James W. Morrison, Director of 
Government Relations, National Association for the Self-
Employed, and representing the Regulatory Flexibility Act 
Coalition.
    The months following the Committee's July 28th hearing 
involved much work by members of the Regulatory Flexibility Act 
Coalition, who pressed for a hearing on H.R. 830 before the 
Committee on the Judiciary's Subcommittee on Administrative Law 
and Governmental Relations.
    In September of 1993, the Report of the National 
Performance Review conducted by Vice President Gore made 
judicial review for the Regulatory Flexibility Act its number 
one recommendation for the Small Business Administration.\18\
    \18\ See Appendix C to this report.
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    On November 18, 1993, the Judiciary Subcommittee on 
Administrative Law and Government Relations held a hearing on 
H.R. 830. In addition to testimony by Rep. Tom Ewing in support 
of his legislation, Rep. Ike Skelton (D-MO) testified on the 
need for strengthening the RFA, and in support of H.R. 830.\19\ 
The witnesses testifying at the Judiciary Subcommittee hearing 
on November 18, 1993 included Ms. Doris Freedman, the Acting 
Chief Counsel for Advocacy, representatives from the Regulatory 
Flexibility Act Coalition and some of its member groups, 
academics and other interested parties.\20\
    \19\ In his testimony, Rep. Skelton specifically mentioned a 
Congressional oversight initiative by the Committee on Small Business 
which led to a report by the Committee which contains the most 
extensive analysis thus far concerning implementation of the Regulatory 
Flexibility Act. Rep. Skelton led that effort as Chairman of the Small 
Business Subcommittee on Exports, Tourism, and Special Problems. See 
Report of the Committee on Small Business: ``Implementation of the 
Regulatory Flexibility Act--A Five-Year Report,'' 100th Cong., 1st 
Sess. (1987). H. Rep. 100-273.
    \20\ See Hearing Report on H.R. 830, Regulatory Flexibility 
Amendments Act of 1993, before Subcommittee on Administrative Law and 
Governmental Relations, November 18, 1993. Serial No. 69.
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    No further action was taken on H.R. 830 by the Committee on 
the Judiciary during the 103d Congress. However, there was 
substantial other activity involving the issue of strengthening 
the Regulatory Flexibility Act during the last Congress.
    On March 17, 1994, during consideration of S. 4 (the Senate 
version of the National Competitiveness Act), Senator Malcolm 
Wallop (R-WY) introduced an amendment which, among other 
things, provided for judicial review of the RFA. After a motion 
to table the Wallop amendment was defeated by a vote of 67 to 
31, the amendment passed by voice vote. Shortly after 
provisions amending the Regulatory Flexibility Act were 
included in the Senate version of the National Competitiveness 
Act, efforts began in the House to develop a motion to instruct 
the House conferees that would embrace judicial review for the 
RFA.\21\
    \21\ In addition to these efforts to fashion a motion to instruct 
for use when House conferees were chosen, efforts continued to attempt 
to move Rep. Ewing's legislation, H.R. 830. Rep. Ewing filed a 
discharge petition in May of 1994, which was ultimately signed by 100 
Members.
    Only July, 19, 1994, the House conferees on the National 
Competitiveness Act were named. At that time, a motion to 
instruct the conferees to accept the Senate's approach and 
provide judicial review for the RFA was offered by Rep. Robert 
Walker (R-PA). After debate on the House floor, the motion to 
instruct offered by Rep. Walker passed by a recorded vote of 
380 to 36. The National Competitiveness Act died in conference.

                            Committee Action

    On January 4, 1995, H.R. 9 was introduced as one of the 
bills which makes up the ``Contract with America.'' The bill, 
entitled the ``Job Creation and Wage Enhancement Act of 1995,'' 
contained several provisions aimed at improving the regulatory 
system. Divided into twelve titles, the bill was referred for 
consideration to several Committees of the House. The Committee 
on Small Business received a re-referral of Title VI, along 
with other provisions, on February 9, 1995. Title VI, relating 
to strengthening the Regulatory Flexibility Act, was the 
subject of hearings by the Committee on Small Business on 
January 23 and February 10, 1995.\22\
    \22\ Title VI was among several titles of H.R. 9 referred to the 
Committee on the Judiciary on January 4, 1995 and was the subject of a 
hearing held before the Judiciary Subcommittee on Commercial and 
Administrative Law on February 3, 1995.
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    The hearing held by the Committee on Small Business on 
January 23, 1995 involved the testimony of the following 
witnesses: the Honorable Jere Glover, Chief Counsel for 
Advocacy of the U.S. Small Business Administration; Mr. Jack 
Faris, President and CEO, National Federation of Independent 
Business; Mr. Charles N. ``Rusty'' Griffiths, Jr. of 
Binghampton Slag Roofing Co. Inc., a member of the National 
Roofing Contractors Association; Mr. James P. Carty. V.P.--
Small Manufacturers, National Association of Manufacturers; Mr. 
Robert Pool, Homestyle Publishing, appearing on behalf of the 
National Association for the Self-Employed; and Mr. Lee 
Taddonio, V.P.--TEC/Pennsylvania Small Business United, 
appearing on behalf of National Small Business United.
    The hearing held by the Committee on February 10, 1995 
involved the testimony of the Honorable Jere Glover, Chief 
Counsel for Advocacy of the U.S. Small Business 
Administration;\23\ Mr. John T. Spotila, General Counsel of the 
U.S. Small Business Administration, appearing on behalf of the 
Clinton Administration; Mr. Frank S. Swain, the SBA Chief 
Counsel for Advocacy during the Reagan Administration; and 
several government representatives who appeared on behalf of 
several federal regulatory agencies.
    \23\ In connection with the hearing held on February 10, 1995, 
Committee staff reviewed the Annual Reports of the Chief Counsel for 
Advocacy on implementation of the Regulatory Flexibility Act for the 
years 1981 through 1993. See 5 U.S.C. Sec. 612(a).
---------------------------------------------------------------------------
    Subsequent to hearings by the Committee, and re-referral of 
Title VI of H.R. 9, H.R. 937 was introduced on February 14, 
1995 by Mrs. Meyers and was referred to the Committee on the 
Judiciary and the Committee on Small Business. The bill 
contains the substance of Title VI of H.R. 9 as revised and 
improved, taking into consideration comments offered by 
witnesses at the hearings and suggestions proposed by other 
Members.
    On February 15, 1995, the Committee on Small Business, with 
a quorum present, reported H.R. 937 by voice vote, after having 
adopted one amendment, also by voice vote.
                      Section-by-Section Analysis

