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The seed of OIRA was planted not under Carter but Ford. During his campaign to "Whip Inflation Now" he included a provision that a "major regulation" would involve an impact on the economy of $100 million or more and would require review. IIRC that might have been a reliance on the originating agency to certify they'd done the review, rather like Carter's requirement that regulations be in "plain English".

My pet peeve is the failure of later presidents to change the $100 million parameter. Adjusted for inflation today it should >$500 million, getting close to what Ev Dirksen would call "money".

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Excellent Interview! Dr. Graham should write a book about his time in OIRA.

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