CPR's Comments on OMB's Draft Report on Costs and Benefits of Regulations: Why More of the Same?
Cass Sunstein had barely begun settling in to his new position as Administrator of OMB’s Office of Regulatory Affairs (OIRA) in September, when OIRA released a draft of OMB’s 2009 Report to Congress on the Benefits and Costs of Federal Regulations. Today marks the deadline for submitting comments to OMB on the draft, and I joined CPR President Rena Steinzor and Policy Analyst James Goodwin in submitting comments.
We read this year’s report with interest, curious to see how the new administration would approach this annual ritual. While OIRA has in the past been a nerve-center of anti-regulatory ideology and the annual report a ritualized hymn to the virtues of cost-benefit analysis, we hoped Obama’s OIRA would use the annual report as an opportunity to fundamentally re-envision its mission – to perhaps re-invent itself as a resource providing positive and constructive assistance to the embattled, de-funded and demoralized federal agencies charged with protecting our health and environment.
Overall, we were disappointed. While this year’s report sanitized some of the more blatantly ideological material that had become a staple of past reports, the basic form and content of the report remain unchanged. It continues to waste inordinate …
Imagine if the end of the world were coming and everyone was just too polite to talk about it. That’s been the eerie feeling I've gotten over the past eight months listening to the President talk about energy policy. Not wanting to be a downer, he couches his energy talk in positive spin: We’re going to invest in the new clean green economy, create jobs, sell American ingenuity and know-how around the world, and reduce our dependence on foreign oil. Missing is any mention of the reason we’re going to all the trouble of undertaking a vast and expensive transformation of our well-entrenched carbon economy in the first place: all those coal plants and gas guzzling cars threaten to end life as we know it on this planet (not my words – NASA climate scientist Jim Hansen’s). Just a minor detail – but one …
The Supreme Court today upheld a decision from the Bush administration's EPA that was good for industry and bad for the environmental health of our rivers and estuaries (my brief press statement on the case, Entergy v. EPA, is here; the court's decision is here). But the majority opinion by Justice Scalia was written narrowly in a way that gives the Obama administration the leeway to approach these kinds of decisions in a more productive way. I'm hopeful they will seize that opportunity and avoid using cost-benefit analysis to set environmental standards in this case and beyond. The profound environmental challenges we face in the 21st century demand a different approach. If the EPA confronts the climate crisis with methodology that requires putting a dollar figure on every bird, bee and ecosystem that faces devastation from a warming globe, they’ll be paralyzed. This …
President-elect Obama has a lot on his plate. No doubt the financial crisis is foremost on his mind. But as he ticked off his to-do list in his victory speech Tuesday night, I heard our new president mention another global crisis as well: “a planet in peril.” The worst economic crisis since the great depression may be the crisis that’s getting all the attention and money thrown its way lately, but the other global crisis—the inexorable and ominous warming of the planet—has the capacity to wreak a far more profound and irreversible havoc in the long term.
I can go through the usual ominous litany—rising seas, drought, crop failure, tropical diseases creeping northward. But to understand the depth and magnitude of the threats we face from the climate crisis, consider that, if current trends continue, every last spot on earth—and that means …