                       section 1--judicial review

    Currently, 5 U.S.C. Sec. 611 generally prohibits judicial 
review of agency compliance with the Regulatory Flexibility Act 
(RFA). Judicial review is provided only in those limited 
instances when a petition for judicial review is instituted on 
other grounds, and only to the extent that the regulatory 
flexibility analysis has been made part of the record of agency 
action to be considered by the reviewing court. An agency's 
certification that a regulatory flexibility analysis is not 
required is not reviewable by a court, nor is the adequacy of a 
regulatory flexibility analysis unless it is considered as a 
part of a larger challenge.
    Section 1 of H.R. 937 creates a new 5 U.S.C. Sec. 611, 
which in subsection (a)(1) grants judicial review of compliance 
with the RFA to affected small entities, but requires that they 
must petition for review within 180 days after the effective 
date of the final rule they seek to challenge. The challenge 
must be brought to the court having jurisdiction, or which 
would have jurisdiction, to review such rule for compliance 
with the provisions of the Administrative Procedure Act or any 
other provision of law.
    Subsection (a)(2)(A) provides that where another provision 
of law requires that an action challenging a final agency 
regulation be commenced before 180 days, a regulatory 
flexibility challenge must be brought within that shorter time 
period. Subsection (a)(2)(B) covers those situations where an 
agency has delayed the issuance of a final regulatory 
flexibility analysis because it was operating under an 
emergency situation. In those cases, an affected small entity 
has 180 days from the date the analysis is made available to 
the public or within a shorter period if another provision of 
law requires a challenge be brought in a shorter time.
    Subsection (a)(3) defines ``affected small entity'' as one 
that is or will be adversely affected by the final rule.
    Subsection (a)(4) states that nothing in subsection (a) of 
Section 611 shall be construed to affect a court's authority to 
stay the effective date of any rule because of any other 
provision of law.
    Subsection (a)(5)(A) gives a court reviewing a challenge 
under the RFA the authority to order an agency to prepare a 
regulatory flexibility analysis if the agency has improperly 
certified that a proposed rule would not have a significant 
economic impact on a substantial number of small entities. The 
standard that the court is to follow is that, on the basis of 
the rulemaking record, the certification was ``arbitrary, 
capricious, an abuse of discretion, or otherwise not in 
accordance with law.'' This standard is identical to the 
standard of review for the Administrative Procedure Act.
    If the agency has prepared a final regulatory flexibility 
analysis, subsection (a)(5)(B) authorizes the court to order 
the agency to take corrective action consistent with Section 
604 of Title 5 (the section describing what should be in a 
final regulatory flexibility analysis).
    Subsection (a)(6) gives agencies a 90 day grace period in 
which to take corrective action as a result of an order of the 
court pursuant to subsection (a)(5). If after that period the 
agency has not complied, the court may stay the rule or grant 
such other relief as it deems appropriate.
    Subsection (a)(7) requires the court to take due account of 
the rule of prejudicial error.
    Subsection (b) of the new Section 611 provides that in an 
action for judicial review of a rule, any regulatory 
flexibility analysis for such rule shall be considered part of 
the whole record of agency action in connection with such 
review.
    Subsection (c) of the new Section 611 states that nothing 
contained in Section 611 of Title 5 bars judicial review of any 
other impact statement or analysis required or permitted by any 
other law.
    The effective date of the amended judicial review 
provisions contained in the new Section 611 applies to final 
agency rules issued after the date of enactment of H.R. 937.
    section 2--rules commented on by sba chief counsel for advocacy

    It is the intention of this legislation to strengthen 
agency compliance with the RFA. It is also the intention to 
require agencies to work more closely with the SBA Chief 
Counsel for Advocacy, who is charged with monitoring RFA 
compliance, during the drafting of new rules.
    Section 2 of H.R. 937 would amend Section 612 of the RFA to 
require that when an agency is drafting a new rule, the agency 
must provide the SBA Chief Counsel for Advocacy with an advance 
copy of the rule 30 days before publishing a general notice of 
proposed rulemaking in the Federal Register. (General Notices 
of Proposed Rulemaking are required under the APA, 5 U.S.C. 
Sec. 553(b).) At that time, the agency must also provide the 
SBA Chief Counsel for Advocacy with a draft of the initial 
regulatory flexibility analysis for the rule or if the agency 
determines that a regulatory flexibility analysis will not be 
necessary the agency must provide an explanation for that 
determination.
    Following receipt of the above information, the SBA Chief 
Counsel for Advocacy may review the proposed rule and 
regulatory flexibility analysis or other explanation. The SBA 
Chief Counsel for Advocacy will have 15 days to transmit, in 
writing, to the agency, any opposition or comments on the 
proposed rule or regulatory flexibility analysis or agency 
determination that an analysis is not necessary.
    If the SBA Chief Counsel for Advocacy submits such a 
statement, the agency shall publish that statement, together 
with the response to the agency, if the Federal Register at the 
same time the general notice of the proposed rulemaking for the 
rule is published. The failure of the SBA Chief Counsel for 
Advocacy to submit any statement to an agency during this 
advance notification procedure should not be construed as an 
approval by the Chief Counsel of the agency's initial 
regulatory flexibility analysis or certification.
    New Section 612(d)(4) of Title 5, which was added by the 
amendment adopted in the Committee by voice vote, contains a 
narrowly drawn exception for any proposed rules issued in 
connection with implementation of monetary policy or actions 
taken to ensure the safety and soundness of federally insured 
depository institutions, affiliates of such institutions, 
credit unions, or government sponsored housing enterprises (as 
the term ``enterprise'' is defined in Sec. 1303(6) of the 
Housing and Community Development Act of 1992 or to protect the 
deposit insurance funds. Safety and soundness regulations are 
designed to ensure proper supervision of banking operations and 
promote prudential standards designed to guard against undue 
risk or loss to banking instutitions and, potentially, the 
deposit insurance funds. The SBA Chief Counsel for Advocacy's 
review could add considerable time to the rulemaking process, 
thereby delaying the promulgation of regulations necessary to 
ensure that safety and soundness of the nation's financial 
institutions or actions taken in connection with monetary 
policy. A delay in promulgating these type of regulations, 
which in some instances may require expeditious treatment, 
could put the taxpayer-backed deposit insurance funds at risk.

   section 3--sense of congress regarding the sba chief counsel for 
                                advocacy

    Section 3 of this bill is a ``sense of Congress'' provision 
reaffirming what is presently contained in 5 U.S.C. 
Sec. 612(b).
    The Regulatory Flexibility Act currently gives the SBA 
Chief Counsel for Advocacy authority to file amicus briefs in 
litigation involving federal rules. In the history of the RFA 
this has only been done once, in the 1986 case of Lehigh Valley 
Farmers. At that time, the Justice Department indicated that 
this amicus authority was unconstitutional because it would 
impair the ability of the Executive branch to fulfill its 
constitutional functions.
    After a great deal of wrangling between the Department of 
Justice and the Chief Counsel, the Chief Counsel eventually 
withdrew the amicus brief filed in the Lehigh Valley Farmers 
case.
    The ability to appear as amicus curiae is important to the 
ability of the SBA Chief Counsel for Advocacy to represent the 
interests of Small businesses in the rulemaking process. 
Furthermore, if H.R. 937 becomes law, with its provision to 
permit judicial review of agency compliance with the Regulatory 
Flexibility Act, the importance of the SBA Chief Counsel's 
ability to file amicus briefs will be magnified.
                               Discussion

