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Letter to the OMB re: midnight regulations
Agencies are infamous for pushing through regulations on the eve of an Administration’s exit. In May 2008, the Bush Administration issued a bulletin mandating that no regulations were to be proposed after June 1, 2008, except in extraordinary circumstances.
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Comments on New York’s GORR cost-benefit analysis guidelines
For the first time in a dozen years, the New York State Governor’s Office of Regulatory Reform (GORR) has begun to update its guidelines for how state agencies should conduct cost-benefit analysis. This update seeks to transform what had been an infrequently and inconsistently used technique in New York into a more standard and powerful decisionmaking tool.
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Retaking Rationality
How Cost-Benefit Analysis Can Better Protect the Environment and Our Health
In Retaking Rationality: How Cost-Benefit Analysis Can Better Protect the Environment and Our Health (Oxford University Press, 2008), Dean Richard L. Revesz and Michael A. Livermore argue for a more rational approach to cost-benefit analysis and regulation. They show how traditional cost-benefit analysis tends to overestimate costs and underestimate benefits, leading to less-than-optimal levels of regulation.