Who is Susan Dudley, and Why Does Mordor Love Her?

...Susan Dudley was nominated by the president in July to head OIRA, an office in the White House with broad power over federal regulatory policy, yet Dudley spent her time at the Mercatus Center opposing health, safety and environmental regulations. She has opposed lowering the threshold for arsenic in drinking water and closing loopholes in the Davis Bacon Act, which requires employers to pay locally prevailing wages and benefits on public works projects.

Dudley has utilized cost-benefit analysis as a weapon to undermine or kill regulations that industry opposes. She even claims that cost-benefit studies demonstrate that OSHA regulations - many of which are widely recognized as protecting the lives and safety of countless workers - have not had a "substantial impact."

Dudley applies the same logic to the public's right to know about toxic chemicals. According to her public interest comments, while it may be an "intuitively desirable social goal" to provide information to the public, it costs money and may even "confuse, rather than inform" the public. The costs must be outweighed by the social goal, explains Dudley, and even when this is the case it does not suggest that more information available to the public is in order.

Were Dudley to be confirmed as the next regulatory czar, she would likely review an EPA proposal that would undermine the Toxics Release Inventory, the premier right-to-know program about chemical information.

Dudley's championing of industry at times comes across as frighteningly naive. Arguing against regulation requiring air bags in vehicles, which have clearly been shown to save the lives of drivers and passages, she writes that, "if air bags save lives and consumers demand them," then the auto industry would have installed them without federal regulations.

In addition to her pro-industry work at the Mercatus Center, Dudley also once worked for OIRA, reviewing environmental regulations, and was widely criticized by environmental groups for her decisions there.

A little more on Susan Dudley here.

Also, Public Citizen has some things to say:

The announcement last night of the White House’s intention to nominate Susan Dudley as administrator of the Office of Information and Regulatory Affairs (OIRA) within the Office of Management and Budget represents another attack by the Bush administration on the government’s ability to hold industry accountable and keep Americans safe.

Although the OIRA is little known to the public, it has enormous power to weaken, delay and eliminate hard-won regulations designed to protect the public in the workplace, on our roads and in our homes. It reviews protections instituted by watchdog offices such as the National Highway Traffic Safety Administration (NHTSA), the Food and Drug Administration and the Environmental Protection Agency (EPA) - everything from auto safety standards to limits on industrial chemicals and air and water pollutants. Under this administration, OIRA has weakened these already troubled agencies. If Dudley is confirmed by the Senate, she will further strip them of their ability to stand up to government secrecy, politicization and corporate interests.

Throughout her career, Dudley has consistently fought against government safeguards and advocated a radical, hands-off approach to regulating corporations. As director of regulatory studies at the industry-funded Mercatus Center, Dudley has sought to strike down countless environmental, health and safety rules and found willing allies in the administration. She has opposed such things as EPA’s attempts to keep arsenic out of our drinking water and to lower levels of disease-causing smog. She has questioned NHTSA’s life-saving airbag regulations and the Department of Transportation’s hours-of-service rules to keep sleep-deprived truck drivers off our roads. She has championed energy deregulation, which has led to skyrocketing prices and little consumer relief during record-setting heat waves. The list goes on and on...

This is one evil woman. I think the tarantula is probably being compared unfairly.