    At the two hearings held by the Committee on the regulatory 
flexibility provisions contained in Title VI of H.R. 9, several 
witnesses and many Members of the Committee, including the 
Chair, the Ranking Member, and Reps. Wyden and Sisisky, raised 
concerns over a provision contained in Title IV of H.R. 9.
    Title IV of H.R. 9 was designed to provide for federal 
regulatory budget cost control through amendments to the 
Congressional Budget Act of 1974. However, the last provision 
in this Title, Section 4003, goes substantially beyond this 
goal. Section 4003 of H.R. 9 would make substantive changes to 
the Regulatory Flexibility Act which would expand the 
protections of the Act to big business.
    Section 4003 of H.R. 9 adds requirements calling for 
monetary cost assessments to be provided as an additional 
product of the analyses required by Sections 603 and 604 of 
Title 5 of the U.S. Code (the RFA). However, instead of 
limiting the assessment of costs of compliance with a proposed 
or final rule to the costs to small entities, Section 4003 of 
H.R. 9 goes further and requires the cost assessment to set 
forth the monetary costs to ``small entities, other businesses, 
and individuals.'' Since the term ``small entities'' contained 
in the RFA is defined to include small businesses, the new term 
``other businesses'' set forth in Section 4003 must include big 
businesses.
    Since this ``cost assessment'' provision contained in 
Section 4003 of H.R. 9 is designed to amend the two 
substantive, analytical sections of the RFA, it was perceived 
by Members of the Committee that the intent of Section 4003 was 
to expand the reach of the RFA to big business.
    At both of the Committee's hearings on the regulatory 
flexibility provisions of H.R. 9, the Committee heard universal 
disapproval concerning expanding the reach of the Regulatory 
Flexibility Act to big businesses. This included testimony by 
the Honorable Jere Glover, the Chief Counsel for Advocacy of 
the U.S. Small Business Administration, who is charged by 
statute with overseeing implementation of the RFA, and 
testimony by Mr. John T. Spotila, General Counsel of the U.S. 
Small Business Administration, who appeared before the 
Committee to provide the Clinton Administration's position on 
the regulatory flexibility provisions contained in H.R. 9.
    At the Committee mark-up on February 15, 1995, Chair Meyers 
represented to the Members of the Committee that it was her 
understanding from the House Leadership that Section 4003 of 
H.R. 9 would not be reported out by any committee of the House.
    It is the position of the Committee on Small Business that 
the benefits of the Regulatory Flexibility Act should be 
preserved solely for small entities as that term is currently 
defined in the Act and that the RFA should not be extended to 
big business.
    Another issue which was raised during the Committee's 
consideration of H.R. 937 (and Title VI of H.R. 9) concerns 
what standards should be applied by courts in their review of 
agency compliance with the Regulatory Flexibility Act. The 
simple answer is that reviewing courts should draw upon 
precedents and decisions interpreting the Administrative 
Procedure Act and, specifically, its judicial review 
provisions. See 5 U.S.C. Sec. 701 et seq.\24\ For example, if 
H.R. 937 becomes law, the new Section 611 (a)(7) of Title 5 of 
the U.S. Code will refer to the ``rule of prejudicial error.'' 
The ``rule of prejudicial error'' is also referred to in 5 
U.S.C. Sec. 706 (the APA) and its definition and application 
can be found throughout the case law analyzing principles of 
administrative law both before and after adoption of the 
Administrative Procedure Act in 1946.\25\
    \24\ While reviewing courts should give the deference to agency 
judgments required by APA precedents, the Committee believes that real 
and effective review within these limits is necessary to accomplish the 
purposes of the Regulatory Flexibility Act.
    \25\ See, Generally, Riverbend Farms, Inc. v. Madigan, 958 F.2d 
1479 (9th Cir. 1992); Shelton v. Marsh, 902 F.2d 1201 (6th Cir. 1990); 
and Small Refiner Lead Phase-Down Task Force v. EPA, 705 F.2d 506 (D.C. 
Cir. 1986).
               Congressional Budget Office Cost Estimate

    In compliance with clause 2(l)(3)(C) of rule XI of the 
House of Representatives, the Committee sets forth, with 
respect to H.R. 937, the following statement received from the 
Director of the Congressional Budget Office under Section 403 
of the Congressional Budget Act of 1974:

                                     U.S. Congress,
                               Congressional Budget Office,
                                 Washington, DC, February 23, 1995.
Hon. Jan Meyers,
Chair, Committee on Small Business,
House of Representatives, Washington, DC.
    Dear Madam Chair: The Congressional Budget Office has 
reviewed H.R. 937, a bill to amend title 5, United States Code, 
to clarify procedures for judicial review of Federal agency 
compliance with regulatory flexibility analysis requirements, 
and for other purposes, as ordered reported by the House 
Committee on Small Business on February 15, 1995. CBO estimates 
that implementing the provisions of H.R. 937 would cost the 
Federal Government approximately $1 million over the next five 
years, assuming appropriation of the necessary funds. Because 
enactment of H.R. 937 could affect direct spending, pay-as-you-
go procedures would apply to the bill. Enacting H.R. 937 would 
not affect the budgets of State or local governments.
    H.R. 937 would permit small entities to petition for 
judicial review of a Federal agency's compliance with the 
requirements of the Regulatory Flexibility Act. The bill also 
would require that a Federal agency transmit to the Small 
Business Administration (SBA) a copy of any proposed rule (and 
the agency's initial regulatory flexibility analysis, if 
required) at least 30 days prior to the publication of the 
notice of proposed rulemaking. The SBA would be permitted to 
transmit to the proposing agency the SBA's analysis of the 
proposed rule's effects on small businesses.
    Federal agencies required to file regulatory flexibility 
analyses would incur some additional costs in transmitting the 
required documents to the SBA, but CBO does not expect these 
costs to be significant. Based on information from the SBA, CBO 
estimates that reviewing proposed rules and preparing analyses 
of their effects on small businesses would cost the Federal 
Government approximately $200,000 per year over the next five 
years, assuming appropriation of the necessary amounts.
    Enactment of H.R. 937 could result in additional lawsuits 
against the Federal Government requesting judicial review of 
Federal agency compliance with the requirements of the 
Regulatory Flexibility Act. To the extent that the additional 
lawsuits were successful and the plaintiffs were awarded 
attorney's fees, enactment of H.R. 937 could result in 
additional direct spending because these fees are paid from the 
Claims, Judgments and Relief Acts account. CBO cannot estimate 
either the likelihood or the magnitude of the direct spending, 
because there is no basis for predicting either the outcome of 
possible litigation or the amount of potential compensation.
    If you wish further details on this estimate, we will be 
pleased to provide them. The CBO staff contact is John Webb.
            Sincerely,
                                              James L. Blum
                              (For Robert D. Reischauer, Director).

                     Inflationary Impact Statement

    Pursuant to clause 2(l)(4) of rule XI of the House of 
Representatives, the Committee estimates that H.R. 937 will 
have no inflationary impact on prices and costs in the 
operation of the national economy.

