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Environmental Protection Agency (EPA) Cost-Benefit Analysis Office of Management and Budget

Foley Hoag LLP - Energy & Climate Counsel

Biden Expands Consideration of Social Cost of Carbon by Federal Agencies

On September 21, 2023, the Biden administration outlined plans to expand federal agencies’ consideration of the social cost of carbon—a metric for the economic cost of each additional ton of carbon dioxide emitted to the...more

Foley Hoag LLP - Environmental Law

OMB Proposes to Revise Circular A-4; This is Not Trivial

On Thursday, the Office of Management and Budget released proposed revisions to “Circular A-4”.  It also released a separate preamble, explaining its thinking and asking for comment on certain identified issues....more

Foley Hoag LLP - Environmental Law

Can Cumulative Impact Analysis Improve Cost-Benefit Analysis?

As frequent readers know, I am a big fan of cost-benefit analysis. The basic idea is that, when we make a decision to regulate at a certain level, we are by definition deciding that regulating to that level is “worth” the...more

Morgan Lewis

President Biden’s ‘Modernizing Regulatory Review’ Memorandum

Morgan Lewis on

Much of the attention in President Joseph Biden’s executive actions in his first 100 days has been focused on his numerous executive orders on topics ranging from climate and COVID-19 to race and gender. Although these...more

Foley Hoag LLP - Environmental Law

OMB Reports that the Benefits of Regulation Exceed the Costs. The President Knows that Can’t Be Right

Late last month, to no fanfare whatsoever, OMB released its annual report on the costs and benefits of federal regulations. There’s a reason that the Administration did not give the report any attention. The report states...more

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