Rulemaking:

Report to Congress on the Costs and Benefits of Federal Regulations

Stated Purpose:

Report on the costs and benefits of federal regulation, including estimates of the costs and benefits of significant rules, estimates of indirect impacts, and recommendations for reform.

Summary of RSP Comment:

OMB has made an admirable attempt at compiling the costs and benefits of federal regulation, and this second annual report reflects several improvements over its 1997 report. However, there are still several key areas in which OMB could improve its future reports:

1. OMB should report best (i.e., expected value) estimates of aggregate benefits and costs.
2. OMB should adjust its aggregate estimates to correct for identified problems in the EPA Section 812 retrospective, on which its cost and benefit estimates are based.
3. OMB should identify in a concise but comprehensive manner variations in agency methodologies used to estimate benefits and costs of individual regulations.
4. It should present a "report card" for agency analyses that highlights their strengths and weaknesses.
5. OMB should present objective estimates of the benefits and costs of individual rules.
6. OMB should present information on the effects of federal regulation on state and local entities.
7. OMB should report aggregate costs and benefits in useful ways, e.g., by household, by type of regulation, by growth in burden, etc.
8. OMB should expand its coverage of aggregate impacts to include all costs related to paperwork requirements.
9. Agencies should follow the OMB's Best Practices when preparing regulatory analyses under Executive Order 12866.