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Comments on Reforms to Regulatory Cost-Benefit Analysis

July 5, 2023

The Biden administration released a set of reforms on April 6, 2023, to modernize the regulatory review process and make it work more effectively in the public interest. One of the reforms, a proposed update to Circular A-4 on “Regulatory Analysis,” would improve regulatory cost-benefit analysis. Cost-benefit analysis is an outdated and anti-regulatory economic exercise that puts too much weight on the calculable costs of regulating versus the benefits of regulating that you can’t put a price on (i.e., human dignity and life, welfare, a better environment, clean air, and clean water). The Biden administration recognizes this, and the proposed update to Circular A-4 would make cost-benefit analysis work in the public interest.


Comments from CSS Members


American Lung Association

Americans for Financial Reform Education Fund

Better Markets

Center for Biological Diversity

Center for Progressive Reform

Center for Science in the Public Interest

Coalition for Sensible Safeguards

Consumer Federation of America

Earthjustice & Sierra Club

Economic Policy Institute

Farmworker Justice

Jobs to Move America

Main Street Alliance

National Employment Law Project

National Health Law Program

National Partnership for Women & Families

National Women’s Law Center

Public Citizen

Service Employees International Union

United Steelworkers