Cost-Benefit Analysis Without the B: How Rewriting OIRA’s Past Threatens Its Future

Sally Katzen

Journal of Benefit-Cost Analysis, 2020, vol. 11, issue 1, 49-54

Abstract: Jim Tozzi has a wealth of knowledge and experience with cost-benefit analysis and centralized review of Executive Branch rulemaking. Mine is more limited, but nonetheless significant.1 And while I may agree with much of what he says in his article “Office of Information and Regulatory Affairs: Past, Present and Future,” (Tozzi, 2019) I do see things differently than he does in a number of respects.

Date: 2020
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