This paper critically reviews the draft of the Office of Management and Budget’s fourth report on the benefits and costs of federal regulation. The purpose of this analysis is to offer constructive recommendations for improving that report.
We conclude that that this draft report represents a significant departure from previous reports. It provides very little in the way of new quantitative information. Instead, it solicits input on improving the report and the regulatory process. We have provided such input for the previous reports and believe that it has largely been ignored. We provide such input for this report in hopes that the regulatory process will become more transparent and that regulators and lawmakers will be held more accountable for regulations.
This draft report has failed to provide a reasonable analysis of newly proposed regulations. At a minimum, the Office of Management and Budget should provide a cogent analysis of these regulations.
We recommend that OMB make greater use of its in- house expertise to refine estimates of benefits and costs. We also argue that OMB should focus on the incremental impact of regulations rather than aggregate impacts. Finally, we believe that Congress should give OMB additional authority to enforce its guidelines on standardizing measures of costs and benefits.