“When all else fails, blame Bush.” This seems to be the operating principle of the current Administration.

Case in point: At a conference on innovation earlier this week, Cass Sunstein—the head of OMB’s regulatory review office—tried to deflect criticism that the Obama Administration was responsible for a “tsunami” of regulation sweeping over the American economy. His defense: Bush was worse:

“The annual cost of regulations has not increased during the Obama administration,” Sunstein said. “In its last two years, executive agencies in the Bush administration proposed far higher regulatory costs than did those agencies in the Obama administration in our first two years.”

Sunstein is wrong.

Now, George W. Bush was no paragon of regulatory restraint, having imposed over $60 billion in new regulatory costs during his two terms in office. And the red tape machine was particularly active during the final two years, churning out close to $20 billion in new burdens during that time.

Not a record to be proud of, to be sure. But it pales in comparison to President Obama’s frenetic regulatory pace. In just two years, Obama regulators have imposed close to $40 billion in new costs. It took Bush some six years to reach that level. Obama has done it in two.

You don’t have to look far to see the reasons for these stark numbers—health care regulations, new bank regulations, Internet regulations, environment regulations have all been pressed forward relentlessly. The tsunami is indeed real.

Sunstein, the Administration’s point man on regulation, certainly knows this. And he may want to defend this rising tide. But he can’t stand on the shore and deny it is happening or deflect blame to the President’s predecessors. This time, “Blame the Other Guy” is simply not an option.