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Cost-Benefit Analysis and Regulation

Frank Ackerman collaborated with Lisa Heinzerling of Georgetown University Law School to write Priceless: On Knowing the Price of Everything and the Value of Nothing, (The New Press, 2004). This book critiques the arguments used to justify the current attacks on health, safety, and the environment.

Ackerman and Heinzerling have also produced a widely circulated report, "Pricing the Priceless: Cost-Benefit Analysis of Environmental Protection," criticizing the current misuse of cost-benefit analysis in evaluating environmental policies. (Read the executive summary, or download the full report.) A modified version of this report, with the same title, appeared in the University of Pennsylvania Law Review in 2002, and was voted one of the ten best land use and environmental law review articles of the year, in an annual competition judged by a panel of law professors and practicing attorneys.

Frank Ackerman is a member of the Center for Progressive Regulation (CPR), an organization of researchers who support regulatory action to protect health, safety, and the environment, and who reject the conservative view that the government’s only function is to improve the efficiency of private markets. GDAE produced the CPR report, "Applying Cost-Benefit Analysis to Past Decision: Was Protecting the Environment Ever a Good Idea?", an examination of the decision processes that produced some of the most popular and successful health and environmental regulations applied in the past, comparing these processes with the cost-benefit standards now favored by the federal Office of Management and Budget.

GDAE has worked with the Hudson River-based group, Riverkeeper, to analyze and respond to EPA’s cost-benefit analysis of regulation of power plant cooling water intake systems. (Download GDAE’s August 2002 comments or June 2003 comments.)

Working with the Natural Resources Defense Council (NRDC) in 2000, Frank Ackerman submitted formal comments on the use of cost-benefit analysis in EPA's proposed arsenic standard. His testimony made clear the severe limitations of EPA's analysis.

Again in collaboration with NRDC, GDAE also filed comments on EPA's proposal to regulate stormwater runoff from construction and development sites, a major source of water pollution. GDAE's comments supported EPA's analysis against criticisms from the Office of Management and Budget (OMB).

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Global Development And Environment Institute
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