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Public Comments to the Administrative Conference of the United States

Today, Policy Integrity submitted public comments to the Administrative Conference of the United States regarding their Committee on Regulation’s proposed recommendations for review of regulatory analysis requirements.

Our suggestions focus on the legally and economically appropriate scope of cost-benefit analysis, as well as other ways to improve the efficiency of regulatory analysis requirements.

We have two changes we would like to see made. The first is to revise the language of Recommendation Eight to better reflect the types of rules that should be subject to cost-benefit analysis, as required by law and justified by best economic practices.

The second is to explore additional opportunities to rationalize the practice of regulatory analysis. For example, the Committee could develop guidance on how agencies can use ex‐post, retrospective analysis to improve their ex‐ante analytical estimates of costs and benefits.