On September 21, 2023, the Biden administration outlined plans to expand federal agencies’ consideration of the social cost of carbon—a metric for the economic cost of each additional ton of carbon dioxide emitted to the atmosphere. This announcement tilts the balance of cost-benefit analyses in favor of activities that reduce greenhouse gas emissions, and it could have widespread effects for entities that receive federal funding or are subject to federal regulation.… More
Tag Archives: OMB
OMB Proposes to Revise Circular A-4; This is Not Trivial
On Thursday, the Office of Management and Budget released proposed revisions to “Circular A-4”. It also released a separate preamble, explaining its thinking and asking for comment on certain identified issues.
Circular A-4 is almost certainly the most important document that most people have never heard of, since it governs how federal agencies conduct cost-benefit analysis of potential federal actions. The proposal is not a massive rewrite of Circular A-4,… More
Red States Still Have Nothing to Complain About Regarding the Social Cost of Carbon
Today, the 5th Circuit Court of Appeals dismissed for lack of standing claims by a number of states challenging the Biden Administration’s Interim Estimates of the Social Cost of Carbon. The Court had telegraphed this outcome last spring when it vacated a District Court injunction against use of the Interim Estimates, noting that:
The Government Defendants are likely to succeed on the merits because the Plaintiff States lack standing.… More
OMB Reports that the Benefits of Regulation Exceed the Costs. The President Knows that Can’t Be Right
Late last month, to no fanfare whatsoever, OMB released its annual report on the costs and benefits of federal regulations. There’s a reason that the Administration did not give the report any attention. The report states that, for the 10-year period ending September 30, 2016, the benefits of major Federal regulations ranged from $219 billion and $695 billion, while the costs ranged between $59 billion and $88 billion. … More
EPA Compromises (Again) on the Boiler Rule: Will It Get Any Credit?
On Friday, EPA proposed certain revisions to its rule on air emissions from boilers and commercial and industrial solid waste incinerators (CISWI). As with other major rules under development in the past few years, EPA has taken fairly substantial steps to limit the reach of the rule to those boilers and CISWI that are of greatest concern. Without engaging in formal cost-effectiveness analysis, EPA has sought to make the rule as cost-effective as possible.… More
Is It Possible to Be Progressive and Effective at the Same Time?
President Obama continues to surprise some of his progressive backers. This time, it was his selection of Cass Sunstein to head the Office of Information and Regulatory Affairs at OMB. The Center for Progressive Reform called Sunstein’s views “conservative” and similar to those of the Bush administration.
How did the appointment of a known progressive annoy the progressives? Sunstein’s sin is the support of the use of cost-benefit analysis in regulatory decision-making. … More