Vintage OIRA…
OIRA Discussion Forum
The Bottom Line: (1) An analysis conducted pursuant to OMB Circular A-4 should include a disclosure of the “conventional ” B/C ratio and (2) A demonstration of positive net benefits, however defined, should be a necessary but not a sufficient condition for the adoption of a proposed rule until which time the said rule is included in a regulatory budget. A regulatory budget compels the disclosure of the opportunity cost of a decision rule. See the Opportunity Cost of Neglect in Public Policy and here. In addition there is ample evidence to suggest that decisions made pursuant to bounded institutions, such as the regulatory budget, yield superior results relative to unbounded institutions. [ Jim Tozzi, Office of Information and Regulatory Affairs: Past, Present, and Future, 11 J. BENEFIT COST-ANALYSIS 1, 24–37 (2020); Yair Listokin, Bounded Institutions, 124 YALE L.J. 336, 367 (2014) ]
See Vintage OIRA… for a highlight of four observations which describe the manifestation of centralized regulatory review.
Serious consideration should be given to making sequential revisions to OMB Circular A-4, beginning with one limited to income distribution.[08 22 2023]
A Related Link: Opportunity Cost Neglect in Public Policy
A Forum for Venting Key Submissions to OIRA: Analytical and Subject-Limited Comments Welcome Here
Out of Sight, out of Mind: How Opportunity Cost Neglect Undermines Democracy
March 25, 2021
March 17, 2021