                           Oversight Findings

    In accordance with clause 2(l)(3)(D) of rule XI of the 
House of Representatives, the Committee states that no 
oversight findings or recommendations have been made by the 
Committee on Government Reform and Oversight with respect to 
the subject matter contained in H.R. 937.
    In accordance with clause 2(l)(3)(A) of rule XI and clause 
2(b)(1) of rule X of the House of Representatives, the 
oversight findings and recommendations of the Committee on 
Small Business with respect to the subject matter contained in 
H.R. 937 are incorporated into the descriptive portions of this 
report.
         Changes in Existing Law Made by the Bill, as Reported

  In compliance with clause 3 of rule XIII of the Rules of the 
House of Representatives, changes in existing law made by the 
bill, as reported, are shown as follows (existing law proposed 
to be omitted is enclosed in black brackets, new matter is 
printed in italic, existing law in which no change is proposed 
is shown in roman):

                      TITLE 5, UNITED STATES CODE

          * * * * * * *

                     PART I--THE AGENCIES GENERALLY

          * * * * * * *

            CHAPTER 6--THE ANALYSIS OF REGULATORY FUNCTIONS

          * * * * * * *

Sec. 603. Initial regulatory flexibility analysis

  (a) Whenever an agency is required by section 553 of this 
title, or any other law, to publish general notice of proposed 
rulemaking for any proposed rule, the agency shall prepare and 
make available for public comment an initial regulatory 
flexibility analysis. Such analysis shall describe the impact 
of the proposed rule on small entities. The initial regulatory 
flexibility analysis or a summary shall be published in the 
Federal Register at the time of the publication of general 
notice of proposed rulemaking for the rule. The agency shall 
transmit a copy of the initial regulatory flexibility analysis 
to the Chief Counsel for Advocacy of the Small Business 
Administration in accordance with section 612(d).
          * * * * * * *

[Sec. 611. Judicial review

  [(a) Except as otherwise provided in subsection (b), any 
determination by an agency concerning the applicability of any 
of the provisions of this chapter to any action of the agency 
shall not be subject to judicial review.
  [(b) Any regulatory flexibility analysis prepared under 
sections 603 and 604 of this title and the compliance or 
noncompliance of the agency with the provisions of this chapter 
shall not be subject to judicial review. When an action for 
judicial review of a rule is instituted, any regulatory 
flexibility analysis for such rule shall constitute part of the 
whole record of agency action in connection with the review.
  [(c) Nothing in this section bars judicial review of any 
other impact statement or similar analysis required by any 
other law if judicial review of such statement or analysis is 
otherwise provided by law.]
Sec. 611. Judicial review

  (a)(1) Except as provided in paragraph (2), not later than 
180 days after the effective date of a final rule with respect 
to which an agency--
          (A) certified, pursuant to section 605(b) of this 
        title, that such rule would not have a significant 
        economic impact on a substantial number of small 
        entities; or
          (B) prepared a final regulatory flexibility analysis 
        pursuant to section 604 of this title,
an affected small entity may petition for the judicial review 
of such certification or analysis in accordance with the terms 
of this subsection. A court having jurisdiction to review such 
rule for compliance with the provisions of section 553 or under 
any other provision of law shall have jurisdiction to review 
such certification or analysis.
  (2)(A) Except as provided in subparagraph (B), in the case 
where a provision of law requires that an action challenging a 
final agency regulation be commenced before the expiration of 
the 180 day period provided in paragraph (1), such lesser 
period shall apply to a petition for the judicial review under 
this subsection.
  (B) In the case where an agency delays the issuance of a 
final regulatory flexibility analysis pursuant to section 
608(b) of this title, a petition for judicial review under this 
subsection shall be filed not later than--
          (i) 180 days; or
          (ii) in the case where a provision of law requires 
        that an action challenging a final agency regulation be 
        commenced before the expiration of the 180 day period 
        provided in paragraph (1), the number of days specified 
        in such provision of law,
after the date the analysis is made available to the public.
  (3) For purposes of this subsection, the term ``affected 
small entity'' means a small entity that is or will be 
adversely affected by the final rule.
  (4) Nothing in this subsection shall be construed to affect 
the authority of any court to stay the effective date of any 
rule or provision thereof under any other provision of law.
  (5)(A) In the case where the agency certified that such rule 
would not have a significant economic impact on a substantial 
number of small entities, the court may order the agency to 
prepare a final regulatory flexibility analysis pursuant to 
section 604 if the court determines, on the basis of the 
rulemaking record, that the certification was arbitrary, 
capricious, an abuse of discretion, or otherwise not in 
accordance with law.
  (B) In the case where the agency prepared a final regulatory 
flexibility analysis, the court may order the agency to take 
corrective action consistent with the requirements of section 
604 if the court determines, on the basis of the rulemaking 
record, that the final regulatory flexibility analysis was 
prepared by the agency without observance of procedure required 
by section 604 of this title.
  (6) If, by the end of the 90-day period beginning on the date 
of the order of the court pursuant to paragraph (5) (or such 
longer period as the court may provide), the agency fails, as 
appropriate--
          (A) to prepare the analysis required by section 604 
        of this title; or
          (B) to take corrective action consistent with the 
        requirements of section 604 of this title,
the court may stay the rule or grant such other relief as it 
deems appropriate.
  (7) In making any determination or granting any relief 
authorized by this subsection, the court shall take due account 
of the rule of prejudicial error.
  (b) In an action for the judicial review of a rule, any 
regulatory flexibility analysis for such rule (including an 
analysis prepared or corrected pursuant to subsection (a)(5)) 
shall constitute part of the whole record of agency action in 
connection with such review.
  (c) Nothing in this section bars judicial review of any other 
impact statement or similar analysis required by any other law 
if judicial review of such statement or analysis is otherwise 
provided by law.
Sec. 612. Reports and intervention rights

  (a) * * *
          * * * * * * *
  (d) Action by SBA Chief Counsel for Advocacy.--
          (1) Transmittal of proposed rules and initial 
        regulatory flexibility analysis to sba chief counsel 
        for advocacy.--On or before the 30th day preceding the 
        date of publication by an agency of general notice of 
        proposed rulemaking for a rule, the agency shall 
        transmit to the Chief Counsel for Advocacy of the Small 
        Business Administration--
                  (A) a copy of the proposed rule; and
                  (B)(i) a copy of the initial regulatory 
                flexibility analysis for the rule if required 
                under section 603; or
                  (ii) a determination by the agency that an 
                initial regulatory flexibility analysis is not 
                required for the proposed rule under section 
                603 and an explanation for the determination.
          (2) Statement of effect.--On or before the 15th day 
        following receipt of a proposed rule and initial 
        regulatory flexibility analysis from an agency under 
        paragraph (1), the Chief Counsel for Advocacy may 
        transmit to the agency a written statement of the 
        effect of the proposed rule on small entities.
          (3) Response.--If the Chief Counsel for Advocacy 
        transmits to an agency a statement of effect of a 
        proposed rule in accordance with paragraph (2), the 
        agency shall publish the statement, together with the 
        response of the agency to the statement, in the Federal 
        Register at the time of publication of general notice 
        of proposed rulemaking for the rule.
          (4) Special rule.--Any proposed rules issued by an 
        appropriate Federal banking agency (as that term is 
        defined in section 3(q) of the Federal Deposit 
        Insurance Act (12 U.S.C. 1813(q)), the National Credit 
        Union Administration, or the Office of Federal Housing 
        Enterprise Oversight, in connection with the 
        implementation of monetary policy or to ensure the 
        safety and soundness of federally insured depository 
        institutions, any affiliate of such an institution, 
        credit unions, or government sponsored housing 
        enterprises or to protect the Federal deposit insurance 
        funds shall not be subject to the requirements of this 
        subsection.
          * * * * * * *
                               APPENDIX A

