Regulating Cost-Benefit Analysis

Recently, the U.S. Environmental Protection Agency (EPA) issued an advance notice of proposed rulemaking (ANPRM) that asks the public to comment on the possible development of regulations for “increasing consistency and transparency in considering costs and benefits in the rulemaking process.” This framing suggests three propositions which I examine in this essay: (1) Costs and benefits should be considered in EPA’s rulemaking process; (2) Consistency and transparency in EPA’s use of cost-benefit analysis should be improved; and (3) EPA requires regulations to implement such improvements. It is difficult to argue with the first two propositions. Considering positive and negative impacts seems like an essential component of any decision-making process. Consistency and transparency seem like laudable goals too, and improvement is always possible. But what do terms such as “consider,” “consistency,” and “transparency”…

Read more detail on Recent Administrative Law posts –

This entry was posted in Administrative law and tagged , , . Bookmark the permalink.

Leave a Reply