In an April 19 report, Why Congress Must End Regulation by Guidance Document, the Competitive Enterprise Institute (CEI) warns us about the enormous impact of federal agencies’ sub-regulatory “guidance” documents, including a big negative effect on the economy and job creators. These guidelines, which can be as informal as a bulletin or press release, do not undergo formal notice and comment rulemaking procedures and are not legally binding in a strict sense, as the House Oversight Committee has noted. Nonetheless, they are used to make major policy decisions and, according to Senator Pat Roberts (R-Kan.), are “often as effective as regulations in changing behavior due to the weight agencies and courts give them.”