                              ----------                              


   [Letter from Representative Tom Ewing to President Clinton, dated 
                           February 4, 1993]

                     Congress of the United States,
                                  House of Representatives,
                                  Washington, DC, February 4, 1993.
The President,
The White House,
Washington, DC.
    Dear Mr. President: I was excited to learn of your 
commitment during a September 30 speech at Clinton, Maryland to 
``enforce the Regulatory Flexibility Act's requirements'' as a 
way to help small businesses cope with federal regulation. I 
would like to work with you on this issue.
    As you know the Regulatory Flexibility Act (RFA) was 
designed to minimize the impact of federal regulations on small 
businesses. The RFA requires agencies to prepare analyses of 
the potential effect, including compliance costs of proposed 
rules on small businesses and develop final rules which 
minimize that impact. However, agencies in many cases have not 
complied with the spirit or letter of the RFA, in part because 
of some flaws in the original legislation. The most glaring 
problem is that there is no method to force agencies to heed 
the RFA as the Act contains a provision prohibiting judicial 
review of agency compliance.
    Over the past year I have developed legislation to improve 
the RFA, which is being introduced today. This bill has 
received strong bi-partisan support so far in Congress, 
including the Chairman and Ranking Member of the House Small 
Business Committee. It has also received strong support from 
the small business community.
    I would be honored to work with you in a bi-partisan spirit 
to pass this legislation which is critically important to small 
businesses if we are to ease the burden of excessive and costly 
federal regulations. Enclosed is detailed information about the 
Regulatory Flexibility Amendments Act of 1993.
    Thank you for your consideration.
            Sincerely,
                                           Thomas W. Ewing,
                                                Member of Congress.
                               APPENDIX B

                              ----------                              


[Letter from President Clinton to Representative Tom Ewing, dated April 
                               22, 1993]

                                           The White House,
                                    Washington, DC, April 22, 1993.
Hon. Thomas W. Ewing,
House of Representatives,
Washington, DC
    Dear Representative Ewing: Thank you for your letter 
informing me that you had introduced H.R. 830, the ``Regulatory 
Flexibility Amendments Act of 1993.''
    The Regulatory Flexibility Act (RFA) has played an 
important role in many rulemakings by ensuring that the effects 
on small businesses and small governmental entities are 
considered during the rulemaking process. However, experience 
with the RFA suggests that improvements may be needed in its 
implementation, particularly in agency compliance with the 
requirements to perform adequate regulatory flexibility 
analysis.
    My Administration looks forward to working with you and the 
Congress on this important issue. I appreciate your interest in 
small business, and want you to know that the concerns of small 
business are a very high priority in my Administration.
    With best wishes,
            Sincerely,
                                                      Bill Clinton.
                               APPENDIX C

                              ----------                              


  [Excerpt from the Report of the National Performance Review, dated 
                            September, 1993]

     SBA01: Allow Judicial Review of the Regulatory Flexibility Act

                               background

    Small businesses often feel overwhelmed by well-intentioned 
regulations that burden them with needless costs. Congress and 
the President recognized this problem in 1980 and enacted the 
Regulatory Flexibility Act (RFA). The RFA requires agencies to 
seek alternative regulatory solutions when their rules have a 
disproportionately severe impact on small entities, including 
small businesses and nonprofit organizations and relatively 
small government jurisdictions. However, most agencies have 
failed to perform the required RFA analysis. Rules continue to 
be issued even though the harm that resulted could have been 
alleviated had they been examined according to RFA 
guidelines.1
    For example, in 1986, Congress enacted the Emergency 
Planning and Community Right-To-Know Act, requiring local 
reporting of hazardous chemicals. The initial Environmental 
Protection Agency (EPA) implementation instructions required 
reporting ``any amount'' of hazardous chemicals. The potential 
impact on small business was staggering. Even hot-dog stands 
would have been required to report bottles of solvent or metal 
polish.
    The Small Business Administration's (SBA's) Office of 
Advocacy, which is directed by law to monitor compliance with 
the RFA, coordinated small business comments with EPA, which 
explored less burdensome alternatives. As a result of this 
process, EPA raised the threshold for reporting to 10,000 
pounds of hazardous chemicals. This threshold eliminated 
hundreds of thousands of unnecessary reports, yet still covered 
more than 95 percent of the total quantity of stored chemicals 
and 100 percent of those in quantities likely to produce the 
sort of hazard that was the concern of the legislation.
    The RFA, which works in conjunction with the fundamental 
agency rulemaking law, the Administrative Procedure Act (APA), 
leads rulemakers to one of two outcomes:
    (1) For rules that will have a significant economic impact 
upon a substantial number of small entities, the agency is 
required to perform a regulatory flexibility analysis. This 
analysis defines the burdens of the rule and examines 
alternatives that will lessen those burdens for small entities.
    (2) For rules that will not have a significant economic 
impact upon a substantial number of small entities, the agency 
must so certify, with a brief statement explaining the 
rationale behind this conclusion.
    While SBA's Office of Advocacy can ask agencies to follow 
the RFA, no mechanism for enforcing compliance exists. As a 
result, federal agency compliance is spotty at best. A few 
agencies, such as the EPA, the Food Safety Inspection Service, 
and the Nuclear Regulatory Commission, now consistently use the 
RFA to reduce the regulatory burden imposed on small entities. 
Most agencies employ simplistic analysis that barely meet even 
the minimal requirements of the RFA. Others, including the 
Internal Revenue Service, define their rulemaking activities in 
the Federal Register as ``interpretative, a category excluded 
from RFA responsibilities.''
    Several administrative efforts have been made to improve 
the level of responsiveness to the RFA, but with little 
success. The fundamental solution is judicial review, an 
approach favored by small business. Such review is permitted 
for agency rulemaking under the APA. However, the RFA itself 
prohibits judicial review of agency compliance with the RFA. 
Courts have further restricted the use of RFA analysis as 
evidence in suits brought under the APA.
    For the RFA to succeed at its goal of avoiding needless 
government regulatory burdens on small entities, sanctions for 
non-compliance with the RFA must be created.
    With judicial review, small entities could challenge an 
agency's failure to perform an RFA review or a flawed RFA 
review. They could sue in the appropriate federal court and, if 
they won, the court could order the agency to explain its RFA 
determination or develop appropriate alternatives under the 
RFA. A credible threat of lawsuits would give agencies a strong 
motive to ensure that the RFA is followed.
    Judicial review is supported by all major small business 
associations, including the American Small Business 
Association, the American Trucking Association, the National 
Association for the Self-Employed, the National Association of 
Manufacturers, the National Federation of Independent Business, 
National Small Business United, the National Society of Public 
Accountants, the Small Business Legislative Council, and the 
U.S. Chamber of Commerce.\2\
    To create better compliance with the RFA and avoid needless 
lawsuits, the availability of judicial review must be 
accompanied by systematic compliance guidelines for agencies 
concerning how to conduct RFA reviews. For more than a decade, 
most agencies have failed to develop such guidelines on their 
own.
                                actions

