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Comments on Regulatory Impacts Draft Report to Congress

The Office of Management and Budget’s (OMB’s) annual reports to Congress not only compile all the significant benefits and costs of federal regulations, but they also offer federal agencies and academics an up-to-date summary of the literature on key practices in regulatory impact analysis. As such, OMB’s annual reports should reflect the most comprehensive syntheses of the legal and economic literature on these analytical practices.

Our comments on OMB’s draft report for 2017 propose two additions to its summaries of the literature on job impact analysis and on co-benefits analysis. First, OMB should add information on the economy-wide modeling of regulatory impacts provided by Environmental Protection Agency’s Science Advisory Board, which raises concerns with the use of these models to estimate employment impacts. Second, OMB should include the conclusions of a recent paper by Richard Revesz, “Environmental Standards, Thresholds, and the Next Battleground of Climate Change Regulations which encourages counting the “co-benefits” of particulate matter reductions that come from climate regulation.