Operation Brushfire: An LLM For Major Regulatory Reform

BY JASON KILLMEYER

A Policy Brief Prepared for The Department of Government Efficiency (DOGE)

On behalf of the Club for Growth Foundation

Foreword

The brilliance of the American Constitution lies in its carefully crafted balance of powers, designed to prevent any one branch from becoming too powerful. Legislative authority was intentionally reserved for Congress, made up of elected representatives accountable to the people, while the executive branch was tasked solely with enforcing laws and the Juciary with interpreting them. However, the rise of the bureaucracy has effectively created a fourth branch of government—one never envisioned by the Founders.

This unelected body, originally intended to serve a purely administrative role within the executive branch, now wields significant legislative and regulatory power, undermining the Founders’ vision of safeguarding liberty by ensuring that lawmaking remains exclusively in the hands of representatives chosen by the people.

The truth about regulations is that they have the force of law. As the Legislative Branch continues to cede its Constitutional authority to unelected bureaucrats, those bureaucrats have compiled over 200,000 pages of federal regulation, adding 90,000 pages of revisions and updates each year as documented in the Federal Register.

The result is that the “Regulatory State” is the true governing force in American life – tens of thousands of edicts promulgated by over 400 federal agencies that impact the day-to-day lives of the American people more than the legislation passed by our elected representation in Congress. Americans are forced to accept “Rule by the Register.”

For instance, small and mid-size manufacturers – the backbone of our economy – face aggregate annual regulatory costs per employee of $50,000. Neither the Congress, nor the people, ever voted for such a tax – but this insidious accumulation of regulatory burden bears upon small and mid-size manufacturers all the same. This is a devastating impediment to progress in a country with over 600,000 unfilled manufacturing jobs that dampens worker wages and is a direct assault on the Constitution’s brilliant system of distributed power.

In 2025, an important first step in resetting the relationship between citizen and state is the focus by the newly formed Department of Government Efficiency (DOGE) on unearthing efficiency and eliminating waste, fraud, and abuse. DOGE will need to utilize innovative strategies and disciplined execution to accomplish its mission. Fortunately, it appears that the DOGE leadership understands the stakes.

Executive Summary

As 2025 approaches, America’s governing compact is fraying. Founded on the ideals of liberty and limited government, the power of the American government can only be justly derived from the consent of the governed. These principles are not mere historical curiosities; they are the foundation of our union.

The restoration of these principles requires vigilance and decisive action to curtail bureaucratic overreach and empower the people to reclaim self-governance. If this broad imbalance of power is not corrected, this union cannot stand. Americans are too proud and diverse a people to endure such a centralized and unrepresentative form of government.

Despite this undeniable truth, previous attempts to reform the regulatory state have largely failed, and the sheer pace of regulatory churn – again, over 90,000 pages of changes every year – further complicates the task.

Not only is the future of American ingenuity and prosperity at stake, but the hundreds of thousands of federal regulations are violations of the Bill of Rights. Regulators often skillfully– and sometimes deceptively – impose their political will by redefining terms and concepts used in the initial legislation.

If changing the status quo is a required step to the restoration of self-government and the balance of powers, then DOGE must find a way. A moment such as this will not present itself again, and it is time to seize this moment and significantly curtail federal regulations.

Doing so will require skill and efficiency, and the DOGE should utilize emerging technology to expedite and exact the process of identifying the usurpations of Congressional intent alongside the freedoms constituted in America’s founding documents.

Though some Americans are wary of a coterie of popular emerging technologies that appear to have underdelivered compared to their hype, this moment is different. With mature-use case formation, a realistic appreciation of the limits of current-state artificial intelligence, and ruthlessly aggressive project management, the DOGE can use AI in its current state to dramatically reduce the size and complexity of the federal regulatory corpus.

Sample Use Cases

Deliberately Misleading Regulatory Issuances

Here are two recent examples of deliberate deception built into regulations regarding the implementation of the Fair Housing Act by the Federal Housing Finance Agency (FHFA):

Under the guise of advancing “equity” in the housing market, FHFA plans to foist “equitable housing finance plans” on lenders selling mortgages to the government-sponsored enterprises (GSEs) FannieMae and FreddieMac. To do so, the FHFA redefines “sustainable housing” as those which provide “reasonable opportunities to accommodate hardships by the renter or homeowner to allow continuation of the housing opportunity.”

In other words, FHFA plans to make market access for mortgage sellers contingent on the erosion of private property rights through eviction and foreclosure leniency. The FHFA also seeks to redefine “underserved communities” to include “individuals with limited mainstream credit and banking history.” It’s hard to imagine our elected representatives intended such a dramatic innovation when they passed the Fair Housing Act decades ago.

That example follows a different FHFA scheme to penalize responsible homebuyers by increasing the loan-level pricing adjustment (LLPA) fee on borrowers with high credit scores— and use these proceeds to lower the risk assessment fees on those with poor credit. Typical homebuyers with high FICOs could see $20 in higher mortgage payments—delivering more than $9200 in “savings” to those with shoddy credit.

The problem? Congress never authorized such credit redistribution schemes. The social justice warriors embedded in the agency took the “initiative” to advance the “E” in “ESG” by parasitically attaching their personal agendas to an existing framework. Another tax Congress nor the American people voted for, invented by those acting well outside the scope of legislative intent.

