This chapter includes an evaluation of the level of adoption of each of the building blocks to introduce, design the necessary framework and prepare the implementation of the RIA in Peru. The OECD report on Building an Institutional Framework for Regulatory Impact Analysis (RIA), Guidance for Policy Makers is used as a guide for such evaluation.
Implementing Regulatory Impact Analysis in the Central Government of Peru
Case Studies 2014-16
Chapter 6. Evaluation of the building blocks of a RIA system in Peru
Abstract
Introduction
The OECD report Building an Institutional Framework for Regulatory Impact Analysis (RIA), Guidance for Policy Makers (OECD, 2008[1]) identifies the subjects that must be addressed by an analyst to create the guiding framework for regulatory impact assessment (RIA). According to the report, regulators involved in regulatory-management matters and public policies should consider if there are some pre-existing conditions and to what extent current institutions can provide a good framework to implement the RIA, before venturing into the design and implementation of the RIA. The framework offered by the OCDE in this report highlights the questions that must be considered and the benefits of this tool to help professionals better understand the elements needed for a RIA system.
Figure 6.1 shows a summary of the building blocks needed to implement a RIA system, which also should be considered and evaluated by the analysts in charge of the regulatory policy. This chapter includes an analysis of the level of adoption of those building blocks in Peru, carried out by the OCED. The quotations of the next section explain the importance of each building block, and they are immediately followed by their corresponding assessment for Peru.
Evaluation
Introduction of the RIA
Before designing and implementing the RIA system in Peru, a series of elements that will effectively contribute to adopt and implement RIA for increasing the quality in the design of the regulation should be considered. These building blocks are described below:
1. Political commitment
One of the essential factors for the adoption of the RIA is to have political support from the highest level, as this allows its implementation to be widely accepted as a new tool to create regulations; even by the agencies issuing them, who must modify their current methodologies y conduct these impact assessments while developing any new regulation.
Over the last years, the Peruvian government implemented a series of measures aimed to improve the quality of regulations through different high-level agencies. On the one hand, the PCM is responsible for the administrative simplification and the promotion of regulator quality, in which the RQA is a pivotal element. The MEF conducts an economic analysis of regulations, which has the objective of guaranteeing the coherence between the sectorial and the economic policies of the government. The MINJUSDH issued a manual on legislative technique to prepare regulatory proposals and, in certain cases, it also analyses the consistency of regulation with the legal framework in force; the CCV reviews and discusses multisectoral regulatory proposals. The National Institute for the Defense of Free Competition and Protection of Intellectual Property (INDECOPI), which reviews the existence of bureaucratic barriers. In addition to this, each ministry and government agency frequently have legal divisions who often perform a legal analysis of the regulatory proposals prepared by each regulator and, in some cases, they even have experts in economics, who conduct impact analyses of the regulatory proposals.
Figure 6.1. Building blocks necessary to implement a RIA system
Source: (OECD, 2008[1]), Building an Institutional Framework for Regulatory Impact Analysis (RIA): Guidance for Policy Maker, OECD Publishing, Paris, http://dx.doi.org/10.1787/9789264050013-en.
However, within the public administration there are no cross-cutting instructions for the adoption of an ex ante evaluation system that acts as an analysis tool to assess the impact and regulatory quality, with the exception of the RQA. Although Legislative Decree Nº 1310, its Bylaw and the Manual for the application of the Regulatory Quality Analysis are an unprecedented step for an ex ante evaluation of the regulation, it cannot be considered as a RIA system yet. These instruments establish a system of ex ante evaluation of regulatory proposals that focuses on the performance of an analysis of the formalities included in the proposal in question. Its objective is to evaluate the administrative procedures following the principles of legality, need and proportionality. Specifically, in the process of need these elements are evaluated i) identification of the public problem that the regulation seeks to solve; ii) the objective of the administrative procedure and if it exists a causal relation with the public problem; iii) analysis of different alternatives to the procedure and the risk in case its evaluation is produced. An element that could be added to the RQA is the evaluation of administrative procedures based on a comparison of potential costs and benefits. This, the RQA is a vital element for the ex ante evaluation of regulations in Peru, but it still requires further development to be considered a RIA system. However, the implementation of the Regulatory Quality Analysis underlines the fact that in Peru there is a political commitment for the ex ante evaluation of regulation, and that it could be used to introduced the RIA system, following the recommendations described in the next chapters.
