Policy Integrity submitted comments on draft recommendations proposed by the ACUS (Administrative Conference of the United States) Committee on Regulation on the use of cost-benefit analysis at independent regulatory agencies.
Our suggested changes to the recommendations include encouraging broader application of cost-benefit analysis to significant rulemakings by independent regulatory agencies and not limiting the scope of analysis to only monetized effects. Our comments also urge the committee to recommend establishing a peer review and public comment process for the development of written economic analysis guidance and having agencies publish and summarize their analyses in time to allow for meaningful public comment.