Industrial waste reduction provides an opportunity to improve environmental quality while reducing industrial costs. Significant evidence exists that firms can realize economic benefits while practicing waste reduction techniques, yet opportunities are being missed by firms due to internal...

As EPA rolls out controversial regulations on power plant emissions of greenhouse gases, a vocal group of legislators, industry groups, and legal and economic scholars are crying foul, arguing that EPA didn't “follow the rules” when it conducted its cost-benefit analyses of these...

Over the past thirty years, the dominant rationale for mandatory, formal cost-benefit analysis (CBA) of federal health, safety and environmental regulations has changed from “CBA operates as a necessary institutional roadblock against power-hungry regulators” to “CBA is a neutral tool that...

Although the prospect of increased rationality in rulemaking makes legislation, such as Independent Agency Regulatory Analysis Act (S. 1173), facially appealing, there are a number of reasons to be wary of such efforts to impose OMB-supervised regulatory review on independent regulatory...

OMB-overseen regulatory cost-benefit analysis (CBA) requirements distort the regulatory decision-making process in ways that cause serious harm to public health, safety and the environment. The methodologies used in these analyses are fatally flawed. In general, no real effort is made to measure...

Were this anti-regulatory NPRM—or any logical outgrowth of it—to be finalized, it would result in repeated violations of the Clean Air Act and the Administrative Procedures Act. The problematic methodologies being codified in this NPRM would often generate nonsensical, arbitrary results, and...