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REGULATORY REFORM
Remarks by
Darryl R. Francis, President
Federal Reserve Bank of St. Louis
before a luncheon co-sponsored
by the
U.S. Department of Commerce
and U.S. Department of Labor
Bel Air Hilton
February 5, 1976

I welcome the opportunity to address this luncheon
gathering and wish to thank the sponsors of today's hearings for
granting me the opportunity to do so. While my comments today will
focus upon the impact of government regulations on our economy,
the ideas that I will express have a bearing on all government
actions, be they classified as economic, social, or political in design.
In my view the effects of government actions in any one of these
spheres are interdependent and virtually inseparable.
Let me begin by saying that I subscribe to the widely
held doctrine that minimal government regulation is consistent with
the attainment of the maximum possible standard of living for society.
According to this view, government regulation should be viewed with
skepticism as a potential enemy of society's material well-being. On
the other hand, freedom from regulation is viewed as a source of the
variety and diversification of ideas, experiments, and innovations
which lead to the discovery of new products, more efficient means of




-2production, and offers the most promising means by which the
standards of living of all members of society can be raised.
However, I do recognize that there is a constructive role
for government in the economy; I am not an advocate of anarchy. I
recognize that a system which promotes maximum material well-being
may not be a godsend and that its existence depends, in part, upon
affirmative government action. However, I also recognize that each
new government regulation involves a loss of some of the variety and
diversification of ideas, experiments, and innovations which
contribute to the realization of this maximum material well-being.
In my view, one of the most useful roles that government
can play in the economy, aside from its role as a protector of property
rights, is to aid in the collection and dissemination of information.
The more information there is available regarding new technological
developments, the more quickly will these new techniques be tried
and tested, and the more quickly will society as a whole be able to
benefit from them. I think a good example of this type of function is
the agricultural extension services provided by many state universities.
Likewise, the more information consumers have at their disposal
when they are making decisions regarding what products to choose,
the better off will society be.
Let me stress, however, that I advocate only the
dissemination of information, and I reject the notion that individual
entrepreneurs and consumers should be told what they may or may



-3not do on the basis of this information. It is one thing to give an
individual some information which helps him make a decision; it is
quite another matter to decide for him what the correct decision is.
The Surgeon General's report on the dangers associated with smoking
could be cited as an example of the dissemination of information. It
would be quite another matter if we attempted to pass a law which
forbids the use of tobacco products. It was this latter approach which
was tried, and predictably failed, with the prohibition of alcoholic
beverages and with seat belt interlock mechanisms.
I believe that the main reason why there are so many
government regulations is that the public is seldom made aware of the
total cost of most government undertakings. The benefits are
flaunted, but the costs are seldom computed, much less given equal
billing. If the public were given accurate and complete information
on both the costs and the benefits of government programs, I submit
that there would be many fewer of them. Our society currently
requires an environmental impact statement for all private projects;
why not require something like an economic impact statement for
government programs.
It is a common phenomenon today that when a group of
members of our society perceives something as a threat to their
security or to their environment, their immediate reaction is to turn
to the government for protection. I submit that many such calls for




-4the government to do something are indeed effective in getting the
government to do something, but in most instances that something
has so many costly side effects that it constrains the ability of our
economic system to achieve an efficient solution to the problem at
hand.
This kind of approach to our problems would be
defensible only if we could assume that the concentration of power
in the hands of the state is economically more efficient than is the
dilution of power which is inherent in private competition. I
submit that just the opposite is true. Power concentrated in the
state is less consistent with the maximization of economic
efficiency than is its dispersion among competing private individuals.
The primary reason is because those who make decisions within the
government are often insulated from the wishes of all segments of
society. On the other hand, inherent in the private rivalry of
competition is the power for every segment of society to let its wishes
be known. Government is an apparatus of compulsion which has the
power to obtain obedience by force. Oftentimes decisions within
government are made by a naturally myopic minority group who focus
pressure against a lethargic, dispersed and indifferent majority.
Implicit in the creation of every new government agency
is the bestowing upon its managers the power to force or coerce
others to adopt their values. As a result, these new government
agencies oftentimes merely feed the appetite for power on the part of



