At the same time, agencies frequently complete cost-benefit analyses
where the science and economics are in some dispute.
The entire process took longest with the rules involving cost-benefit analyses
, and the economically significant rules had a combined cost of $7 billion and benefits of $11 billion.
Twenty-nine states and the District of Columbia were using cost-benefit analyses
, but less effectively or consistently.
Instead, the discounting practices in EPA's Clear Skies Initiative (106) and Nonroad Diesel-Engine Rule (107) show that questionable cost-benefit analyses
may be becoming more commonplace at EPA.
Concentrating on the development of cost-benefit analyses
can be considered a strategic opportunity in an era of growing expectations for public accountability.
Traditionally, OIRA has had fairly minimal interactions with submitting agencies as they prepare cost-benefit analyses
. But under its current administrator, John Graham, OIRA has become intimately involved in all aspects of the cost-benefit process.
Bruce Kingma (e.g., 1998) applied cost-benefit analyses
to access, ownership, and interlibrary loan service.
Executive orders extending back to 1981 direct regulatory agencies to perform cost-benefit analyses
of major regulations, (1) and to comply with the analyses when not barred by statute, as is usually the case.
Finally, also in Part III, I argue that judicial review of cost-benefit analyses
should take into account agency reputation and political proclivities as developed over a number of such analyses, as well as the political orientation of the courts in cases reviewing agency action.
Require the use of cost-benefit analyses
in both regulatory and compliance actions.
This report also offers recommendations for further cost-benefit analyses
of a distance education program.
The agency also feels that the bill would require lengthy cost-benefit analyses
rather than simple evaluations.