New Report outlines concerns about our new “regulatory czar”
The biggest concern to me is the first: That cost-benefit analyses can be easily manipulated to achieve desired policy outcomes. Even if the analyses are manipulated to skew in favor of policies I support, I’d still prefer a better method.
Among the concerns raised in the report, Reinvigorating Protection of Health, Safety, and the Environment: The Choices Facing Cass Sunstein:
- Sunstein is a stout supporter of cost-benefit analysis as a primary tool for assessing regulations, despite its imprecision and the ease with which it is manipulated to achieve preferred policy outcomes;
- He supports such cost-benefit approaches as the widely condemned “senior discount” method for undervaluing the lives of seniors in cost-benefit analyses, an approach even the Bush Administration was forced to disown;
- He rejects the “precautionary principle” as a basis for regulating, thus ensuring that dangerous pollutants and products will be given the “benefit of the doubt,” rather than well-grounded concerns about health and safety;
- He supports the centralization of authority over regulatory decisions in the White House – OIRA in particular, even though Congress delegated the exercise of expert judgment to the regulatory agencies, not to OIRA’s staff economists in the White House; and
- He has written that the Occupational Safety and Health Administration might be unconstitutional.
In releasing the report, CPR President Rena Steinzor, one of seven co-authors of the report, warned that “Unless he turns over a new leaf, or unless President Obama keeps a careful eye on OIRA, we fear that Cass Sunstein’s reliance on cost-benefit analysis will create a regulatory fiefdom in the White House that will deal with needed regulations in very much the same way that the Bush Administration did. We desperately need change in this area, so we hope that if he is confirmed, Professor Sunstein moderates his past-stated views on these issues. In any event, we look forward to working with him in the years to come.”
And isn’t that just a delightfully perverse usage of “Senior Discount?” I’m sorry if I don’t think the value of a person’s life depends upon their income-earning potential… by that standard Mother Theresa was worthless.
Cross-posted to www.justinian.us