In “Nonquantifiable,” the 2013 Jorde Lecture at UC Berkeley, Professor Cass Sunstein explores the steps that agencies should take in doing breakeven analysis, which determines how high nonquantifiable benefits of a regulation would have to be for the benefits to justify the costs. OMB Circular A-4 requires the use of breakeven analysis when estimates of particular benefits cannot be determined. In his Comment on the Lecture, Revesz argues that breakeven analysis is at best second-best technique. The first-best approach is to actually quantify the benefit. Revesz notes that a great deal of progress has been made on efforts to quantify previously unquantifiable benefits for cost-benefit analysis and that governmental intervention is necessary to this endeavor. Revesz acknowledges that bringing greater attention to breakeven analysis is salutary, but cautions that a focus on the technique must be balanced against the possible negative effects such efforts might have on the resources and attention the government devotes to quantification.
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