Our History: Told By You - a 50th Anniversary Blog Post Series

On its 50th Anniversary, the best method of appreciating ACUS’ unique contributions in fostering the effective working of administrative agencies is by reviewing the operations of its Committees. 

I serve on the Committee on Administration and Management, many of whose projects involve policy issues within the jurisdiction of the Office of Management and Budget.  Since ACUS’s reauthorization, two OMB-related issues have provoked the most vigorous debate within the Committee: (1) under what circumstances in the digital age should agencies exercise their authority to incorporate private sector standards into their rules by reference, pursuant to the governing OMB Circular; and (2) the causes and potential measures to address the extraordinary delays recently experienced by OMB’s Office of Information and Regulatory Affairs in reviewing draft agency rules for consistency with the President’s policy priorities.  In all its projects, the Committee’s deliberations have been well informed by the insightful work of ACUS’ researchers who review difficult policy issues in great depth, and by the hard work by ACUS staff to distill the research reports and draft practical recommendations for the Members’ consideration. 

For me, the most remarkable feature of ACUS has been the extraordinary quality of the discussions in Committee meetings.  The ACUS Members and interested citizens who participate in these deliberations bring to the table many hundreds of years of collective experience with the issues under consideration and the operation of high-level agency dispute resolution processes.  The Members have volunteered their time to assist ACUS in developing recommendations for problems facing the agencies because of their common understanding, developed in many different fields of endeavor, of the importance of effective administration of law in promoting the public interest.  Although they understand from bitter experience how easily policy processes can be derailed, the Members have chosen not to obstruct, but to trust the intellectual integrity of their colleagues and to discuss their conflicting policy views on the merits, with confidence that better solutions may emerge from frank discussions.  The Members’ commitment to improving the functioning of government is matched only by their experience and intellectual firepower.  It has been a privilege to be associated with such a high performing group.  

--John F. Cooney