Bill of Rights Violations

In the modern era, injuries to the Bill of Rights come from many assailants, but violations via regulation are particularly insidious as they are generally enacted swiftly, significant in impact yet scarcely noticed by the general public.

For example, on the very last day of the Obama Administration, the Department of Health and Human Services published a rule granting the Center for Disease Control Director significant additional quarantine (e.g., detainment) authorities. The rule greatly expanded how and where CDC could ‘apprehend’ individuals (apprehend being the verb), making it so anyone could be detained anywhere in the country and not only, for example, at a port of entry. It denied Americans recourse to contest their detention for 72 hours and allowed the government to force individuals  to undergo certain medical examinations.

The rule also changed the threshold to include detention of Americans suspected to be in the

‘qualifying stages’ of having a communicable disease, which would include extremely common symptoms witnessed in colds and flus. And finally, it changed the detainment authority focus from prevention of the spread of a defined list of extremely dangerous diseases to a much more general authority to focus on preventing the spread of any dangerous communicable diseases that the CDC decided warranted the detention of American citizens.

General Pilot Approach

To eliminate these violations of our founding principles, and remove their affronts to Constitutional rights, we propose a technology-assisted approach to taming the mass of federal regulations in a way that:

• Highlights potential violations of the Bill of Rights inherent in regulation (Rights),
• Respects the original intent of the enabling laws while removing deliberately misleading and confusing regulations from the books (“Rigged Regs”), and
• Identifies conflicting regulations and unnecessary overlap (Redundancies).

These three categories can serve as the basis for three 60-day sprints, focusing first on individual “Rights,” then on “Rigged Regs,” and finally, on ridding the entire corpus of “Redundancies.”

To sufficiently and efficiently identify examples of the aforementioned, a large language model must be fed the 200,000+ pages of federal regulations, the 90,000+ pages of revisions each year, the entire history of Congressional testimony along with other recorded hearings, every Supreme Court ruling, and more.

The Process

The model must be trained on parameters from concrete political science-derived use cases to identify targetable regulations across the three identified categories. Following the identification of individual regs or other federal decisions, a written justification must be provided why the selected reg fits one of those three categories, and proposed strikethroughs and revisions should be identified, producing two immediate outputs:

And finally, a third output for Congressional use should be added:

This final category of action aims to provide the legislature tools to strengthen Congressional intent. While using Leviathan to eat itself, there must be sustaining, institutional fixes from Congress. Legislators should also consider a major “clean sweep” reform bill where the regulatory strikethroughs and loophole fill-ins are prescribed directly to each individual agency.

The pilot concept is simple: three teams are outfitted for each category (Rights, Rigged Regs, and Redundancies). Each team is given a project manager, a political scientist, and an AI expert and then spends 30-days on use-case development and perfecting the associated parameters in the AI model – twenty days of doing the work, five days of murder board and feedback from other teams, and five days to crash on fixes.

Finally, the results are generated and the final 30 days are spent ingesting, organizing, and preparing the final results for DOGE leadership, whose job it will be to build consensus and add pressure for reform adoption.

Force-Multiplication

In addition to the recommended reform sprint, along with the work publicly identified by DOGE leadership, there will be opportunities to expand the reach of these reforms.

State-level DOGEs are organically forming across the nation with leadership capable of implementing the same system and processes identified here. These efforts will scrutinize state-level regulations that encroach on the rights guaranteed by the federal Constitution. This use of technology could also identify additional weaknesses in existing law to fortify the code against future manipulation by lawfare practitioners or activist regulators.

Further, AI could be used to summarize the monstrous spending and omnibus bills Congress passes as a fait accompli. No longer can elected representatives use the excuse that their hands were forced by leadership to pass a 3,000 page law before they could understand it.

If success can be shown through identifying constructive cuts and clarifications to regulation, we can get additionally aggressive with our parameters, removing for example the word ‘equity’ in its bastardized context from all regulations (“DEI Hunter”) or challenging the AI to propose a slimmed down set of regulations (“Slasher AI”) at X% of current page volume.

Conclusion

We might, at the point of drafting, post the revisions publicly and ask for comment in a similar fashion as the public comment process for major rulemaking. This could be done for all new regulation moving forward: AI- assisted regulatory improvements could be added during the official public comment section as an extra hurdle for regulators to clear.

There is no technical fix for a brand of government that abandons its role to the degree that the U.S. Congress has by enabling and empowering the Regulatory State. Over time, the reforms made will only be as sustainable as the consensus that maintains it. However, the DOGE has a once-in-a-lifetime opportunity to lead the way for reform and serve as an enabler of meaningful legislative attempts to restore the balance of power and retake their Constitutionally-mandated role.

The new presidential administration has the potential to act as a bolt of lightning cutting through the mass of thickets and vines of regulations stifling American ingenuity and opportunity. The Department of Government Efficiency (DOGE), empowered by AI, has the potential to be the transformative brushfire needed to clear the path forward.

Endnotes

1. We might, at the point of drafting, post the revisions publicly and ask for comment in a similar fashion as the public comment process for major rulemaking. This could be done for all new regulation moving forward: AI- assisted regulatory improvements could be added during the official public comment section as an extra hurdle for regulators to clear.