Public Interest Comment on The Office of Management and Budget’s 2015 Draft Report to Congress on the Benefits and Costs of Federal Regulations Open Access
OMB’s 2015 Draft Report to Congress on the Benefits and Costs of Federal Regulations (the Report) provides the public valuable information both on estimates of the effects of major executive branch regulations and also on OMB’s focus and priorities. It also offers valuable recommendations that we agree “would allow for impact assessments to be more evidence-based, logically sound, and effectively communicated.” This comment focuses on several topics covered in the Report, offers suggestions for improving retrospective review as a means to improve ex ante regulatory decisions, and raises questions about the private benefits associated with energy efficiency standards and the co-benefits attributed to some air quality standards.
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