SBCA Presidents’ and JBCA Editors' Comments on Revised U.S. Analytic GuidanceOver the next few weeks, the Society for Benefit-Cost Analysis will be posting a series of working papers compiled for a special issue of the Journal of Benefit-Cost Analysis expected next year. This will be an unusual issue of the Journal in that all but two of the articles were initially submitted as a public comment to the Office of Management and Budget (OMB) on its proposed revisions to the federal government’s guidance on conducting regulatory impact analysis, “Circular A-4.” The Circular covers a range of issues, including analytical approaches; scope of analysis; developing an analytic baseline; identifying the potential needs for federal regulatory action; alternative regulatory approaches; assessing benefits and costs; transfers; distributional effects; treatment of uncertainty; discount rates; quality, objectivity, transparency, and reproducibility of results; specialized analytical requirements; and other key considerations. OMB issued draft revisions to Circular A-4 in June of 2023. Its request for comment yielded almost 4,500 submissions, but most of those were associated with mass comment campaigns, followed a template, and shared identical or nearly identical content (Xie, Hay and Hirsch 2024). The comments OMB received included 185 unique submissions that contained substantive content. In addition to this public request for comment, OMB solicited peer review comment from a select group of experts on specified issues. In November 2023, OMB released a final Circular. Several former presidents of the Society for Benefit-Cost Analysis and editors of the Journal of Benefit-Cost Analysis provided input on the draft Circular, either as peer reviewers or through public comments. In addition, all former SBCA presidents sent a letter to OMB commenting on the draft guidelines. Because elected presidents of the Society for Benefit-Cost Analysis and editors of the Journal bring unique expertise on the subject of regulatory impact analysis, this issue reproduces their comments as submitted. In addition, each author has supplemented their original submission with a prologue and/or epilogue. Each of these essays reflects the views of the authors, and not an official position of the Society. The series begins with a short letter from all the former presidents of the Society and several of the editors of the Journal to OMB’s Administrator of the Office of Information and Regulatory Affairs, Ricky Revesz. Next is a paper by Glenn Blomquist, one of the Circular’s peer reviewers as well as former SBCA president and JBCA editor, titled “What OIRA Peer Reviewers Advised Regarding Notable Proposed Updates to Circular A-4: An Ignored Consensus?” The series continues with the eight comments submitted by former SBCA officials, along with their prologues and epilogues. It concludes with an essay by Febrizio, Hay and Xie that compares the draft and final Circulars.
*Indicates invited peer reviewer
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