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Comments on ACUS Committee on Regulation Recommendations on CBA

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.