the scope of Executive Order 13771 extends to conventional regulatory actions, deregulatory actions, and significant guidance documents. Second, Executive Order 13771 focuses on regulatory cost alone without regard to regulatory benefits. Executive Order 13777 Executive Order 13777 directs federal agencies to establish Regulatory Reform Officers (RROs) to “oversee the implementation of regulatory reform initiatives and policies to ensure that agencies effectively carry out regulatory reforms, consistent with applicable law.” RROs are responsible for identifying regulations that, inter alia, “eliminate jobs, or inhibit job creation.” “are outdated, unnecessary, or ineffective,” “impose costs that exceed benefits,” or “create a serious inconsistency or otherwise interfere with regulatory reform initiatives and policies.” In addition, existing regulations that rely on information that violates the Information Quality Act are specifically targeted for repeal, replacement, or modification. Executive Order 13777 specifically directs agencies modify the performance indicators established pursuant to the Government Performance and Results Act of 1993 (GPRA) to reflect Executive Order 13771 goals. OMB implementing guidance expands upon the Order by enumerating specific requirements and expectations for agencies’ FY 2018 GPRA annual Performance Reports and FY 2019 annual Performance Plans. This is a key process change. OMB’s GPRA existing guidance does not reflect regulatory policy objectives, and the decision to include them is new. Executive Orders 13891 and 13892 On October 9, 2019, the White House issued two executive orders, Executive Order 13891, Promoting the Rule of Law Through Improved Agency Guidance Documents, reprinted at 84 Fed. Reg. 55235 (Oct. 15, 2019), and Executive Order 13892, Promoting the Rule of Law Through Transparency and Fairness in Civil Administrative Enforcement and Adjudication, reprinted at 84 Fed. Reg. 55239 (Oct. 15, 2019). Both Executive Orders are generally directed to requiring federal agencies to “act transparently and fairly with respect to all affected parties … when engaged in civil administrative enforcement or adjudication.” E.O. 13892 goes on to explain that individuals should not be subject to enforcement actions without “prior public notice of both the enforcing agency’s jurisdiction over particular conduct and the legal standards applicable to that conduct.” Executive Orders 13891 and 13892—in General For the most part, Executive Orders 13891 and 13892 are simple reminders and restatements of long-standing requirements of the Administrative Procedure Act (APA). For example, E.O. 13891 § 1 and E.O. 13892 § 3 remind agencies that they may not enforce “rules” against the public unless those rules are promulgated as “regulations,” in