Comments to OMB on the Proposed Revisions to Circular A-4
To the Office of Management and Budget on proposed revisions to Circular A-4.
OMB’s proposed revisions to Circular A-4 represent an essential and important step to update 20-year-old guidance. Much has changed in financial markets and in economic and scientific understanding in the past two decades, which merits updates to regulatory analysis—in particular regarding approaches to discounting. Discounting is the process of converting a value received in a future time period to an equivalent value received immediately. For more, see Prest (2020). Our comments below focus on three key issues that have been updated in the proposed revision to Circular A-4: (1) approaches to discounting; (2) the scope of analysis; and (3) the newly proposed approach to distributional weighting. We conclude by noting the important role of OMB guidance for ensuring analytical consistency across agencies.
Richard D. Morgenstern
Richard Morgenstern is a senior fellow at RFF. His research focuses on the economic analysis of environmental issues with an emphasis on the costs, benefits, evaluation, and design of environmental policies.
Richard G. Newell
President and CEO, Resources for the Future
Dr. Richard G. Newell is the President and CEO of Resources for the Future. From 2009 to 2011, he served as the administrator of the US Energy Information Administration, the agency responsible for official US government energy statistics and analysis.
William A. Pizer
Vice President for Research and Policy Engagement
Billy Pizer is Vice President for Research and Policy Engagement at RFF.
On the Issues — Sep 22, 2023
On the Issues: Equitable Climate Policy, Value of a Statistical Life, and More
A biweekly newsletter connecting global current events, pressing climate and energy policy news, and economics research from RFF scholars. This week: equitable climate policy, value of a statistical life, and more.
Common Resources — Sep 21, 2023
Rethinking the Value of a Statistical Life
The value of statistical life is a number that informs analyses of the benefits and costs of regulations. But the number that the US Environmental Protection Agency currently uses needs attention: it hasn’t been updated since 1997.
Explainer — Sep 8, 2023
Agricultural Greenhouse Gas Emissions 101
This explainer provides an overview of agriculture's contributions to US greenhouse gas emissions, detailing major emissions sources and technology options for emissions mitigation.