 OMB and Cost-Benefit AnalysisOver-reliance on a Flawed Approach
CPR’s Member Scholars have written extensively on the many methodological and conceptual deficiencies built into the way cost-benefit analysis is applied to regulations aimed at protecting the health, safety and the environment. The distortion and over-reliance on cost-benefit analysis is just one of several problems with the way the White House Office of Management and Budget (OMB) exercises its control over the federal regulatory process.
CPR's commentary on OMB and cost-benefit analysis includes:
- A CPR Perspective. Read CPR's Perspective on Cost Benefit Analysis by Frank Ackerman and Lisa Heinzerling and David Driesen's CPR Perspective on the Feasibility Principle. Read related CPR Perspectives on Data Quality, Federal Advisory Committee Act, OMB Annual Report & 'Hit List', the Precautionary Principle and Statutory Design.
- Poisoned for Pennies: The Book. Read Frank Ackerman's 2008 book, Poisoned for Pennies, on the failings of cost-benefit analysis in the regulatory process.
- CPR White Paper: Is C-B Neutral?. Read David Driesen's June 2005 White Paper, "Is Cost-Benefit Analysis Neutral? An Analysis of the Bush Administration's Approach to Environmental, Health, and Safety Protection."
- Testimony. Read Sidney Shapiro's April 12, 2005 congressional testimony on OMB's regulatory "hit list."
- CPR White Paper: An Alternative. Advocates of cost-benefit analysis frequently claim that rational regulation requires CBA and suggest that all other ways of setting standards are irrational. CPR believes that several competing approaches to standard-setting are rational, and ethically superior to CBA. CPR’s rationality series explains why these alternatives offer rational approaches to limiting pollution. Read the first in this series of white papers, David Driesen's "Feasibility Principle."
- Center for American Progress Op-Ed. Read "Responsible Regulation Sabotaged," by Sidney A. Shapiro and Thomas O. McGarity, published September 22, 2004 on the Center for American Progress website.
- CPR White Paper: What Past Decisions Reveal About the Flaws of Cost-Benefit Analysis. Read Lisa Heinzerling and Frank Ackerman's "Applying Cost-Benefit Analysis to Past Decisions: Was Protecting the Environment Ever a Good Idea?," with Rachel Massey. A CPR White Paper, published July 2004.
- LA Times and San Jose M-N Op-Eds. Read Frank Ackerman and Lisa Heinzerling's April 26, 2004 op-ed in the San Jose Mercury News on the Bush Administration's use of cost-benefit analysis to foil California environmental laws. Or read Lisa Heinzerling and Frank Ackerman's February 25, 2004 Op-Ed in the LA Times on the failings of cost-benefit analysis.
- Conference Transcript. Listen to Ackerman and Heinzerling discuss cost-benefit analysis with Jim Tozzi of the Center for Regulatory Effectiveness, and former OMB official Sally Katzen, at a forum sponsored by the Center for American Progress on February 25, 2004. (This link takes you to the website of the Center for American Progress.)
- Comments on Cooling Water Intake Standards. Read August 2002 comments from a number of CPR Member Scholars on EPA's proposal to incorporate Cost-Benefit Principles into the Technology Based Standards for Cooling Water Intake Structures.
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