Individual Peer Reviewer Comments on Proposed OMB Circular No. A-4, "Regulatory Analysis"

Billy Pizer, RFF's Vice President for Research and Policy Engagement, shares his thoughts on Circular A-4 as part of the US Office of Management and Budget's peer-review process.

View Testimony and Public Comments


Aug. 3, 2023


William Pizer


Testimony and Public Comments

Reading time

1 minute

“A large part of [the] comments here are focused on the discounting recommendation in the proposed revisions. These recommendations can be broken down into five main points: the change in the consumption rate, the shift to a shadow price of capital approach, use of a default risk premium versus certainty equivalents to address risk, the option to use a Ramsey discounting approach, and options for a declining discount rate over long horizons.”

Click here to read the comments prepared for the US Office of Management and Budget.


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