    1. The Regulatory Flexibility Act of 1980 should be amended 
to allow for judicial review of agency determinations under the 
RFA.\3\
    This approach would allow small entities that have been 
injured by an agency action to seek judicial relief. This would 
be possible only after an agency has published a final rule, 
not at any earlier point in the rulemaking process.
    2. An Executive Order should be issued requiring the SBA 
Office of Advocacy to issue governmentwide guidance on 
appropriate processes for complying with the analytical 
requirements of RFA.\4\
    This approach would provide consistent technical guidance--
the foundation for avoiding lawsuits.

                              implications

    The potential for judicial review would give agencies 
greater incentive to meet their present statutory obligations 
to consider the impact of their rules on small entities. Agency 
lawyers would ensure that the agency would properly comply with 
the RFA to avoid the valid threat of litigation.
    Judicial review is not expected to lead to a large number 
of lawsuits. No basis for suits would exist if agencies 
conducted an appropriate RFA review. As a practical matter, 
most regulations to which small entities have significant 
objections are already in litigation; judicial review of RFA 
would at most add another ground to these challenges. A few new 
cases based solely on RFA failure might result, in instances in 
which the impact of rules on small entities is sufficiently 
negative to impose greater costs than the cost of litigation--a 
fairly high threshold. In these rare cases, a challenge may be 
in the nation's best interests.
    In the most extreme cases, judicial review of RFA could 
lead to an initial flurry of lawsuits. Once the first few cases 
are decided, however, the boundaries between acceptable and 
unacceptable agency behavior under RFA would become well-known 
to agency attorneys and the administrative law bar. After that, 
legal challenges could be expected to fall off dramatically.
    Both the process for developing SBA guidance and the 
guidance itself would help achieve compliance with the RFA. The 
notice, comment, and public hearings phase would raise the 
level of awareness in federal agencies about the RFA. 
Furthermore, the Office of Advocacy expects that the guidance 
ultimately developed will provide agencies with a map 
sufficiently detailed to allow them to navigate their way 
through the RFA with minimal effort.
    The RFA does not impose a requirement for an agency to 
collect additional data except in rare instances in which data 
originally collected was insufficient to understand the problem 
the rule was trying to solve. In such cases, the additional 
task of information collection should not be attributed to the 
RFA but to an agency's failure to meet its obligations for 
reasoned decisionmaking.
                             fiscal impact

    Judicial review of the RFA imposes no costs outside the 
government. In rare cases where there is no court challenge of 
regulations on grounds other than the RFA and the cost of 
unnecessary or overly burdensome regulations is greater than 
the cost of litigation, small entities may choose to incur the 
cost of bringing suit based solely on an RFA violation. The 
cost to these entities cannot be estimated but would be seen by 
them as a net savings.
    Procedures to implement the RFA would be limited to federal 
agencies. The costs inside the federal government are difficult 
to estimate because the costs of rulemaking are not a line item 
and are generally not well-measured. The best estimates 
available suggest a maximum average of one work day per rule 
when there is no substantial impact on small entities, a total 
effort that should be absorbed in the current personnel 
ceiling. Over the years, SBA has found that only 30 to 50 rules 
a year have significant negative impact on small entities.
    If agencies do not comply with RFA, costs for litigation 
would certainly accrue. The marginal cost of RFA suits cannot 
be calculated in advance. Additional funds should not be 
budgeted for such costs.

                                endnotes

    \1\ See annual reports on the implementation of the 
Regulatory Flexibility Act, U.S. Small Business Administration, 
Office of Advocacy, 1981-1992.
    \2\ U.S. Congress, House Committee on Small Business, 
testimony of James Morrison, July 28, 1993. The organizations 
listed are the Regulatory Flexibility Act Coalition, which 
supports judicial review of RFA.
    \3\ Judicial review can be established with the following 
language: (a) Section 611 of title 5, United States Code is 
amended by striking subsections (a), (b), and (c) and inserting 
a new subsection (a): ``For purposes of section 702 of title 5, 
determinations made pursuant to this chapter shall only be 
reviewable upon publication or service of a rule as required by 
section 553(d) of title 5.''
    \4\ Implementing instructions for complying with the 
analytical requirements in sections 603, 604, and 605 of the 
RFA can be brought about by the following executive order: 
``The Small Business Administration Office of Advocacy shall: 
Issue guidance to federal agencies for the implementation of 
the Regulatory Flexibility Act. Such guidance shall be 
developed after consultation with affected agencies and after 
such public hearings as may be appropriate. The guidance will 
be designed to ensure that the analysis conducted under the Act 
provide data and reasonable alternatives.'' This approach was 
used successfully in 1977 to provide a framework for all 
federal agencies in meeting the requirement to examine 
environmental impacts of federal actions mandated by the 
National Environmental Policy Act of 1969 (NEPA). This approach 
was tested in the Supreme Court, and has been favorably 
commented on by that court several times. Such guidance would 
help agencies defend their actions in any legal challenges 
under the RFA.
                               APPENDIX D

                              ----------                              


   [Memorandum of the American Law Division (Congressional Research 
      Service) of the Library of Congress, dated October 22, 1993]

Subject: Constitutional Analysis of Sec. 612(b) of the Regulatory 
        Flexibility Act Authorizing the Chief Counsel for Advocacy of 
        the Small Business Administration to Appear as Amicus Curiae in 
        Any Court Action to Review an Agency Rule.
Author: John Contrubis.

