Regulatory Reform: Information on Costs, Cost-Effectiveness, and Mandated Deadlines for Regulations

------------------------------ Indexing Terms ------------------------------

REPORTNUM: PEMD-95-18BR
TITLE: Regulatory Reform: Information on Costs,
Cost-Effectiveness, and Mandated Deadlines for Regulations
DATE: 03/08/95
SUBJECT: Federal regulations
Economic growth
Economic analysis
Cost effectiveness analysis
Gross National Product
Environmental legislation
Transfer payments
Safety regulation
Regulatory agencies
Federal administrative law
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Cover
================================================================ COVER

Briefing Report to the Ranking Minority Member, Committee on
Governmental Affairs, U.S. Senate

March 1995

REGULATORY REFORM - INFORMATION ON
COSTS, COST-EFFECTIVENESS, AND
MANDATED DEADLINES FOR REGULATIONS

GAO/PEMD-95-18BR

Regulatory Reform

Abbreviations
=============================================================== ABBREV

CAA - Clean Air Act
CPSC - Consumer Product Safety Commission
EPA - Environmental Protection Agency
FAA - Federal Aviation Administration
FDA - Food and Drug Administration
FHWA - Federal Highway Administration
GDP - Gross domestic product
NHTSA - National Highway Traffic Safety Administration
OMB - Office of Management and Budget
OSHA - Occupational Safety and Health Administration
RCRA - Resource Conservation and Recovery Act
SRA - Significant regulatory action

Letter
=============================================================== LETTER

B-260553

March 8, 1995

The Honorable John Glenn
Ranking Minority Member
Committee on Governmental Affairs
United States Senate

Dear Senator Glenn:

On February 21, 1995, you asked us to provide you with information
relevant to the Committee's consideration of regulatory reform
legislation. On March 3, we briefed the staff of the Governmental
Affairs Committee and other invited Senate staff members on the
cumulative costs of federal regulations, the cost-effectiveness of
regulations, and trends in mandated deadlines for significant
regulations. In each area, we presented additional information
relevant to environmental regulations. This report summarizes the
information we presented in that briefing.

BACKGROUND
------------------------------------------------------------ Letter :1

Over time, the federal government has constructed a set of intricate
controls over the economy. From agricultural price supports and
export subsidies to automobile safety and occupational health, the
Congress has passed laws to achieve public policy goals. Through
these laws, federal agencies are often directed to issue regulations
to achieve the stated goals. In recent years, the Congress has
removed some regulatory controls, such as those dealing with
restrictions on the ability of airlines to enter markets. However,
other regulations, such as those designed to assist individuals with
disabilities and more stringent protections against air pollution
have been added.

Currently, the Congress is actively debating the way in which
regulations are developed, and it is now considering legislation that
would direct changes in procedures for agencies to issue regulations.
Questions of the cost and cost-effectiveness of regulations and the
degree to which agencies' regulatory agendas are controlled by the
legislative and judicial branches have been considerations in this
debate. You requested that we briefly review available sources of
research on these topics to provide you with background information
prior to consideration of legislation that would modify federal
regulatory policy.

RESULTS
------------------------------------------------------------ Letter :2

Our review indicates that there is a large degree of uncertainty
about basic questions such as the costs and benefits of regulations.
In addition, agencies operate under distinct statutory mandates, some
requiring and others prohibiting costs to be considered.

Estimates of total regulatory costs can vary depending on assumptions
about what constitutes regulatory cost. For example, economists
argue whether or not transfers, such as the added cost a consumer
pays for goods in the marketplace because of agricultural price
supports, should be included in such estimates. Others are concerned
about including process costs, such as those for completing tax
returns. These two cost categories account for over half of some
estimates. The cost-per-life-saved, or cost-effectiveness, varies
dramatically across agencies, indicating that other factors influence
regulatory decision-making. Regarding trends in mandated deadlines
for regulatory actions, they have increased over recent years,
particularly for the Environmental Protection Agency (EPA). Details
of our review are summarized below and presented in detail in the
body of the report.

CUMULATIVE COSTS OF
REGULATIONS
---------------------------------------------------------- Letter :2.1

A number of approaches have been used to assess the costs imposed on
the economy by federal regulations. Depending upon the measures used
and the assumptions made, the estimates can vary widely. In addition
to the current debate about the extent of the dollar costs to the
economy, there is also a debate about the nature of the impact of
regulations on the economy. Although a regulation imposes costs on
society and can slow economic growth, it has a net positive effect
when the value of its benefits exceeds its cost. In addition, a
recent view is that some regulations (certain environmental and
occupational safety and health regulations in particular) have been a
net positive force driving private firms and the economy as a whole
to become more competitive in international markets.\1

However, for this effort, we were specifically asked to review the
work of Thomas Hopkins, which is a compilation of other efforts in
this area, drawing on many studies to produce estimates of the
cumulative cost of federal regulations.\2 We report his principal
findings and discuss them in the context of their size vis-a-vis the
overall economy.

One indicator that Hopkins uses to assess the cost of federal
regulations is federal spending on regulatory programs. Reporting
work conducted by the Center for the Study of American Business, he
measures this by summing the budgets of the major federal regulatory
agencies.\3 He notes that federal spending on regulatory programs
increased from approximately $10 billion in 1977 to about $14 billion
in 1992, in constant 1995 dollars.\4

However, when we analyze this finding as a percentage of gross
domestic product (GDP), we see that federal spending remained
relatively constant over this period.

