By Robert W. Hahn
This monograph addresses the analytical issues raised through critics of the industrial research of law.
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Extra info for In Defense of The Economic Analysis of Regulation
170 The critics tend to miss an important implication related to the argument, that not all important costs are included. The argument is simple: If important costs are excluded, then it is virtually impossible to argue that there is a clear antiregulatory bias in the kinds of cost and cost-benefit analyses that have been considered here. 172 Exclusion of Cost Savings. 174 The issue of cost savings is complicated. 175 A good illustration is energy savings associated with a particular technology.
Thus, two somewhat different methodologies arrive at similar findings about which regulations are likely to pass a cost-benefit test. This scorecard leads me to the conclusion that the OMB numbers are plausible, given the methodology that the agency employed. This discussion reveals that scorecards related to assessing the costs and benefits of regulations can do a lot more than Parker suggests. They are quite versatile instruments that have offered important insights. 221 In my early research on RIAs, I discovered some very simple problems with the presentation of information.
The OMB takes the agency’s analyses of the expected economic impacts of regulations as given, monetizes benefits where it can, and does not revisit the assumptions or numbers in the agency’s analyses. 219 Using the agency’s numbers, the OMB reports on the aggregate net benefits of regulation, but it does not report on the number of regulations that are likely to pass a cost-benefit test by category. I believe information on the number of regulations that pass a cost-benefit test is potentially useful to decision makers.
In Defense of The Economic Analysis of Regulation by Robert W. Hahn