Affordability, Security, and Regulatory Discipline: What CRF’s Latest Comments Tell Us About Governing at Scale

Last week, the Center for Regulatory Freedom (CRF) filed a series of formal comments across multiple federal agencies, addressing issues ranging from immigration adjudication and border integrity to energy preparedness, artificial intelligence governance, health care access, and housing finance paperwork. While these comments responded to distinct rulemakings and requests for information, they were unified by a consistent policy framework: affordability depends on disciplined regulation, and national security depends on institutions that function as designed—not on paperwork accumulation or bureaucratic overreach.

Taken together, CRF’s submissions highlight a central truth of modern governance: regulatory systems that lose sight of function, proportionality, and economic reality ultimately undermine both public trust and public outcomes.

Affordability Is a Regulatory Outcome, Not a Slogan

Across agencies, CRF emphasized that affordability is not achieved through mandates or aspirational targets, but through supply, efficiency, and institutional clarity. Whether addressing energy infrastructure, health care delivery, or housing finance, CRF warned that excessive or misdirected paperwork requirements translate directly into higher costs for consumers.

In its comments to the Environmental Protection Agency on Oil Pollution Act Facility Response Plans, CRF supported genuine emergency preparedness while cautioning against paperwork creep that diverts resources away from operational readiness and into compliance theater. Energy infrastructure sits at the foundation of the modern economy; when regulatory paperwork expands beyond operational necessity, those costs are passed through to fuel prices, electricity rates, and consumer goods. Paperwork discipline, in this context, is not deregulation—it is energy affordability policy.

A similar logic guided CRF’s comments to the Centers for Medicare and Medicaid Services on transcatheter aortic valve replacement (TAVR). There, CRF argued that outdated Coverage with Evidence Development requirements now function less as evidence tools and more as access barriers—particularly for rural and mobility-limited patients. When bureaucratic conditions persist long after evidentiary questions have been resolved, they restrict access, delay care, and raise system-wide costs without improving outcomes. Removing such barriers is a necessary step toward a more affordable and responsive health care system.

Sound Regulatory Policy Requires Distinguishing Function from Friction

A recurring theme in CRF’s comments was the need to distinguish between necessary adjudicatory information and low-value regulatory accumulation. The Paperwork Reduction Act was designed precisely to enforce that distinction, yet too often agencies collapse all paperwork into a single category of “burden,” obscuring whether the information collected actually informs real-world decisions.

CRF’s submissions to U.S. Citizenship and Immigration Services on Forms G-28/G-28I and Form I-131 made this point explicit. Immigration adjudication and border control are core sovereign functions. Information collections that verify lawful representation or determine eligibility for travel and reentry are not bureaucratic excess—they are integral to lawful governance and procedural integrity. Eliminating or weakening such collections in the name of burden reduction would undermine both due process and system integrity.

At the same time, CRF stressed that defending necessary paperwork strengthens—not weakens—the case for eliminating paperwork that merely accumulates data without affecting outcomes. Regulatory reform succeeds only when it is principled and targeted, not indiscriminate.

This same functional lens shapes CRF’s support for HUD’s technical update to its Privacy Act System of Records for CAIVRS. CRF backed the revision precisely because it improved accuracy, transparency, and data minimization without expanding eligibility, altering underwriting standards, or affecting access to credit. Treating such technical corrections as policy shifts would confuse paperwork governance with substantive regulation—and erode public confidence in both.

National and Homeland Security Depend on Institutional Design

CRF’s comments also underscored that security is as much an institutional design problem as a resource problem. Nowhere was this clearer than in CRF’s response to the Department of Energy’s Request for Information on partnerships for transformational artificial intelligence models.

CRF argued that artificial intelligence models trained on DOE scientific data now function as strategic national infrastructure, with implications for energy reliability, defense readiness, and technological competitiveness. The critical question is not whether government should engage, but how. Over-centralization, discretionary access rules, or guidance-driven control risk chilling private participation and slowing deployment—outcomes that weaken, rather than strengthen, national security.

Drawing on the logic of Bayh-Dole–style decentralization, CRF urged DOE to adopt a framework of mobilization without centralization: curate and safeguard foundational assets, but enable decentralized development, competition, and diffusion. In a world of rapid technological change and strategic competition, resilience comes from pluralism and speed—not from bureaucratic control.

The same principle applies at the border. Effective homeland security requires clear gatekeeping rules, lawful adjudication, and information that directly informs decisions about entry, representation, and status. Treating such information collections as mere administrative burdens risks weakening the very functions the government is most clearly obligated to perform.

Governing for Outcomes

Viewed collectively, CRF’s comments last week advance a coherent governing philosophy: affordability, security, and innovation are not competing goals—they rise or fall together based on regulatory discipline. Institutions that collect information untethered from decisions impose costs without benefits. Institutions that lose sight of proportionality undermine trust. And institutions that confuse control with stewardship risk falling behind in a competitive world.

Regulatory reform, properly understood, is not about shrinking government for its own sake. It is about ensuring that the government acts where decisions are required, restrains itself where paperwork merely accumulates, and structures policy to deliver real-world outcomes for Americans. That is the through-line of CRF’s work—and the standard by which regulatory policy should be judged going forward.