    This memorandum has been prepared in order to analyze the 
constitutionality of Sec. 612(b) of the Regulatory Flexibility 
Act \1\ which authorizes the Chief Counsel for Advocacy (the 
Chief Counsel) of the Small Business Administration to appear 
as amicus curiae in any court action to review an agency rule. 
Specifically, this memorandum responds to past determinations 
by the Department of Justice (DOJ) indicating that Sec. 612(b) 
is limited to certain circumstances.\2\
    \1\ U.S.C.A. Sec. 601 et seq.
    \2\ DOJ has stated that ``the litigation authority granted to the 
Chief Counsel by Sec. 612(b) is limited to litigation challenging rules 
promulgated by independent agencies, and then, only if the Attorney 
General, or any other Executive Branch officer, has not already taken a 
position in the litigation on behalf of the United States, which is 
inconsistent with that which the Chief Counsel seeks to present. In 
litigation involving Executive Branch agencies, the Chief Counsel's 
authority to present his views to the court is limited to the 
presentation of views which would not conflict with those presented by 
the defendant agency.'' Memorandum from Theodore B. Olson, Assistant 
Attorney General, Office of Legal Counsel, to J. Paul McGrath, 
Assistant Attorney General, Civil Division, re: ``Amicus Curiae Role of 
the Small Business Administration's Chief Counsel for Advocacy under 
the Regulatory Flexibility Act'' (May 17, 1983).
---------------------------------------------------------------------------
    Traditionally, DOJ has based its opposition on two 
theories. The first theory states that the Chief Counsel's 
authority to appear as amicus curiae may, in certain 
circumstances, interfere with the President's constitutional 
obligation to ``take care that the laws be faithfully 
executed.* * *'' \3\ The second theory suggests that 
intrabranch litigation would create a nonjusticiable issue, 
thus, running afoul of the Constitution's requirement that a 
case or controversy exist before a matter be presented before a 
United States court.\4\ Neither of these theories are likely to 
be held to limit the Chief Counsel's authority to appear as 
amicus curiae in any court action to review an agency rule.
    \3\ U.S. CONST. art. II, Sec. 3.
    \4\ U.S. CONST. art. III.
---------------------------------------------------------------------------
    In advocating the ``take care'' clause of Article II, DOJ 
is relying on the assumption that the executive power is 
hierarchical in nature and uniquely vested in the President 
alone (the unitary executive theory \5\). However, a pure 
unitary executive theory has arguably been undermined by the 
Supreme Court's rulings in Morrison v. Olson \6\ and Mistretta 
v. United States.\7\
    \5\ See Rosenberg, ``Congress's Prerogative Over Agencies and 
Agency Decisionmakers: The Rise and Demise of the Reagan 
Administration's Theory of the Unitary Executive,'' 57 Geo. Wash. L. 
Rev. 627 (1989).
    \6\ Morrison v. Olson, 487 U.S. 654 (1988).
    \7\Mistretta v. United States, 488 U.S. 361 (1989).
---------------------------------------------------------------------------
    In Morrison, the appellees argued that since an independent 
counsel is removable by the executive, through the Attorney 
General, only for ``good cause,'' such statutory limitation on 
the President's at-will removal authority of an officer who is 
exercising purely executive functions unduly interferes with 
the President's constitutional duties and prerogatives and 
thereby violates separation of powers principles. The Court 
held that the validity of insulating an inferior officer from 
at-will removal by the President can no longer turn on whether 
such an officer is performing ``purely executive'' or ``quasi 
legislative'' or ``quasi judicial'' functions.\8\ Instead, the 
``good cause'' removal limitation will turn on whether such 
limitation interferes with the President's ability to perform 
his constitutional duty.\9\ Addressing the independent 
counsel's powers, the Court noted that the exercise of 
prosecutorial discretion is not ``central'' to the functioning 
of the executive branch.\10\ Moreover, since the independent 
counsel could be removed by the Attorney General, this is 
sufficient to ensure that he is performing his statutory 
duties, which is all that is required by the ``take care'' 
clause.\11\ Furthermore, the limited ability of the President 
to remove the independent counsel, through the Attorney 
General, was also seen as leaving enough control in his hands 
to reject the argument that the scheme of the Ethics in 
Government Act impermissibly undermines executive powers or 
disrupts the proper constitutional balance by preventing the 
executive from performing his functions.\12\
    \8\ Morrison, supra at 687.
    \9\ Id. at 687-91.
    \10\ Id. at 691-92.
    \11\ Id. at 692-93.
    \12\ Id. at 695-96.
    The Court's support for broad congressional authority over 
agency structure was furthered in Mistretta. Here, the Court 
was presented with a broad ranging separation of powers 
challenge to the United States Sentencing Commission. 
Petitioners argued that the Commission, an independent agency 
in the judicial branch vested with power to promulgate binding 
sentencing guidelines, violated the separation doctrine by its 
placement in the judicial branch, by requiring federal judges 
to serve on the Commission and to share their authority with 
nonjudges, and by empowering the President to appoint 
Commission members but limiting his power to remove them only 
for cause. The Court, in describing this separation of powers 
dilemma, explained that the issue involved whether there exists 
``the accumulation of excessive authority in a single branch'' 
through encroachment and aggrandizement by one branch against 
another.\13\ In cases where statutory provisions commingled the 
functions of the Branches, but pose no danger of either 
aggrandizement or encroachment \14\ the Court has developed a 
balancing test. This test determines whether the challenged 
arrangement `` `prevents the Executive Branch from 
accomplishing its assigned functions,' '' \15\ and if so, `` 
`whether that impact is justified by an overriding need to 
promote objectives within the constitutional authority of 
Congress.' '' \16\ Applying this test, the Court found that 
although the Commission is located in the judicial branch, its 
rulemaking powers are separate from those of the judiciary. 
Moreover, the Commission is an independent agency accountable 
to Congress, which can revoke any or all of the guidelines at 
any time, its members are subject to the President's limited 
removal powers, and its rules are subject to the notice and 
comment requirements of the Administrative Procedure Act. Thus, 
the Court concluded, ``because Congress vested the power to 
promulgate sentencing guidelines in an independent agency, not 
a court, there can be no serious argument that Congress 
combined legislative and judicial power within the Judicial 
Branch.'' \17\
    \13\ 488 U.S. at 381.
    \14\ Id. at 382.
    \15\ Id. (quoting Nixon v. Administrator of Gen. Servs., 433 U.S. 
425, 443 (1979)).
    \16\ Id.
    \17\ Id. at 383.
---------------------------------------------------------------------------
    Similar to the situation in Morrison and Mistretta, the 
Small Business Administration Act also arguably leaves enough 
control in the President's hands so that it does not undermine 
the executive's powers or disrupt the proper constitutional 
balance by preventing the executive from performing his 
functions. Comparing the independent counsel in Morrison to the 
Chief Counsel of the SBA demonstrates that the President 
actually has more control over the latter.\18\ Moreover, since 
the exercise of prosecutorial discretion is not ``central'' to 
the functioning of the executive branch, the Chief Counsel's 
appearance as amicus curiae may not interfere with the 
executive's ``take care'' responsibilities. The fact that the 
Chief Counsel would appear simply as amicus curiae is further 
evidence that the executive's power is not likely to be waived 
as being usurped.\19\ Therefore, opposition to the Chief 
Counsel's statutorily authorized appearance as amicus curiae 
will likely fail.
    \18\ The Chief Counsel of the SBA, unlike an independent counsel, 
is appointed by the President, by and with the advice and consent of 
the Senate, and is subject to removal at will. 15 U.S.C.A. Sec. 634a.
    \19\ An amicus curiae is not a litigant to a suit, but an 
interested party who wishes to convey its views upon the court.
---------------------------------------------------------------------------
    Furthermore, the proposition that executive powers are 
solely vested in the President has been discounted well before 
this century. In Kendall v. United States ex rel. Stokes, the 
Court was quick to point out that Congress may impose upon an 
officer statutory duties that ``grow out of and are subject to 
the control of the law, and not to the direction of the 
president.'' \20\ The Court also rejected the proposition that 
``every officer in every branch of [the executive] department 
is under the exclusive direction of the president. * * *  Such 
a principle, we apprehend, is not, and certainly cannot be 
claimed by the president.'' \21\ In a more recent case, the 
Tenth Circuit stated that ``[i]t is a matter of fundamental law 
that the Constitution assigns to Congress the power to 
designate duties of particular officers. The President is not 
obligated under the Constitution to exercise absolute control 
over our government executives. The President is not required 
to execute laws; he is required to take care they be executed 
faithfully.'' \22\
    \20\ Kendall v. United States ex rel. Stokes, 37 U.S. (12 Pet.) 
524, 610 (1838).
    \21\ Id.
    \22\ SEC v. Blinder & Co., 855 F.2d 677 (10th Cir. 1988). cert. 
denied 109 S. Ct. 1172 (1989).
---------------------------------------------------------------------------
    Upon forming the SBA, Congress authorized the Chief Counsel 
to appear as amicus curiae in any court action to review an 
agency rule.\23\ In pursuance of his ``take care'' 
responsibilities, the President may not limit the Chief 
Counsel's authority to appear as amicus curiae. Instead, the 
President is required to take care that the Chief Counsel's 
right to appear as amicus curiae be faithfully executed.
    \23\ Supra at n.1.
---------------------------------------------------------------------------
    Another issue which need be briefly mentioned is the 
argument that the SBA's appearance as amicus curiae may create 
litigation between SBA and DOJ which would be held to be 
nonjusticiable because one executive agency suing another would 
not present the requisite constitutional ``case or 
controversy.'' \24\ This issue is moot in the present situation 
since the SBA would not be a party to the action, but instead 
would appear as a friend of the court (amicus curiae). Thus, 
where a party (X) challenges an agency rule, DOJ represents the 
United States and SBA appears as an amicus curiae, the 
litigation are X and DOJ, and SBA and DOJ. In other words, the 
only parties in litigation are X and DOJ. Even if SBA and DOJ 
were opposing parties, an article III challenge would likely be 
unsuccessful.\25\ There are innumerable instances in which 
Congress has specifically authorized litigation between 
executive agencies, none of which have been challenged on 
constitutional grounds.\26\
    \24\ Supra at n.4.
    \25\ See United States v. Nixon, 418 U.S. 683 (1974).
    \26\ See, e.g., Mail Order Association of America v. United States 
Postal Service, 986 F.2d 509 (D.C. Cir. 1993); and Rosenberg, supra n.5 
at pp. 662-688.
---------------------------------------------------------------------------
    In sum, it is not likely to be held that Congress may not 
vest in the Chief Counsel the authority to appear as an amicus 
curiae should a court action to review an agency rule arise.
                              John Contrubis, Legislative Attorney.
                               APPENDIX E

