Joint Letter to EPA Administrator Andrew Wheeler re Cost-Benefit Analysis Proposal from CPR Member Scholars. Nineteen CPR Member Scholars joined in comments calling on Wheeler to withdraw an Advance Notice of Public Rulemaking on cost-benefit analysis. August 13, 2018.

How Trump Officials Abuse Cost-Benefit Analysis to Attack Regulations, op-ed by Dan Farber

EPA's backward accounting protects polluters, not the people, op-ed by Amy Sinden and James Goodwin

Balancing Lives Against Lucre, op-ed by Frank Ackerman and Lisa Heinzerling

Applying Cost Benefit Analysis to Past Decisions, by Frank Ackerman, Lisa Heinzerling, and Rachel Massey. White Paper 401, July 2004.

Doubting Daubert, by Lisa Heinzerling, White Paper 511, August 2005.

Bush's Cost-Benefit View Carries a High Price, op-ed by Frank Ackerman and Lisa Heinzerling

Is Cost-Benefit Analysis Neutral? An Analysis of the Bush Administration's Approach to Environmental, Health, and Safety Protection, by David M. Driesen, White Paper 507, June 2005.

Robert R.M. Verchick's February 25, 2004, testimony to the Subcommittee on Energy Policy, Natural Resources and Regulatory Affairs on OMB's 2004 Draft report to Congress on the costs and benefits of regulation

The Feasibility Principle, by David Driesen, first in a series of papers outline alternatives to cost-benefit analysis. White Paper 407, December 2004.

The Cost-Benefit Dodge: Used to Dilute Regulation, op-ed by Catherine O'Neill and Amy Sinden

A Return to Common Sense: Protecting Health, Safety, and the Environment Through Pragmatic Regulatory Impact Analysis, CPR White Paper 909

Regulatory Dysfunction: How Insufficient Resources, Outdated Laws, and Political Interference Cripple the 'Protector Agencies,' CPR White Paper 906

Comments to the White House Office of Information and Regulatory Affairs on 2009 OMB Report to Congress re the costs and benefits of regulation, by Amy Sinden, Rena Steinzor and James Goodwin

Comments from CPR Member Scholars and staff on 2010 OMB Report to Congress on Costs and Benefits of Regulation

David Driesen's July 6, 2016, testimony before the House Judiciary Committee's Subcommittee on Regulatory Reform, Commercial and Antitrust Law re OIRA's role and cost-benefit analysis.

CPR's James Goodwin examines the implications of EPA Administrator Andrew Wheeler's May 13, 2019, memo to the agency’s Assistant Administrators. In the memo, Wheeler announced the agency was partially backtracking on its pending rulemaking to overhaul how it would perform cost-benefit analyses for its future rules.

CPR's June 27, 2018 webinar on EPA's benefits-busting proposal to slant EPA's cost-benefit analysis methods even further in favor of pollution, featuring CPR's Amy Sinden and James Goodwin.

As absurd as it sounds to express the value of human lives, the environment, or conservation in dollars and cents, cost-benefit analysis requires it. Embraced by a growing number of politicians, economic analysts and conservative pundits as the most reasonable way to make decisions on proposed regulations, cost-benefit analysis attempts to convert all relevant factors into monetary terms. Written by economist CPR Member Scholars Frank Ackerman, economist at the Global Development and Environment Institute at Tufts University, and Lisa Heinzerling, professor of law at the Georgetown University Law Center, Priceless is a combative, no-holds-barred debunking of cost-benefit analysis and the derelict logic used to defend it.

The term, “Cost-benefit analysis,” is used so frequently that we rarely stop to think about it. But relying on it can lead to some dubious conclusions, as Frank Ackerman points out in this eye-opening book. Inventing dollar values for human life and health, endangered species, and fragile ecosystems does not guide us to better policies, he maintains. Cost-benefit analysis, as practiced today, could have led to damming the Grand Canyon for hydroelectric power, leaving lead in gasoline, and other absurd and harmful decisions. In Poisoned for Pennies, Ackerman uses clear, understandable language to describe an alternative, precautionary approach to making decisions under uncertainty.

With the calendar running out of pages on Donald Trump's first term, EPA is pushing hard to adopt its "benefits-busting" rule, hoping to defeat efforts to implement the Clear Air Act's protections by tilting the cost-benefit analysis process ever more to industry's favor. James Goodwin offers an analysis of the effort.

On August 3, 2020, several CPR Member Scholars and staff joined in submitting comments on the Environmental Protection Agency’s (EPA) “benefits-busting” proposal, designed to drastically overhaul how the agency performs cost-benefit analysis on its biggest Clean Air Act rules. The proposal is a thinly veiled effort to rig the results of those analyses – more so than they already are – to make it harder to issue appropriately strong safeguards, thereby sabotaging the effective and timely implementation of the Clean Air Act.

Led by the Center for Progressive Reform, a number of public interest organizations submitted comments to the EPA on August 3, 2020, opposing the agency's efforts to rewrite its cost-benefit analysis methodology as it applies to the Clean Air Act. The "benefits-busting" proposal would tilt the playing field even further than it already is toward industry's profit-making interests at the expense of Americans' health.

In James Goodwin's article on the workings of cost-benefit analysis, he writes, "In cost-benefit analysis, small government ideologues and corporate interests have fashioned a powerful weapon for attacking regulatory safeguards and undercutting landmark laws. Much of that power derives from the elaborate mythology that its proponents have woven around the methodology over the course of the past four decades.... For its supporters, the real genius of the cost-benefit analysis myth is that it distracts from the fact that the methodology is in fact neither neutral nor objective."

Rebuilding our regulatory system is a key though often overlooked imperative for the broader progressive movement as it works to achieve its vision of a more equitable and just society. The rebuilding will ultimately require legislation, but considerable progress can be achieved through unilateral actions by the president, including executive orders. Building on its previous work to advance the cause of progressive regulatory reform, CPR is compiling on this page resources and materials that should inform the development of new executive orders for progressive regulation that would replace Executive Order 12866 and any subsequent executive orders and memoranda built on its framework.

In this web article, James Goodwin describes the ways that cost-benefit analysis as used in the regulatory process perpetuates racial injustice and reinforces race-based inequities.

In his latest article on the need for regulatory reform, James Goodwin writes that overhauling cost-benefit analysis is crucial to restoring scientific integrity. He writes, "blind-to-reality calculations are sadly commonplace in the practice of the unique form of cost-benefit analysis that now dominates in the U.S. regulatory system. Defenders of the approach claim that it makes regulatory decision-making more 'rational' and insulates the process against improper political or subjective considerations. Yet ... the methodological techniques this form of cost-benefit analysis uses can be arbitrary, unscientific, ethically dubious, and at times even absurd."