Reforming Regulatory Impact Analysis
Winston Harrington, Lisa Heinzerling, Richard D. Morgenstern
Earthscan, 2009 - Political Science - 246 pages
Over the past decades, considerable debate has emerged surrounding the use of cost-benefit analysis (CBA) to analyze and make recommendations for environmental and safety regulations. Critics argue that CBA forces values on unquantifiable factors, that it does not adequately measure benefits across generations, and that it is not adaptable in situations of uncertainty. Proponents, on the other hand, believe that a well-done CBA provides useful, albeit imperfect, information to policymakers precisely because of the standard metrics that are applied across the analysis. Largely absent from the debate have been practical questions about how the use of CBA could be improved. Relying on the assumption that CBA will remain an important component in the regulatory process, this new work from Resources for the Future brings together experts representing both sides of the debate to analyze the use of CBA in three key case studies: the Clean Air Interstate Rule, the Clean Air Mercury Rule, and the Cooling Water Intake Structure Rule (Phase II). Each of the case studies is accompanied by critiques from both an opponent and a proponent of CBA and includes consideration of complementary analyses that could have been employed. The work's editors - two CBA supporters and one critic - conclude the report by offering concrete recommendations for improving the use of CBA, focusing on five areas: technical quality of the analyses, relevance to the agency decision-making process, transparency of the analyses, treatment of new scientific findings, and balance in both the analyses and associated processes, including the treatment of distributional consequences.
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Chapter 1 Controversies Surrounding Regulatory Impact Analysis
Chapter 2 The Clean Air Interstate Rule
Chapter 3 The Technocratic and Democratic Functions of the CAIR Regulatory Analysis
Advocacy Dressed Up as Policy Analysis
Chapter 5 The Clean Air Mercury Rule
Chapter 6 The Mathematics of Mercury
An Economists Perspective
Chapter 8 The Cooling Water Intake Structures Rule
What Does an Economist Want?
Chapter 10 Fish Tales
Chapter 11 What We Learned
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aﬀected agency’s air pollution air quality alternatives approach assessment assumptions baseline beneﬁt estimates beneﬁts and costs cair camr ria cap-and-trade changes chapter Clean Air Act coal-ﬁred compliance consider cooling water intake cost–beneﬁt analysis costs and beneﬁts CWIS decision decisionmaking deﬁned diﬀerent discount rate ecological economic economists ecosystems eﬀects eﬃciency eﬀorts eﬁts electricity emissions reductions entrainment Environmental Protection Agency epa’s expert elicitation exposure Federal Register ﬁgures ﬁnal rule ﬁnd ﬁrst ﬁsh consumption ﬁshing freshwater ﬁsh health beneﬁts Heinzerling issues MACT mercury emissions Mercury Rule methylmercury million monetized nomic oﬀered Oﬃce options ozone percent plants policy analysis population quantiﬁed reference dose reﬂect regulation regulatory impact analysis revealed preference risk Riverkeeper rulemaking scientiﬁc Section signiﬁcant sources species speciﬁc standard studies supra note thecair theria tion Trasande U.S. Environmental Protection uncertainty utilities valuation Water Intake Structures welfare economics