Comment on the Federal Trade Commission’s Strategic Plan for 2003-2008

Robert Hahn,
Robert Hahn
Robert Hahn Director of Economics - Smith School of Enterprise and the Environment at the University of Oxford, Former Brookings Expert
Robert E. Litan, and Roger G. Noll

July 15, 2003

Executive Summary

This comment assesses some important economic consequences of the Federal Trade Commission’s approach to strategic planning. We recommend that the FTC evaluate cases based on their impact on consumer benefits, and that the FTC develop a formal “Investigation Impact Statement” for each case to better manage resource allocation within the agency.


We are submitting this comment for the Federal Trade Commission (FTC) in response to the publication of the Federal Trade Commission Strategic Plan: Fiscal Years 2003-2008.

Although our organizations are not listed as among the “stakeholders” for this comment, as scholarly research institutions that engage in extensive research on antitrust and economic policy analysis, we have a strong interest in promoting efficient enforcement of antitrust laws and the development of useful performance measures for antitrust enforcement agencies. The American Enterprise Institute-Brookings Joint Center for Regulatory Studies is a research center that is devoted to improving the efficiency of regulatory policy and, in particular, working with government agencies to improve the use of cost-benefit analysis and other economics research tools in regulatory policy. The Stanford Institute for Economic Policy Research undertakes research on economic policy, including antitrust.