Professor Sunstein is to be complimented for his informed and steadfast support for benefit-cost analysis notwithstanding opposition from a number of groups.
The application of benefit-cost analysis to regulations traces its conceptual development to the Johnson Administration and its initial application to rulemakings to the Nixon Administration.
Also see this article in the Journal of Benefit-Cost Analysis, this view on relevant Executive Orders from a foreign scholar and this note on OMB and benefit-cost analysis.