In addition to the Regulatory Quality Analysis process that is a responsibility of the PCM, as of January 2017 a pilot committee, which was integrated by the PCM, MEF and MINJUSDH, was created to introduce the RIA for all draft regulations, as a pilot programme.
Finally, with the publication of the Legislative Decree Nº 1448 that modifies Article 2 of the Legislative Decree Nº 1310, Legislative Decree that approves the additional administrative simplification measures and perfects the institutional framework and the instruments that rule the process of improvement of regulatory quality, the bases for the implementation of a transversal and integral regulatory policy are established. In the Legislative Decree, RIA is defined as a tool for regulatory quality and mandates the PCM, MEF and MINJUSDH to emit a decree for the implementation of this tool. This is additional evidence that there is a political commitment in Peru for the formal and systematic adoption of a RIA system.
a. Stakeholders
Besides the political support, it is necessary that groups get involved both inside and outside of the public administration, that they acknowledge and assess the positive and negative conditions in the adoption of the RIA, and that also contribute to disseminate the use of this tool in the decision-making process. These groups can be integrated by public or private institutions, where the counseling offices of the presidency or the prime minister, the different ministries, parliaments, business and consumer associations, and academics participate.
Pursuant to Article 14 of the Bylaw that lays down rules on advertising, publication of regulatory proposals, and dissemination of General Legal Rules, public entities are obliged to publish in the Official Gazette El Peruano the general regulatory proposals that fall within their purview, this must be done at least 30 days before the scheduled date for their entry into force, as well as the deadline to receive comments. The above suggests that Peru has a formal mechanism to allow the participation of stakeholders in regulatory proposals. Nevertheless, this is done once the proposal has already been designed and not in advance. However, some ministries —such as MINAM and PRODUCE— have mechanisms for the participation of stakeholders before the regulatory proposal is prepared, for instance, advisory panels or workshops. Whereas, in others, performing this consultation depends on the regulation and the affected sector.
Furthermore, once the pre-publication of the regulatory proposal has been carried out and the comments are received, there is no formal obligation of responding to comments, although – in practice – it may be done.
b. Legal mandate for RIA
It is necessary that the government expresses its commitment to the use of RIA through a high-level regulatory instrument, that lays down clearly the standards and quality principles of the regulatory policy. To this end, different regulatory instruments have been employed in OECD countries, including laws, decrees, presidential decrees, guidelines or resolutions of prime ministers or government resolutions, among others. Even, another way of expressing the political commitment for the use of this tool can be done by having the RIA instrument directly signed by a minister or a deputy minister.
Currently, Peru has several normative instruments that influence the quality of the issuance of regulations. First of all, the Law of General Administrative Procedure, which lays down that regulation must observe the principles of rationality and proportionality. There is also the Guide on Legislative Technique for the Development of Regulatory Proposals from the Entities of the Executive Branch, which takes as reference the Law Nº 26889, Framework Law for Legislative Production and Systematization, which governs the guidelines for the preparation, titling and publishing of laws, and its Bylaw, approved by Supreme Decree Nº 008-2006-JUS. These instruments, however, are directed to the writing up and structure that must be followed to prepare regulatory proposals, but not to the quality of the regulation; and if this is really necessary and produces greater benefits than costs to society. Likewise, as part of their processes to issue regulations and according to their internal rules, the legal office of each ministry examines and assesses the legal consistency of the regulatory instruments intended to be issued, in order to avoid duplication or conflict with the existing regulation. In the same way, part of the tasks of the MEF includes to carry out an economic analysis of the regulation; while the MINJUSDH reviews that the regulatory proposal does not oppose the Constitution nor federal laws, but this is only for the proposals that have been submitted before the Council of Ministers and the CCV. Moreover, on December 30, 2016, the Legislative Decree Nº 1310 approving additional administrative simplification measures was issued; its Article 2 lays down that the entities of the Executive Branch must conduct a Regulatory Quality Analysis, but this is limited solely to rules that establish administrative procedures.
Finally, the Legislative Decree Nº 1448 published on September 16, 2018 defines the regulatory quality policy in Peru, establishes the RIA as tool for regulatory quality and mandates the PCM, MEF and MINJUSDH to emit a decree for the implementation of RIA.
