Word: costly
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...face of it, the idea of cost-benefit analysis seems like a relatively uncontroversial idea. It seems reasonable to assess, for instance, whether improvements in public health are significant enough to justify the financial costs imposed on polluters to curb the emission of harmful particles into the air. Reasonable, that is, until you start to fashion formulas for deciding just how costs and benefits should be measured...
...Consider government standards for allowable amounts of arsenic in water, a topic Sunstein has written about. A standard set at 3 parts per billion will save more lives than a standard set at 10 parts per billion, but it will also cost more to achieve - a cost that will in turn be passed on to consumers in their water bills. If it can be shown that the more stringent standard would result in saving 10 lives per year, how much would society be willing to pay to achieve that? Ten million dollars? A hundred million? A billion...
...voluminous writings, Sunstein (who is not giving interviews before his confirmation hearings) has repeatedly defended the idea of a strong regulatory state. But his critics say that on a case-by-case basis he routinely comes down in favor of applying cost-benefit analysis in a way that would disallow the regulation in question. And they haven't forgotten that in 2001, Sunstein backed George W. Bush's choice of John Graham to head OIRA, though 37 Senate Democrats voted against him. Under Graham and his successor Susan Dudley, OIRA applied cost-benefit analysis stringently, with what their critics...
...Other supporters of strong regulation aren't worried about the Sunstein nomination. They expect OIRA under Sunstein to preserve cost-benefit analysis as a tool, but not to use it in such a way as to always reach the conclusion that regulation is too costly to impose. "It's true that cost-benefit analysis has been used in a very anti-regulatory way," says Michael A. Livermore, co-author, with Richard L. Revesz, of Retaking Rationality: How Cost-Benefit Analysis Can Better Protect the Enviroment and Our Health. "But cost-benefit analysis can be fixed to be more...
...House put out last month to the heads of federal agencies, asking for their ideas on how to revise both the government rulemaking process and the way OIRA reviews those rules. For one thing, it appears to mean that the new Administration will be looking for ways to apply cost-benefit analysis differently. The Institute for Policy Integrity, a progressive group headed by Livermore at New York University School of Law, has issued a list of proposed reforms that would include greater transparency for the OIRA review processes and reviews to determine the cost of deregulation or inaction...