                              ----------                              --
--------


[Letter from the Honorable Leon E. Panetta, White House Chief of Staff, 
           to Senator Malcolm Wallop, dated October 7, 1994]

                                           The White House,
                                   Washington, DC, October 7, 1994.
Hon. Malcolm Wallop,
U.S. Senate,
Washington, DC.
    Dear Senator Wallop: Your particular question about the 
Administration's position on judicial review of actions taken 
under the Regulatory Flexibility Act has come to my attention.
    As you have discussed with Senator Bumpers, the 
Administration supports such judicial review of ``Reg Flex.''
    The Administration supports a strong judicial review 
provision that will permit small business to challenge agencies 
and receive meaningful redress when they choose to ignore the 
protections afforded by this important statute.
    In fact, the National Performance Review endorsed this 
policy to ensure that the Act's intent is achieved and the 
regulatory and paperwork burdens on small business, states, and 
other entities are reduced.
    Ironically, Phil Lader, our nominee for Administrator of 
the Small Business Administration (whose nomination was voted 
favorably today by a 22-0 vote of the Senate Small Business 
Committee) has been a principal champion of judicial review of 
``Reg Flex.'' In his capacity as Chairman of the Policy 
Committee on the National Performance Review, Phil vigorously 
advocated this position. I know that, if confirmed, as SBA 
Administrator, he would join us in continued efforts to win 
Congressional support for such judicial review.
            Sincerely,
                                           Leon E. Panetta,
                                                    Chief of Staff.
                               APPENDIX F

                              ----------                              


[Letter from the Honorable Philip Lader, Administrator-Designate, Small 
 Business Administration, to Senator Malcolm Wallop, dated October 8, 
                                 1994]

                                                   October 8, 1994.
Hon. Malcolm Wallop,
U.S. Senate,
Washington, DC.
    Dear Senator Wallop: The Administration supports strong 
judicial review of agency determinations under the Regulatory 
Flexibility Act that will permit small businesses to challenge 
agencies and receive strong remedies when agencies do not 
comply with the protections afforded by this important statute.
    In fact, the National Performance Review publicly endorsed 
this policy to ensure that the Act's intent is achieved and the 
regulatory and paperwork burdens on small businesses, states, 
and other entities are reduced.
    As Chairman of the Policy Committee of the National 
Performance Review, under Vice President Gore's leadership I 
vigorously advocated this position. I have continued to 
champion this policy within the Administration.
    If confirmed as Administrator of the U.S. Small Business 
Administration, I will join the Congress and the small business 
community in continued efforts to pass legislation for such 
judicial review.
    Thank you for your leadership on this important issue to 
small business.
            Sincerely,
                                      Philip Lader,
                                   Administrator-Designate,
                                     Small Business Administration.
                               APPENDIX G

                              ----------                              


[Letter from President Clinton to Senator Malcolm Wallop, dated October 
                                8, 1994]

                                            The White House
                                   Washington, DC, October 8, 1994.
Hon. Malcolm Wallop,
U.S. Senate,
Washington, DC.
    Dear Senator Wallop: My Administration strongly supports 
judicial review of agency determinations under the Regulatory 
Flexibility Act, and I appreciate your leadership over the past 
years in fighting for this reform on behalf of small business 
owners.
    Although legislation establishing such review was not 
enacted during the 103rd Congress, my Administration remains 
committed to securing this very important reform. Toward that 
end, my Administration will continue to work with the Congress 
and the small business community next year for enactment of a 
strong judicial review that will permit small businesses to 
challenge agencies and receive meaningful redress when agencies 
ignore the protections afforded by this statute.
    As you know, the National Performance Review endorsed this 
policy to ensure that the Act's intent is achieved and the 
regulatory and paperwork burdens on small business, states, and 
other entities are reduced.
    Again, thank you for your continued leadership in this 
area.
            Sincerely,
                                                      Bill Clinton.