2. Integrate RIA timely in the decision-making process
As the regulatory impact assessment is a policy tool that helps to make decisions, it is necessary to integrate it into the effective policy-making process. RIA provides an assessment of regulatory alternatives and that is why it is crucial to integrate it at an early stage of the policy-making process, this will provide an initial phase of exchange and communication of the potential effects of legislation once it is passed.
So far, Peru has not formally nor systematically adopted all the stages that are an essential part of a RIA system as a tool within the policy-making process, with the exception of the contributions that the RQA makes to the definition of the problem, the public policy objective, identification of alternatives and some costs (see Chapter 5). It is necessary to integrate this impact analysis from an early stage of the policy-making process, so that it contributes efficiently to make decisions and achieve its objectives; otherwise, the RIA can become a tool to justify political decisions or, even, a barrier to issue regulation.
3. Build a RIA team inside the administration
The success of implementing the RIA also depends on the way a RIA team can be made up and strengthened inside the administration, which must be familiar with the current institutional setting. The consolidation of this team will be aimed at integrating this tool into the policy-making process.
There are several groups, within the public administration, whose powers have a bearing on the analysis of regulations; on one side, the MEF, which is responsible for carrying out an economic analysis and a cost-benefit analysis; on the other, the MINJUSDH, which conducts an analysis of the constitutionality and legality, as well as of the legal quality; and the PCM, which assesses whether the proposal is compatible with the organisation and operation of government and if it requires a RQA. These agencies act in an independent capacity and, in most cases, at the request of the entity sponsoring the regulatory proposal; they act collegially through the CCV, but only for multisectoral proposals or those that require the approval vote of the Council of Ministers. Furthermore, the Multisectoral Commission of Regulatory Quality (CCR), subordinated to the PCM, evaluates the Regulatory Quality Analysis of draft regulations. Lastly, the PCM, MEF and MINJUSDH participate in the pilot programme of RIA. Nevertheless, there is not a permanent team in charge of formally reviewing the quality of the regulatory proposals with a RIA1 approach. On the contrary, there is a variety of actions and initiatives that still need to be articulated under a whole-of-government regulatory policy, although the process for the preparation and evaluation of the RQA is a step in this direction.
That is why an oversight body must be created with the explicit mandate of supervising the development process of new regulations, ensuring the quality of RIAs and regulatory proposals or, where appropriate, entrusting that responsibility to an entity within the central government, vested with extensive powers to direct the work of implementing the regulatory impact assessment in Peru.
a. Who should conduct RIA
Considering that several government agencies are the ones empowered to draft regulations, the RIA should be implemented within them; and since this tool requires multiple capacities, it is necessary to create cross-functional technical teams that contribute to draft the RIA with a comprehensive perspective, and have political, legal, economic and communication expertise.
Although each regulatory body within the public administration has several groups of their own able to carry out legal, economic or impact analyses, among others, these are not yet conducted in an articulated way and, in many cases, they only respond to the human resources available.
b. Institutional setting for RIA
There is not a unique institutional model for the systematic use of RIA, since among OECD countries there is a great variety of institutions sharing different responsibilities and working following different methodologies. Nevertheless, in general, it can be considered as a specialised department or group of experts in each line ministry and regulatory institution who undertake the RIA work. In order to ensure co-ordination among these bodies and to give coherence to the regulatory systems, there are two institutional set-ups:
• Centralised institutional frameworks rely on an oversight body for regulatory reform, located at the center of government. In this case, its powers are supported by the highest political level (president, governor, prime minister, etc.) or by a budgetary decision-making institution (Ministry of Economy and Finance).
• Decentralised institutional frameworks do not rely on a specific oversight body, and the co-ordination among regulators is essential to obtain policy objectives. Responsibilities are normally shared by different regulatory institutions and line ministries, which use extended consultations mechanisms to reach agreements and consensus.
Based on OECD experience, choosing either of the institutional frameworks for RIA often depends on the political support available, the original institutional framework, the political and public administration culture, the resources at hand and, more particularly, the existence of any general programme focused on regulatory governance and reform.
As noted, Peru has several agencies partially responsible for the quality of regulation with a RIA approach, but it does not yet have a supervisory body to oversee the development process of the new regulations that ensures the quality of RIA and the regulatory proposals.
