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On the Accuracy of Regulatory Cost Estimates

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Author Info
Morgenstern, Richard () (Resources for the Future)
Harrington, Winston () (Resources for the Future)
Nelson, Per-Kristian () (Resources for the Future)

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Abstract

This study compares ex ante estimates of the direct costs of individual regulations to ex post assessments of the same regulations. A review of more than two dozen environmental and occupational safety regulations indicates that ex ante estimates of total (direct) costs have tended to exceed actuals. The authors find this to be true of 12 of the 25 rules in their data set, while for only 6 were the ex ante estimates too low. The overestimation of total costs is often due to errors in the quantity of emission reductions achieved by the rule which, in turn, suggest that the rule's benefits may also be overestimated. The quantity errors are driven by both baseline and compliance issues. At least for EPA and OSHA rules, overestimation of per-unit abatement costs occurs about as often as underestimation. In contrast, for those rules that use economic incentives, per-unit costs are consistently overestimated. Much of the overestimation can be attributed to technical innovations unanticipated at the time the rule is issued, and to quantity errors. In addition, several methodological and procedural explanations also apply: changes in the regulation after the cost estimate is prepared, use of maximum cost estimates, and asymmetric error correction. Since a number of environmental laws encourage the development of cost estimates that reflect a maximum rather than a mean, regulatory agencies could issue a "best estimate" along with the statutorily preferred cost estimate. Likewise, they could ensure that rule changes made in the course of the regulatory development process are manifest in revised cost estimates. Indeed, discovering how and when to adjust ex ante estimates provides the strongest possible justification for more credible ex post studies—a research activity that merits greater emphasis.

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Paper provided by Resources For the Future in its series Discussion Papers with number dp-99-18.

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Date of creation: 01 Jan 1999
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Handle: RePEc:rff:dpaper:dp-99-18

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  1. Kwerel, Evan, 1977. "To Tell the Truth: Imperfect Information and Optimal Pollution Control," Review of Economic Studies, Blackwell Publishing, vol. 44(3), pages 595-601, October. [Downloadable!] (restricted)
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  3. Hazilla, Michael & Kopp, Raymond J, 1990. "Social Cost of Environmental Quality Regulations: A General Equilibrium Analysis," Journal of Political Economy, University of Chicago Press, vol. 98(4), pages 853-73, August. [Downloadable!] (restricted)
  4. Weitzman, Martin L, 1980. "Efficient Incentive Contracts," The Quarterly Journal of Economics, MIT Press, vol. 94(4), pages 719-30, June. [Downloadable!] (restricted)
  5. Palmer, Karen & Oates, Wallace E & Portney, Paul R, 1995. "Tightening Environmental Standards: The Benefit-Cost or the No-Cost Paradigm?," Journal of Economic Perspectives, American Economic Association, vol. 9(4), pages 119-32, Fall. [Downloadable!] (restricted)
  6. Cropper, Maureen L & Oates, Wallace E, 1992. "Environmental Economics: A Survey," Journal of Economic Literature, American Economic Association, vol. 30(2), pages 675-740, June. [Downloadable!] (restricted)
  7. Maloney, Michael T & McCormick, Robert E, 1982. "A Positive Theory of Environmental Quality Regulation," Journal of Law & Economics, University of Chicago Press, vol. 25(1), pages 99-123, April.
  8. Terasawa, Katsuaki & Quirk, James & Womar, Keith., 1984. "Turbulence, Cost Escalation, and Capital Intensity Bias in Defense Contracting," Working Papers 508, California Institute of Technology, Division of the Humanities and Social Sciences. [Downloadable!]
  9. Adam B. Jaffe et al., 1995. "Environmental Regulation and the Competitiveness of U.S. Manufacturing: What Does the Evidence Tell Us?," Journal of Economic Literature, American Economic Association, vol. 33(1), pages 132-163, March. [Downloadable!] (restricted)
  10. ., ., 1997. "," Journal of Accounting and Economics, Elsevier, vol. 24(2), pages 127-127, December. [Downloadable!] (restricted)
  11. Harris, Milton & Raviv, Artur, 1979. "Optimal incentive contracts with imperfect information," Journal of Economic Theory, Elsevier, vol. 20(2), pages 231-259, April. [Downloadable!] (restricted)
  12. Pizer, William & Morgenstern, Richard & Shih, Jhih-Shyang, 1998. "The Cost of Environmental Protection," Discussion Papers dp-98-36, Resources For the Future. [Downloadable!]
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  13. Spulber, Daniel F., 1988. "Optimal environmental regulation under asymmetric information," Journal of Public Economics, Elsevier, vol. 35(2), pages 163-181, March. [Downloadable!] (restricted)
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  1. A. Myrick Freeman III, 2002. "Environmental Policy since Earth Day I: What Have We Gained?," Journal of Economic Perspectives, American Economic Association, vol. 16(1), pages 125-146, Winter. [Downloadable!] (restricted)
  2. Frank Ackerman, . "06-02 "The Unbearable Lightness of Regulatory Costs"," GDAE Working Papers 06-02, GDAE, Tufts University. [Downloadable!]
  3. Stavins, Robert, 2000. "Economic Analysis of Global Climate Change Policy: A Primer," Working Paper Series rwp00-003, Harvard University, John F. Kennedy School of Government. [Downloadable!]
  4. Burtraw, Dallas & Palmer, Karen & Cropper, Maureen & Carlson, Curtis, 1998. "Sulfur-Dioxide Control By Electric Utilities: What Are the Gains from Trade?," Discussion Papers dp-98-44-rev, Resources For the Future. [Downloadable!]
    Other versions:
  5. Toman, Michael & Morgenstern, Richard & Anderson, John, 1998. "The Economics of "When" Flexibility in the Design of Greenhouse Gas Abatement Policies," Discussion Papers dp-99-38-rev, Resources For the Future. [Downloadable!]
  6. Harrington, Winston, 2006. "Grading Estimates of the Benefits and Costs of Federal Regulation," Discussion Papers dp-06-39, Resources For the Future. [Downloadable!]
  7. Cavanagh, Sheila & Hahn, Robert & Stavins, Robert, 2001. "National Environmental Policy During the Clinton Years," Working Paper Series rwp01-027, Harvard University, John F. Kennedy School of Government. [Downloadable!]
    Other versions:
  8. Dowlatabadi, Hadi & Boyd, David & MacDonald, Jamie, 2004. "Model, Model on the Screen, What's the Cost of Going Green?," Discussion Papers dp-04-17, Resources For the Future. [Downloadable!]
  9. Ted Gayer & Robert Hahn, 2006. "Designing environmental policy: lessons from the regulation of mercury emissions," Journal of Regulatory Economics, Springer, vol. 30(3), pages 291-315, November. [Downloadable!] (restricted)
  10. Robert Gagné & Paul Lanoie & Pierre-Carl Michaud & Michel Patry, 2001. "Les coûts de la réglementation : une revue de la littérature," Cahiers de recherche 01-04, HEC Montréal, Institut d'économie appliquée. [Downloadable!]
    Other versions:
  11. Joel Cohen & John Komen & José Falck Zepeda, 2004. "National Agricultural Biotechnology Research Capacity in Developing Countries," Working Papers 04-14, Agricultural and Development Economics Division of the Food and Agriculture Organization of the United Nations (FAO - ESA). [Downloadable!]
  12. Morgenstern, Richard & Harrington, Winston, 2004. "Evaluating Regulatory Impact Analyses," Discussion Papers dp-04-04, Resources For the Future. [Downloadable!]
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