1. United States
2. Ind.
3. Letter

I urge you to oppose SB76, the Setting Manageable Analysis Requirements in Text Act of 2025. While this bill claims to improve regulatory effectiveness through retrospective review, it creates dangerous opportunities for agencies like Immigration and Customs Enforcement to expand their authority without meaningful oversight. SB76 requires federal agencies to assess whether major rules with annual economic effects of $100 million or more accomplish their stated objectives within ten years of implementation. The bill severely restricts judicial review, allowing courts to examine only whether agencies published required assessments, not the substance or adequacy of those assessments. This limitation eliminates meaningful accountability for how agencies like ICE interpret and apply their regulatory authority. The Administrator of the Office of Information and Regulatory Affairs gains broad exemption authority under this legislation without specified criteria for when exemptions apply. This creates potential for inconsistent application that could favor enforcement agencies while burdening agencies focused on protecting vulnerable communities. Additionally, the bill authorizes unspecified appropriations, meaning enforcement agencies could receive substantial resources for assessment activities while agencies serving immigrants and refugees face continued underfunding. The legislation contains no consequences for agencies that determine their rules are ineffective or fail to accomplish objectives. This means ICE could conduct perfunctory assessments of immigration enforcement regulations, conclude they are not meeting stated goals, yet continue or even expand enforcement activities without modification. The ten-year assessment timeframe is far too long for rules affecting immigrant communities, where harmful effects manifest immediately. I ask you to vote against SB76. Any regulatory reform legislation must include robust judicial review, clear exemption criteria, specified consequences for ineffective rules, and protections ensuring that assessment requirements do not become tools for expanding enforcement authority over vulnerable populations.