Designing the RIA framework
Once preconditions have been created, the next step is to design the RIA process. The design phase involves examining each component of the proposed system for conducting RIA and determining its feasibility. This includes co-ordination mechanisms, targeting RIA efforts, improving data collection and using a flexible methodology for RIA. The components are described below:
4. Co-ordination and management
A RIA system needs to be co-ordinated and carefully managed across the central ministries of government and other law-making institutions. Allocating responsibilities among regulators improves the “ownership” and integration by decision making agents that may generate opposition or badly articulated co‑ordination mechanisms.
In the ideal process, a preliminary RIA document undertaken by the institution initiating the proposal accompanies draft regulation or legislation; and an extended network of policy makers spread around the public administration working on RIA, for their own policy purposes specialised in different issues depending on their field of work, will contribute substantial content to the analysis of possible impacts.
In order to consolidate co-ordination among all parties, some OECD countries have also established a central body with a leading role at a high political level, responsible for overseeing the RIA process and ensuring consistency.
Moreover, a consistent methodology for RIA and its quality standards can be promoted with the provision of guidelines, ensuring that the process follows certain steps in a systematic way and that the final RIA document attains the desired quality level. In any case, increasing capacities inside the administration to conduct RIA is fundamental to make better use of this policy tool.
The OECD experience shows that monitoring and oversight institutions offer quality control by providing basically three services to officials undertaking RIA:
1) consultation and technical assistance in drafting RIA
2) review of an individual RIA, and
3) stocktaking of general compliance with RIA by law makers
Although these institutions should be given the appropriate level of authority to ensure their effectiveness, adequate work is necessary to raise awareness among all parties, provided that the levels of authority vested allow for the participation in the usual public policy flows (i.e., right of veto), and prioritise the search for creative solutions in the face of systematic intervention in processes that involve abusing the powers conferred.
There are several agencies in charge, to a greater or lesser extent, of the regulatory quality in Peru with a RIA approach. In the case of multisectoral regulations, three agencies – that have shown great co-ordination – participate: PCM, MEF and MINJUSDH. However, this co-ordination is vague for regulations issued by a single ministry, except when participating in the Multisectoral Commission of Regulatory Quality. Currently, there is not a governing body for regulatory policy, but rather a group of agencies vested with certain powers that participate in the rule-making process.
5. Targeting and prioritising RIA efforts
Policy makers should target RIA towards regulatory proposals that have the largest impact on society and ensure that all such proposals be subject to close RIA scrutiny. At first, considering limited resources and aiming at familiarising civil servants and stakeholders with the new process, efforts should concentrate on the most challenging regulatory areas.
As RIA is an activity that requires an important degree of expertise and responsibility, it is essential to precisely define the regulation to which RIA is going to be applied. Ideally, it should be applied to high-impact regulations, where their benefits may be higher.
There is no practice in Peru of conducting a more exhaustive impact analysis for regulatory proposals of great importance, nor were criteria established to identify which regulatory proposals this type of assessments should be applied to.
6. Strategies for data collection
Data quality is an essential element for conducting a proper analysis. However, this is one of the most difficult parts of RIA because it can be time and resource consuming; consequently, it requires a systematic and functional approach. The usefulness of RIA depends on the quality of the data used to evaluate the impact of regulation. Hence, governments need to set up a functional framework for a quantitative analysis by developing precise and straightforward strategies and guidelines. This implies, as well, that policy makers need to gain certain skills, think in quantitative terms and get acquainted with the collection of the necessary data for each particular case.
Although a large amount of data is collected through the consultation process, there are numerous ways and sources to get it (in-house expertise of economists, lawyers and analysts; commission research and studies; dedicated RIA training, networking for RIA; international data and best practices; and so forth).
According to the information gathered in the different ministries, there are several data collecting strategies that contribute to the analysis of the draft proposal. Some ministries conduct early consultations with in-house stakeholders and external ones to the public administration. In other cases, the statistical information existing within the ministry itself is used or, even, national and international statistical information is checked, or desk research is also carried out (bibliographic sources, Internet, etc.); but there is not a homogeneous or defined method for a systematic data collection.
7. Using a flexible analytical method
Determining which method to apply is a central element of RIA design and performance. There are several methods used, such as cost-benefit analysis, cost-effectiveness or cost-output analysis, fiscal or budget analysis, socio-economic impact analysis, risk analysis, consequence analysis, compliance cost analysis and business impact tests.
At first, it is common to start with an assessment of costs and quantify the benefits later on. Nevertheless, the latter is a more complicated task since benefits are usually more difficult to measure.
