Cross-posted from Legal Planet.
Of course, not everyone agrees that CBA is good in the first place. It remains anathema to many environmentalists. My own view is that it can be a useful tool so long as its limitations are clearly understood.
But just because something is good doesn’t mean that more is better. My grandmother’s view was that if a recipe called for two eggs and one tablespoon of butter, four eggs and two tablespoons would produce an even tastier result — a theory that did not always prove valid. Sometimes, you really just need two eggs!
The same is true of cost-benefit analysis. There are a number of proposals in Congress to expand cost-benefit analysis to cover many additional regulations. A very thoughtful analysis from the Congressional Research Service points out that these proposals may not themselves pass a cost-benefit analysis:
Although there is no “typical” cost-benefit analysis (just as there is no “typical” rule), the cost of conducting many individual regulatory analyses has been in the hundreds of thousandsof dollars. If more agencies are required to prepare more detailed analyses for more rules, it is unclear how the agencies will be able to do so without more resources. As noted earlier in this report, if agencies are required to prepare cost-benefit analyses for rules that are not expected to be controversial and are unlikely to be improved as a result of the analysis, that type of requirement itself may not pass a cost-benefit test.
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Daniel Farber | October 26, 2011
Cross-posted from Legal Planet. Of course, not everyone agrees that CBA is good in the first place. It remains anathema to many environmentalists. My own view is that it can be a useful tool so long as its limitations are clearly understood. But just because something is good doesn’t mean that more is better. My […]
Ben Somberg | October 25, 2011
If you were an industry lobbyist working to block new health and safety protections, what would make your job easier? How about if the law said that you could flood an agency with alternate regulatory proposals, and the agency wouldn’t just need to consider each one, but in fact conduct a full cost-benefit analysis on […]
Yee Huang | October 21, 2011
Maryland has a long-held reputation as a regional and national leader in environmental protection. But in some areas, especially enforcement, that reputation warrants scrutiny, says a CPR briefing paper released today. For example, the Maryland Department of the Environment (MDE) cannot by law assess fees for issuing and administering permits for municipalities for water pollution, […]
Yee Huang | October 20, 2011
It’s no secret that past efforts to restore the Chesapeake Bay have suffered from a lack of accountability. And so as the EPA, the Chesapeake Bay states, and the District of Columbia engage in their current effort to restore the health and water quality of the Bay, getting accountability right is extremely important. This theme […]
Rena Steinzor | October 19, 2011
In perhaps the most profoundly embarrassing development yet for the U.S. government’s star-crossed efforts to police offshore drilling, the Interior Department’s Bureau of Safety and Environmental Enforcement announced last week that it was asking BP, Transocean, and Halliburton to pay a total of up to $45.7 million in fines for 15 violations arising out of […]
Rena Steinzor | October 18, 2011
Proving the old adage that you must be careful what you wish for, conservative officials in 25 states have done their best to hoist the Obama Administration on its own petard by running off to court to oppose the EPA rule that would curb toxic emissions from power plants. They argue, among other things, that the […]
Rena Steinzor | October 17, 2011
The residents of Kingston, Tennessee had no inkling that the Christmas of 2008 would be any different than another year. In the wee morning hours three days before the holiday, an earthen dam holding back a 40-acre surface impoundment at a Tennessee Valley Authority (TVA) power plant burst, releasing 1 billion gallons of inky coal ash […]
Rena Steinzor | October 14, 2011
This post was co-authored by CPR President Rena Steinzor and CPR Policy Analyst Aimee Simpson. In what at first glance seemed to be a startlingly uncharacteristic move, the American Chemistry Council (ACC) has petitioned the Food and Drug Administration (FDA) to update and strengthen its food additive regulation that sets out the approved uses for polycarbonate resins. […]
Lena Pons | October 11, 2011
EPA’s chemical management efforts have been under attack on every front. Chemical safety was one of Lisa Jackson’s priorities from her first day as EPA administrator. But during her tenure, efforts to improve chemicals policy at the agency have been met with fierce resistance. One recent attack was on EPA’s efforts to identify priority chemicals for risk assessment […]