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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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