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January 11, 2009

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The position of head of OIRA is not a "newly created position." OIRA has been around for decades. Also, OIRA has oversight over ALL reg matters, not just environmental, healthcare, and safety issues.

I agree completely. Sunstein taught my Elements and my Admin Law classes, and he was not only a keenly insightful (and prolific) scholar but also a fascinating communicator.

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