The Trump Administration’s Attacks on Regulatory Benefits

Abstract

For the last four decades, benefit-cost analysis has been a mainstay of the U.S. federal regulatory process and, under Executive Orders in effect since 1981, such analysis must generally be used to justify significant federal regulations. While administrations of different parties have occasionally differed on the methodologies used to assess costs or benefits, these disagreements operated within the bounds of approaches that are supported by the economic and scientific literatures. In contrast, the Trump administration has been operating outside such bounds. In particular, as I discuss in this article, it has sought to justify important deregulatory measures by focusing on cost savings, but ignoring the resulting foregone benefits; placing substantial roadblocks in the way of regulatory agencies’ ability to rely on epidemiological studies; promoting discredited threshold models, under which significant air pollutants are assumed to have no adverse effects below a certain level; calling co-benefits into question; downplaying climate change damages; and counting transfer payments in inappropriate ways. I argue that these moves significantly threaten the health and safety of Americans.

Keywords: benefit-cost analysis, regulatory policy, deregulation, environmental policy, energy policy, public health and safety

JEL Classification: K, K23, K32, Q30, Q38, Q41, Q48, Q51, Q58