-5those who wish to impose their values on the rest of society. These
people seek through government to force some individuals to act
against their own immediate interests in order to promote a
supposedly general interest. They substitute the values of outsiders
(themselves) for the values of those who participate in the day-to-day
operation of an enterprise.
Past experience has taught us that bureaucratic
institutions are prone to become myopic in the performance of their
functions. For example, bureaucrats are typically given one
particular function to perform. However, just as any other
institution or individual, they are just one small part of an overall
system that has become too large for any one individual to understand,
much less control. They are rewarded for carrying out their own
particular function, irrespective of the effects of their actions on
other perhaps equally laudable goals.
One need not look far to find some examples of the kind of
problems that the situation I just described can lead to. Consider,
for example, the case of the catalytic converter. How many billions
of dollars have been spent on their design and installation, not to
mention the billions spent on the construction of a distribution
system for the lead-free gas they require? However, now we find that
we may have acted too hastily and the converters may cause worse
pollution than they eliminate. Consider also the case of cyclamates,




-6in which those who argued in favor of their continued use were
overwhelmed by a more powerful government agency. Now we find
that, here too, a decision was made too hastily and on the basis of
incorrect information. Facts did not prevail in either of these cases;
wishes did. This same phenomenon is, I think, well illustrated by
the recent remarks by the Commissioner of the FDA regarding Red
Dye number two. The Commissioner said that he was halting its use
because, and I quote, "there is no study in sight that is likely to
give unequivocal assurance of the safety of Red Dye number two."
In other words, guilt is presumed until innocence is proven; and,
since the criteria for proof is at the whim of the regulator, proof is
frequently impossible.
It is ironic that groups which constantly look for problems
in our country insist on inhibiting the ability of the economy to
respond to these problems. For example, present technology does not
permit us to have surgically clean air and plentiful electricity at less
cost at the same time. However, there is no reason to believe that
future technology could not provide those benefits. The essential
ingredient is freedom to react to incentives and an understanding
that regulation destroys creativity and creates an environment of
mediocrity. Just as thought control is the great enemy of the freedom
of inquiry, economic controls are the great enemy of the
entrepreneurial spirit which is needed to solve our problems.




-7Rediscovering the indivisibility and efficiency of political
and economic freedom will take time in a society which has become so
accustomed to overreliance on government intervention. The
political and intellectual bias against the free market is strongly
entrenched, and there are some who will always find a platform to
continue to feed this bias out of a complete misunderstanding of both
the political and the market functions.
I would like to conclude my remarks with an appeal for a
new approach to government regulation. Let us recognize that there
exists some optimum level of regulation. That is, we should recognize
that while there may be benefits derived from a particular form of
regulation, so also are there costs. Professor Murray Weidenbaum of
Washington University has estimated that the cost of operating our
regulatory agencies is $4 billion a year. However, this figure only
represents the tip of the iceberg. It is the inefficiency that
government shackles our economy with that represents the true cost
of these programs. Let us look at both sides of the coin. In any
particular case of proposed government intervention, we should make
up a balance sheet, listing separately the costs and the benefits of
the proposed regulation. In other words, let us analyze each and
every regulation within a cost-benefit framework. If we could limit
new regulations only to those whose benefit to society exceeds the cost,
there would be a lot fewer regulations. Then we must see that the same
yardstick is applied to existing regulations and regulatory agencies.



-8I sincerely hope that each of you will give the above
recommendation serious consideration. We have neglected the costs
associated with government regulations for too long. However, I
think we have finally reached the point where we can no longer
afford to be so myopic. I hope that these hearings and my remarks
will help move our nation to a more realistic appraisal of the
unnecessary burden placed upon our society by our current maize
of regulations.