Efforts should be scaled to the specific capacities of each country or region, considering the available resources to collect and analyse the required information. It is not about conducting complex technical analyses but about asking the right questions to the right people.
In nearly all countries, there are a number of instruments that may be used as pillars for the development of a RIA system, among which stand out the legal justifications (notes attached to the laws) or the budget and environmental impact assessments.
The same analytical process applies to the multisectoral regulations that must be examined by the CCV: an economic analysis performed by the MEF, a legislative technique analysis by the MINJUSDH, and an administrative simplification and regulatory quality analysis by the PCM. In the case of regulations issued by an entity, each of them performs different assessments, based on their economic and human resources available, as well as on the relevance of the regulation, plus the Regulatory Quality Analysis of the PCM. However, the legal analysis —that is done at the same time— examines the consistency with the regulatory framework in force. Moreover, some ministries perform a cost-benefit analysis, although in some cases they are more qualitative than quantitative or, in the case of the MTC, differential analyses are also carried out. Likewise, proportionality analyses are carried out but they are done intuitively, because there is not a standardised methodology.
8. Consultation, participation and transparency
RIA can only be legitimate and efficient if it is integrated into public consultation procedures. The systematic integration of stakeholders’ views undoubtedly enhances the quality of this tool. Therefore, consulting these groups can furnish very important information on the feasibility of the proposals. Likewise, it also increases the likelihood compliance, as the ownership of the proposed regulation is shared with these stakeholders.
It is possible to increase the amount of data available for decision-making and reduce the risk of "data capture" by opening the process and involving all stakeholders.
Likewise, the RIA system can only add value if it increases transparency and participation in the regulatory process, and the only way to achieve so is by involving the public. In this sense, stakeholders should be incorporated from the early stages of the process, participating in the assessment of the need for regulation and in the design of the RIA document itself.
There is a procedure for the participation of stakeholders through the pre-publication of regulatory proposals, the Bylaw that lays down rules on establishes provisions for the advertisement, publication of regulatory proposals and dissemination of general legal rules lays down in its Article 14 that stakeholders should be allowed to make their comments on the regulatory proposals. However, there is no harmonised or formal procedure to respond to the comments received.
On one hand, each ministry has several types of consultation that are performed at different times of the development of the regulation and respond to different circumstances. For instance, the MTC conducts specific consultations on telecommunications with certain sector groups; whereas, in the case of transport, it carries them out based on the interests of the regulation. As to the MINAM, it has a specific regulation on transparency and citizen participation for environmental matters; and they consult both with technical groups and with the public at large. PRODUCE, on its part, also makes preliminary consultations through the delivery of workshops. The MEF makes the consultation calling through e-mail or official communication with the ministry related to the activity to be regulated and, to a lesser extent, with trade associations. Most of the time, the regulatory proposal is also posted on the website of each ministry.
In general, although a public consultation is carried out with the pre-publication of the draft proposal, it is done after the proposal has been defined. On the other, in most of the cases preliminary consultations are not formal.
Preparing the implementation of the RIA
The implementation phase of this new policy tool requires, besides training, to become familiar with it, particularly by those who draw up the regulatory proposals, because this new methodology involves a cultural change within the public administration. Therefore, it is important to take into account the following factors:
9. Developing guidelines
Aiming at facilitating capacity building processes on RIA, many countries’ authorities have drafted clear, concise and accessible guidelines, where theory and practical methodology are explored and in which the use of this policy tool is explained. These documents tend to cover a wide range of issues, but usually they are understood as “living documents” that can be continuously improved as experiences and knowledge of RIA issues accumulate and new techniques or methodological changes are embraced.
It is essential to have a series of mandatory basic guidelines at the highest level (laws and regulation), and it is advisable to detail them in an operating manual and/or rely on a consulting firm that can advise on their application and interpretation.
In most OECD countries, central oversight bodies for regulatory reform are in charge of drafting and distributing these guidelines. If these institutions are not responsible for the training on RIA, strong co-ordination mechanisms should be arranged in a timely manner.
The legal instruments available in Peru, described in Chapter 4, do not include a manual nor specific guidelines to perform the RIA. The only instrument including a specific guide for an ex ante evaluation of regulations is the Manual for the application of the Regulatory Quality Analysis, but it focuses solely on the legislation that includes administrative procedures.
