Joint Letter to EPA Administrator Andrew Wheeler re Cost-Benefit Analysis Proposal from CPR Member Scholars. Nineteen CPR Member Scholars joined in comments calling on Wheeler to withdraw an Advance Notice of Public Rulemaking on cost-benefit analysis. August 13, 2018.
Is Cost-Benefit Analysis Neutral? An Analysis of the Bush Administration's Approach to Environmental, Health, and Safety Protection, by David M. Driesen, White Paper 507, June 2005.
Robert R.M. Verchick's February 25, 2004, testimony to the Subcommittee on Energy Policy, Natural Resources and Regulatory Affairs on OMB's 2004 Draft report to Congress on the costs and benefits of regulation
David Driesen's July 6, 2016, testimony before the House Judiciary Committee's Subcommittee on Regulatory Reform, Commercial and Antitrust Law re OIRA's role and cost-benefit analysis.
CPR's James Goodwin examines the implications of EPA Administrator Andrew Wheeler's May 13, 2019, memo to the agency’s Assistant Administrators. In the memo, Wheeler announced the agency was partially backtracking on its pending rulemaking to overhaul how it would perform cost-benefit analyses for its future rules.
As absurd as it sounds to express the value of human lives, the environment, or conservation in dollars and cents, cost-benefit analysis requires it. Embraced by a growing number of politicians, economic analysts and conservative pundits as the most reasonable way to make decisions on proposed regulations, cost-benefit analysis attempts to convert all relevant factors into monetary terms. Written by economist CPR Member Scholars Frank Ackerman, economist at the Global Development and Environment Institute at Tufts University, and Lisa Heinzerling, professor of law at the Georgetown University Law Center, Priceless is a combative, no-holds-barred debunking of cost-benefit analysis and the derelict logic used to defend it.
The term, “Cost-benefit analysis,” is used so frequently that we rarely stop to think about it. But relying on it can lead to some dubious conclusions, as Frank Ackerman points out in this eye-opening book. Inventing dollar values for human life and health, endangered species, and fragile ecosystems does not guide us to better policies, he maintains. Cost-benefit analysis, as practiced today, could have led to damming the Grand Canyon for hydroelectric power, leaving lead in gasoline, and other absurd and harmful decisions. In Poisoned for Pennies, Ackerman uses clear, understandable language to describe an alternative, precautionary approach to making decisions under uncertainty.
With the calendar running out of pages on Donald Trump's first term, EPA is pushing hard to adopt its "benefits-busting" rule, hoping to defeat efforts to implement the Clear Air Act's protections by tilting the cost-benefit analysis process ever more to industry's favor. James Goodwin offers an analysis of the effort.
In James Goodwin's article on the workings of cost-benefit analysis, he writes, "In cost-benefit analysis, small government ideologues and corporate interests have fashioned a powerful weapon for attacking regulatory safeguards and undercutting landmark laws. Much of that power derives from the elaborate mythology that its proponents have woven around the methodology over the course of the past four decades.... For its supporters, the real genius of the cost-benefit analysis myth is that it distracts from the fact that the methodology is in fact neither neutral nor objective."