Join us.
We’re working to create a just society and preserve a healthy environment for future generations. Donate today to help.
Filter by Issue
Filter by Topic
Filter by Content Type
Filter by Author
Showing 1 results
Sort by Date: Newest First Date: Oldest First
Attorney / Equal Justice Works Fellow
Jorge Roman-Romero, Melissa Lutrell | October 11, 2021
Cost-benefit analysis (CBA) is inherently classist, racist, and ableist. Since these are foundational problems with CBA, and are not simply issues with its implementation, they can never be fixed by mere methodological improvements. Instead, the ongoing modernization of centralized regulatory analyses must focus on "moving beyond" CBA, and not on fixing it or improving it. Thus, in implementing President Biden's memorandum on Modernizing Regulatory Review (the Biden Memorandum), the Office of Management and Budget (OMB) should make explicit that regulatory review no longer requires CBA, even—as will be true in the typical case—when regulatory review does demand economic analysis as part of a holistic, multi-factor regulatory impact analysis.