On the recordFebruary 28, 2014
I can tell you I am all for a cost- benefit analysis, but the challenge of doing a cost-benefit analysis comes down to who is doing the cost-benefit analysis and what are they putting into it. There have been multiple times that we have had conversations about a cost-benefit analysis, and there has been a push back to say: well, let's go back and check the math on that later and see if we actually got the benefit that was proposed that we will receive for that benefit. A benefit analysis, in particular, is kind of under scrutiny by academics, even under the Obama administration. As an example, the EPA issued a new standard for mercury emissions and reported that benefits of the rule were up to $90 billion a year, far above their $10 billion a year cost. Less than .01 of that $90 billion in benefits was attributable to actual reduction in mercury, though; instead, nearly all the benefits came from reductions in fine particles, a pollutant that was not even the purposed target of the regulation itself. Fine particle cobenefits accounted for two-thirds of the benefits of the economically significant rules in 2010. This administration has padded the benefit analysis with private benefits. In the fuel economy standards, for instance, for cars and light trucks, nearly 90 percent of the $338 billion in lifetime benefits were benefits to consumers, such as reduced fuel consumption, and--how about this one--shorter refueling times.…





