OMB’s Draft 2013 Report to Congress on Regulatory Costs and Benefits has Limitations Open Access
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The benefits and costs of regulations, individually and in the aggregate, are notoriously hard to measure. In an attempt to measure the size and scope of regulation, the Office of Management and Budget (OMB) each year submits to Congress an accounting statement and associated report providing estimates of the total annual benefits and costs of federal regulations. According to a new GW Regulatory Studies Center comment submitted to OMB, OMB’s Draft 2013 Report to Congress on the Benefits and Costs of Federal Regulations (the Report) probably offers one of the most comprehensive estimates available on the expected benefits and net benefits (benefits minus costs) of federal regulation; but, as OMB acknowledges, it has limitations. The benefits reported both for fiscal year 2012 and over the last decade are dominated by EPA regulations that reduce fine particles (PM2.5) either directly or incidentally. OMB provides a good qualitative presentation of the many uncertainties surrounding the PM2.5 benefits, but it should go further. It should reveal to the public the effect of these uncertainties on the range of plausible benefits derived from regulations.