pageok
pageok
pageok
Heinzerling to Head EPA's Policy & Economics Shop:

Georgetown University law professor Lisa Heinzerling, who had been serving as a climate policy advisor to EPA Administrator Lisa Jackson, has been named Associate Administrator for the Office of Policy, Economics, and Innovation. This is an interesting development. OPEI includes EPA's National Center for Environmental Economics, and Heinzerling has been an outspoken critic of cost-benefit analysis. In her view, cost-benefit analysis "is at odds with fundamental premises of environmentalism." It's also interesting because her views of cost-benefit are at odds with incoming OIRA Administrator Cass Sunstein. Sunstein (whose nomination is stalled for other reasons) has been a cost-benefit proponent.

SuperSkeptic (mail):
Isn't nearly everything in the modern industrialized world "at odds with the fundamental premises of environmentalism?"
7.22.2009 10:58am
GMUSL '07 Alum (mail):
Applying a cost-benefit analysis to Heinzerling's respiration is clearly unwarranted. The only thing to do to accord "with fundamental premises of environmentalism" is to kill herself so she stops emitting CO2.

Somewhere, Michael Crichton is smiling.
7.22.2009 11:02am
DangerMouse:
Environmentalism is the left's new religion. That's really all you need to know. Question it and you're a blasphemer. Ask for cooperation with industry and you're a heathen sympathizer.

Seriously, can anyone tell me why environmentalism isn't a religion? Especially among people who aren't scientists?
7.22.2009 11:13am
xx:
Trick question. Nobody can tell you anything.
7.22.2009 11:34am
troll_dc2 (mail):
In theory, there is nothing wrong with cost-benefit analysis. But how are cost and benefit measured? Also, who would do the determining? There is a lot of room for game-playing here.

As I recall, the Bush 43 Administration is alleged to have done some dishonest stuff here so as to justify preconceived results.
7.22.2009 11:38am
Abdul Abulbul Amir (mail):


In theory, there is nothing wrong with cost-benefit analysis.

There is a lot of room for game-playing here.



Surely there is. The anaylsis should subject to public review to catch dishonesty,
7.22.2009 11:54am
KevinB (www):
In Priceless Heinzerling argues that EPA's reliance on cost-benefit analysis is dangerous because, among other things, the process of placing a monetary value on human life devalues it. She instead urges EPA to make decisions holisticially, like the military.

Dean Revesz, a defender of cost-benefit analysis and author of Retaking Rationality, notes with a hint of irony that the decision-making process leading to the Iraq war is the one Heinzerling wants to apply to environmental decisions. Sure cost-benefit analysis is flawed, but it's the best current decision-making process (as conspirator Eric Posner has argued).
7.22.2009 12:07pm
troll_dc2 (mail):

Sure cost-benefit analysis is flawed, but it's the best current decision-making process (as conspirator Eric Posner has argued).



But cost-benefit analysis has to be done in good faith. I would use it as a tool to help make a decision without letting the superficially precise results determine the decision.
7.22.2009 12:16pm
Edward Lunny (mail):
Relying on cost-benfit analysis is to dangerous for the environment, but just the ticket for nationalised health care. Interesting juxtaposition from the socialists in residence. Very reminiscent of the peta folks whom equate human life with that of small varmints and what not. What could possibly go wrong here ?
7.22.2009 1:15pm
troll_dc2 (mail):

Relying on cost-benfit analysis is to dangerous for the environment, but just the ticket for nationalised health care. Interesting juxtaposition from the socialists in residence.


Why is cost-benefit analysis "just the ticket for nationalised health care"?
7.22.2009 1:21pm
KevinB (www):

I would use it as a tool to help make a decision without letting the superficially precise results determine the decision.


You're right. The outcome of CBA shouldn't determine policy, but should instead give policymakers better information on which to base decisions. My last sentence was poorly worded.
7.22.2009 3:01pm
Paul B:
During the late 1970s I worked at the economic analysis office of EPA (don't remember its exact title) for the summer between first and second year of business school. Most of the people there had public policy degrees, usually from Woodrow Wilson or Kennedy, but there were a scattering of MBAs and PhDs there as well.

Several of the agency's Assistant Administrators, most of whom came to the Carter Administration from environmental groups, held similar views regarding economic and cost benefit analyses as Professor Heinzerling, although they were certainly willing to use them when the results were in sync with their policy preferences. However, my recollection was that they were always willing to listen to our arguments.

To have a law professor that fundamentally disagrees with the idea of economic analysis of environmental regulations in charge of the Office of Policy, Economics, and Innovation is no different than naming a creationist as head of the Biology section of the National Science Foundation.
7.22.2009 4:27pm
JK:
I took an administrative law class from Heinzerling at Georgetown, and I think it's easy to overstate her position. The main point that I took away was that cost-benefit analysis, regardless of its merits or flaws, is neither a consitituional or common law principle that courts can impose on regulations regardless of the language of the statutes.

You also have to consider her position on cost-benefit analysis in light of the fact that she clerked for Posner. Posner really has advocated essentially applying cost-benefit analysis into judicial review, basically because he thinks it's a good idea.

Personally I think the principle of cost-benefit analysis is incredibly important, and in some way should be applied to all government policy. But I think it works much better as a principle that guides good legislation, then as a judicial principle where it can be far too easily used as a cover for judicial nullification con contradiction to the actual law.
7.22.2009 5:14pm
troll_dc2 (mail):
Frequently, assumptions have to be made, probably more on the benefits side than on the costs side (although indirect costs can pose a problem). You can get caught up in hypotheticals, probabilities, extrapolations, and the like. So the numbers that you generate can be awfully spongy.

In addition, there are almost always unintended and unanticipated consequences of an action; some of them may be good and some of them may be unfortunate. It is hard to account for them in advance, but once you act, they become real nonetheless.

So I think that cost-benefit analysis is useful more for helping one's thinking (because it causes one to try to think of all relevant considerations) than for anything else.
7.22.2009 6:45pm
davod (mail):
"As I recall, the Bush 43 Administration is alleged to have done some dishonest stuff here so as to justify preconceived results"

"Alleged"
7.23.2009 7:21am
davod (mail):
Maybe my memory is faulty but I thought the law requires a Cost Benefit Analysis.
7.23.2009 7:24am
troll_dc2 (mail):

Maybe my memory is faulty but I thought the law requires a Cost Benefit Analysis.



Doesn't at least one environmental law actually forbid the use of cost-benefit analysis?
7.23.2009 10:56am
xx:
"davod (mail):
Maybe my memory is faulty but I thought the law requires a Cost Benefit Analysis."

Which law? Some do, some don't.
7.23.2009 5:23pm

Post as: [Register] [Log In]

Account:
Password:
Remember info?

If you have a comment about spelling, typos, or format errors, please e-mail the poster directly rather than posting a comment.

Comment Policy: We reserve the right to edit or delete comments, and in extreme cases to ban commenters, at our discretion. Comments must be relevant and civil (and, especially, free of name-calling). We think of comment threads like dinner parties at our homes. If you make the party unpleasant for us or for others, we'd rather you went elsewhere. We're happy to see a wide range of viewpoints, but we want all of them to be expressed as politely as possible.

We realize that such a comment policy can never be evenly enforced, because we can't possibly monitor every comment equally well. Hundreds of comments are posted every day here, and we don't read them all. Those we read, we read with different degrees of attention, and in different moods. We try to be fair, but we make no promises.

And remember, it's a big Internet. If you think we were mistaken in removing your post (or, in extreme cases, in removing you) -- or if you prefer a more free-for-all approach -- there are surely plenty of ways you can still get your views out.