What's wrong with the back of the envelope? A call for simple (and timely) benefit–cost analysis
本文批评收益-成本分析在监管过程中沦为事后辩护工具,主张在早期对更多备选方案进行更简单的分析,以恢复其政策信息功能,并提出加强或放松后续审查等补救措施。
Abstract Observers across the ideological spectrum have criticized benefit–cost analysis for as long as it has been part of the rulemaking process. Still, proponents and detractors agree that analysis has morphed into a mechanism often used by agencies to justify regulatory decisions already made. We argue that a simpler analysis of more alternatives conducted earlier in the regulatory process can resuscitate it as a tool to inform policy. Recognizing that requiring a procedure does not ensure that regulators will follow it, we offer possible remedies, including strengthening or relaxing subsequent review of proposed rules, which raise the cost of circumventing the reform or lower the cost of following it.