Environmental Policy under Reagan's Executive Order: The Role of Benefit-Cost Analysis

By V. Kerry Smith | Go to book overview

6
A. MYRICK FREEMAN III * ON THE TACTICS OF BENEFIT ESTIMATION UNDER EXECUTIVE ORDER 12291

THE term "tactics" refers to how to employ a given set of weapons and tools to implement some larger strategic design. I assume that the strategic design embodied in Executive Order 12291 is to introduce economic rationality into regulatory decision making by requiring the quantification and measurement of the benefits and costs of proposed regulations. The available weapons are the concepts, analytical techniques, and models that have been developed for the definition and measurement of benefits and costs. Achieving the strategic objective of economically rational regulatory decision making will require that benefit-cost analyses be done for a large number of proposed regulations in the realm of air and water pollution control, toxic substances, solid wastes, hazardous materials, and so forth. The agency in many cases will face time constraints in the form of deadlines for decisions imposed by Congress and the courts or by political considerations. And there will not be enough staff or budget to do first-class, original research on the benefits and costs of all of these regulations in the required time span. The tactical question for the agency is how best to employ the available weapons to achieve the specified objective (defensible estimates of benefits) in a particular set of circumstances while economizing on scarce agency resources.

This chapter focuses on the tactics of benefit estimation for regulatory analyses, not because cost estimation is simple and easy but because my assignment was limited to benefits. It sometimes seems to be assumed that estimating the cost of a regulation is a straightforward problem and that the

____________________
*
Professor, Bowdoin College. I would like to acknowledge the helpful comments of Wesley Magat, Ernest Manuel, and especially V. Kerry Smith on an earlier draft. Of course, I am solely responsible for any remaining errors.

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