RSP applauds the efforts by OMB and the respective agencies to assess regulatory costs and benefits. However, the data as presented in the draft report to Congress are inconsistent and often fragmentary. In addition, the estimates are not made in accordance with the Administration's Best Practices. In order for the Legislative and Executive branches to understand better the effects of regulations on society, a sober and rigorous analysis of regulatory costs and benefits is vital. We therefore urge OMB to continue this process and make improvements in four key areas:
- OMB should report best (i.e., expected value) estimates of aggregate benefits and costs, in addition to ranges.
- The report should present OMB's objective estimates of the benefits and costs of individual regulatory actions.
- OMB should continue to build its regulation-by-regulation database of the costs and benefits of regulations issued before April 1995. When OMB must rely on other aggregate estimates of benefits and costs, such as those in EPA's Section 812 retrospective report, it should adjust them, as necessary, to correct for identified problems.
- OMB should identify in a concise but comprehensive manner variations in agency methodologies used to estimate benefits and costs of individual regulations. It should present a "report card" for agency analyses that highlights their strengths and weaknesses.