Regulatory Impact Analysis

Our assessment of the risks posed by incinerators should be the most structured of our Regulatory Impact Analyses. The detail we will be able to achieve in the other areas is uncertain, but we believe our work will represent the best that can be accomplished now. We need better tools to analyze the effects of our programs. Our two primary tools are economic analysis and risk analysis. We plan to rely heavily on them. To do less would be short-sighted and irresponsible. 

US EPA. (1997). Regulatory Impact Analyses for the Particulate Matter and Ozone National Ambient Air Quality Standards and Proposed Regional Haze Rule. Office of Air Quality Planning and Standards, Research Triangle Park, NC. 

Regulatory Impact Analyses so prepared are required to be reviewed by the Director of the Office of Management and Budget, subject to the direction of the Presidential Task Force on Regulatory Relief. Thus, Executive Order 12291 affords two regulatory review levels, one by 0MB and potentially one by the Task Force. The 0MB, as an agency of the Executive Office of the President, is in a position to ensure that both the letter and the spirit of Executive Order 12291 are followed in RIAs produced by the several agencies. 

In that policy, CMA has unequivocally stated that regulatory agencies should perform regulatory impact analyses to stake governmental decision-making processes more effective. The Association believes that improved analysis at the beginning of a regulatory proposal will allow workable and effective rules to be in place sooner. Economic, scientific and technical issues should be included in the analysis. 

EPA-Diesel RIA, Regulatory Impact Analysis—Control of Air Pollution from New Motor Vehicles Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements United States Environmental Protection Agency, Air and Radiation EPA420-R, 99-023. 1999. December. 

The second area of activity has to do with studies being conducted by EPA to evaluate incinerator performance as part of the Agency s Regulatory Impact Analysis (RIA) of hazardous waste incineration regulations. As part of this analysis, several... 

According to an estimate derived from the Regulatory Impact Analysis (RIA), the RCRA will cost 38.8 billion in 1996 dollars to implement. PRPs will incur most of the cost (about 89%), with the remaining 11% being incurred by federal facilities. 

EPA-Gasoline-RIA. Regulatory impact analysis—Control of Air pollution from new motor vehicles Tier 2 motor vehicle emissions standards and gasoline sulfur control requirements. US Environmental Protection Agency, Air and Radiation. EPA420-R-99-023, December 1999. 

Chemical Industry Perspectives on Regulatory Impact Analysis... 

Thus, the Executive Order requires that agencies affected by the order employ cost-benefit criteria in developing and issuing regulations. The tool to be applied for that purpose is the Regulatory Impact Analysis. 

The nature of the Regulatory Impact Analysis (RIA) is specified in Section 3 of the Executive Order. In general, such analyses are required only for rules which the issuing agency determines are major rules. The order defines a major rule as any regulation likely to result in... 

The proposal to employ cost-benefit methods in regulatory impact analysis is not without its critics. In a November, 1981 address at 8 University of Virginia Law School meeting, U.S. Senator Robert T. Stafford opposed the use of cost-benefit analysis in environmental issues. His comments about the cost-benefit analysis are summed up in the following points ... 

Regulatory impact analysis should not include quantification of intangibles in monetary terms ... 

Some conclusions can nevertheless be drawn. It seems clear from the survey research data that the American public is concerned over the increase in social regulation, and that there is growing interest in introducing the cost factor into agency considerations. It can reasonably be concluded that, so long as Executive Order 12291 requires regulatory impact analysis, cost-benefit analysis will play that function. Nevertheless, the nature of the debate is very likely to change in ways not yet anticipated by the present participants. 

Chemical Manufacturers Association, Policy for Regulatory Impact Analysis of Health. Safety and Environmental Regulations, (Washington, D.C. 1981). 

EPA Regulatory Impact Analysis of the Clean Air Mercury Peule. (2005). EPA-452/R-05-003. Washington, DC Office of Ar Quality Planning and Standards Environmental Ar Quality Strategies and Standards Division, U.S. Environmental Protection Agency. 

Under Section 9(f)(2), the Commission s final rule must be accompanied by a regulatory impact analysis which describes the potential costs and benefits associated with the rule, analyzes the costs and benefits of alternative approaches that the Commission has considered and rejected, and discusses all significant issues raised during the public comment period. Pursuant to Section 9(g)(1), the rule must specify an effective date which does not exceed 180 days from the rule s promulgation unless the Commission finds that a delayed effective date is in the public interest. 

U. S. Environmental Protection Agency - Tier 2/ Sulfur Regulatory Impact Analysis (EPA 420-R-99-023, December 22, 1999, Chapter IV Technology Feasibility, page 311). 

Second, there are major differences between the United States and Europe in the extent of pre-regulatory studies undertaken. Because of the U.S. requirement on agencies like the U.S. Environmental Protection Agency to conduct a Regulatory Impact Analysis before taking action, substantially more information was available about the hoped-for benefits of U.S. policies. A further issue concerns the greater reliance on taxes for regulatory purposes in Europe compared to the United States. A number of European nations use such taxes—sometimes combined with incentive compatible rebate schemes—to achieve environmental objectives. 

United States Environmental Protection Agency Proposed Arsenic in Drinking Water Rule Regulatory Impact Analysis. Washington DC USEPA, EPA 815-R-00-013, 2000. 

R. Lofstedt (2004) The Swing of the Regulatory Pendulum in Europe From Precautionary Principle to (Regulatory) Impact Analysis, The Journal of Risk and... 

EPA-Diesel MA. Regulatory Impact Analysis Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements. United States Enviromnental Protection Agency, Air and Radiation EPA420-R-00-026, December 2000. 

NHTSA (2005b). Tire pressure monitoring system. FMVSS No. 138. Final regulatory impact analysis, March 2005. U.S. Department of Transportation, Washington DC (from Hauer, 2006). 

In October 1981 NHTSA published the final regulatory impact analysis upon which the rescission of mandatory passive (automatic) occupant restraints was based. The basic approach in anal is of the safety nefits and dollar costs is similar to that of earlier studies and some of the same data is used to make estimates. The text of the 1981 NHTSA document and the benefit-cost anal is found in Appendix A of the report permit comparison of... 

U. S. Department of Transportation. National Highway Traffic Safety Administration. Final Regulatory Impact Analysis Rescission of Automatic Occupant Protection Requirements. DOT HS 806 055. October 1981. 

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