10. Training the regulators
Training and capacity building are the most important factors for the success of RIA implementation and systematisation. First, training and capacity building programmes should be established to familiarise officials with their obligations about RIA and the use of its guidelines. At a later stage, properly designed training programmes should be conducted to give regulators the skills needed to undertake high quality RIA as well as providing information on where to get advice with more complex cases. At this stage, it is necessary to thoroughly apply the methodologies for measuring impact and rely on the expertise of relevant practitioners.
This training, however, should not only be targeted to regulators, but should also include civil society and business associations to promote their participation and the addition of more value to public consultation or promote other public policies of their interest with the appropriate support.
Once RIA is introduced in the regulatory process, practical problems may occur more often than technical ones derived from misunderstanding or ignorance of theoretical aspects of RIA. This is why training and capacity building on RIA are of vital importance for its success.
As the use of RIA implies a change of culture in public administration, as already mentioned, it is important to establish training programs, first, to make it known in all government levels and, second, the usefulness and benefits of using this tool, as well as its scope to create public policy alternatives.
Knowledge about this tool has begun to be disseminated in the Peruvian government, workshops have even been delivered with the MEF and other ministries and public entities, including PCM, MINJUSDH, MTC, PRODUCE, MINAM, VIVIENDA, as well as the supervisory agencies (OSINERGMIN and OSITRAN). Nevertheless, it is important to create ongoing training programs that even consider the preparation of a RIA and its analysis.
11. RIA as a communication tool
There are mainly two aspects of communication that have a major impact on a RIA system. First, the communication within the public administration to ensure coherence and co-ordination, and second, the communication of results to all parties involved and interested that may be outside the administration.
Although some activities have been carried out to begin disseminating the use of RIA as the next tool of the public administration to draw up regulations, namely, training workshops, there are still no relevant plans or programs to make it known to all entities and at all levels, as well as to stakeholders. This is particularly important so as to RIA be an efficient tool and widely used by all regulators, as well as to convince stakeholders and even public at large of its usefulness as guarantee of regulatory quality.
a. Communication inside the administration and the network of RIA experts
RIA is a policy tool that should be used by officials working in different government agencies. To ensure co-ordination and coherence in their work, effective communication channels must be established. This communication should be established through a technical network of practitioners to bring the benefits of the exchange of information and share experiences. Furthermore, it is crucial that the activities of all regulators implementing RIA are co-ordinated in an adequate and systematic way to complement and increase communication among them.
According to several current procedures for drawing up regulations, there are some co‑ordination processes among some government entities, for instance, to draw up multisectoral regulation, where the PCM, MEF and MINJUSDH participate in a co‑ordinated manner. However, for the regulation issued by a single ministry, the co‑ordination among several entities is not so formal and it is limited to transfer the draft proposal from one division to the next, so that each of them conducts the corresponding analysis.
b. Communicating results
A major impact of RIA lies in its capacity to show the different possible ways to proceed when putting forward a law proposal. RIA activities should be reviewed and the results communicated, in order to draw lessons from the whole process. This implies not only the release of RIAs along with draft regulatory texts as part of the consultation procedure, but also to record those cases in which the RIA system succeeded in weeding out inefficient regulatory proposals before enactment.
Communication is a key element of RIA and must be in alignment with the policy objectives of the regulation under analysis. The institutions responsible for RIA communication should be clear about who is affected by the analysed regulation, so communication can be well targeted to all stakeholders.
Lastly, bibliography should be provided in the annexes to the RIA so that interested users can find the background information employed to undertake the RIA.
In the current process of drawing up regulations, some ministries follow different steps to show to (in-house and external) stakeholders the results of the regulatory process. For example, MINAM and PRODUCE make preliminary consultations should a problem arise and they decide to step in as regulators to solve it; with this they determine whether or not a draft proposal is needed. Afterwards, and once the development of the draft proposal has been decided, the pre-publication is done, where comments from individuals are received; and, then, the draft proposal is published. However, there are no transparency mechanisms to make known the participation of all the stakeholders, as well as whether or not they had an impact on the draft proposal.
Chapter 7 includes specific recommendations for Peru to address each of these building blocks.
Reference
[1] OECD (2008), Building an Institutional Framework for Regulatory Impact Analysis (RIA): Guidance for Policy Makers, OECD Publishing, Paris, http://dx.doi.org/10.1787/9789264050013-en.
Note
← 1. The PCM, MINJUSDH and MEF have officials devoted to carry out the RIA of the regulatory projects, on top of performing other functions.