Hopkins' estimate of total regulatory costs is his primary indicator
of the cumulative costs that federal regulations place on the
economy. According to his calculation, cumulative regulatory costs
to the economy increased about 9 percent from 1977 to 1994. At the
same time, because GDP grew steadily, the percent of national product
devoted to the cost of federal regulations decreased over the period.

Hopkins includes five categories of costs in his estimate of the
"cost of regulation" on the economy. These are the efficiency costs
(direct costs) of (1) environmental regulations, (2) other social
regulations, and (3) economic regulations. He also includes (4) the
costs to the economy stemming from "process" requirements (such as
providing information to the government--notably tax information).
Lastly, he includes (5) transfers stemming from regulations. As
direct costs, these first four categories represent resources lost to
the economy through regulation. For example, a $1 million cost
stemming from an environmental regulation represents the amount of
economic resources that are not available to be spent on other
economic activities. Through regulation, society has diverted some
of its resources to achieve an environmental goal. However, as noted
above, transfers are not costs to society as a whole because they do
not directly reduce the resources available to society. Transfers do
redistribute resources within society and thus place a burden on some
groups while benefiting others.

For example, Hopkins estimates that in 1990, the "costs" associated
with these five categories were: environmental regulations, $110
billion; other social regulations, $37 billion; economic regulations,
$80 billion; process costs, $191 billion; and transfers, $143
billion. His total estimate for 1990 was, thus, $562 billion.\5

Many economists argue that transfers should not be included in this
type of analysis of the burden placed on the economy by regulations
because transfers are not considered to be "costs." A different kind
of concern can be raised about process costs. Taking these estimates
at face value may be problematic because of measurement concerns.
Also, any change associated with this category may be difficult to
achieve, since the majority of the estimate derives from completing
tax forms. Excluding these, Hopkins' 1990 estimate would drop from
$562 billion to $228 billion, or 3.6 percent of GDP.

What is clear from these analyses is that the measures and
assumptions used have large impacts on the estimates, imposing a
great deal of uncertainty on them.

We prepared an additional analysis to examine in further detail the
question of the costs of environmental regulations. One measure of
the costs imposed on the economy by environmental regulations is
expenditures related to pollution abatement. Such expenditures have
increased 90 percent, from $60 billion to $113 billion, in constant
dollars, from 1972 to 1992. This period includes the enactment of
almost all the environmental statutes. However, since the mid-1970s,
when compared to the economic growth of the nation, these
expenditures have remained relatively constant as a percentage of
GDP.

--------------------
\1 Adam B. Jaffe et al., "Environmental Regulation and the
Competitiveness of U.S. Manufacturing: What Does the Evidence Tell
Us?" Journal of Economic Literature (forthcoming).

\2 Thomas D. Hopkins, Cost of Regulation, A report to the Regulatory
Information Service Center, Aug. 1991; "Federal Regulatory Burdens,"
RIT Public Policy Working Paper, Rochester, N.Y.: Rochester
Institute of Technology, 1993; and unpublished data.

\3 Melinda Warren, Regulation on the Rise: Analysis of the Federal
Budget for 1992, Occasional Paper No. 89. St. Louis: Center for
Study of American Business, Washington University, July 1991.

\4 Costs cited throughout this report have been standardized to
constant 1995 dollars.

\5 Numbers may not sum perfectly due to rounding.

COST-EFFECTIVENESS OF
REGULATIONS
---------------------------------------------------------- Letter :2.2

Several federal agencies issue regulations directing that actions be
taken to reduce risks, thereby having the potential to save lives.
These agencies operate under distinct statutory mandates requiring
that decisions be made using different analyses and decision rules.
Some statutes require both the costs and benefits of a regulation to
be taken into account before issuing a rule, while other statutes
specifically prohibit cost considerations from being used in
decision-making. The studies we reviewed examined the
cost-effectiveness of agency actions without regard to the type of
decision rules called for by the various statutes.

Analyses of cost-effectiveness are typically performed by computing a
ratio of the projected lives saved to the projected costs associated
with the action. A low cost-per-life-saved should not be taken to
indicate a low value placed on life by an agency, however, as it may
simply indicate that there are inexpensive alternatives available
that will save many lives.

We reviewed several studies that have examined cost-effectiveness.
These studies largely focus on lives saved by the regulations and do
not include other benefits that may accrue, such as reduced morbidity
or aesthetic improvements. Estimates of the implicit
cost-per-life-saved range from thousands of dollars per life for
several regulations to millions of dollars per life for others.\6

Overall, the studies indicate that

cost-effectiveness across agencies and statutes varies enormously,
and

agencies might have included cost considerations in some decisions.

A number of factors can explain divergence in estimated
cost-effectiveness. As noted above, statutory mandates for making
these decisions often differ. In addition, some of these regulations
could have benefits other than mortality reduction that could explain
some of the divergence. Also, the costs of reducing risks inevitably
differ. Given these factors, we would not expect to find a
convergence of cost-effectiveness across agencies, statutes, and
technologies.

--------------------
\6 In fact, studies cite several regulations that were estimated to
have "negative costs"--that is, they would save the economy money
(exclusive of the intended environmental or social benefit).

TRENDS IN MANDATED DEADLINES
FOR REGULATIONS
---------------------------------------------------------- Letter :2.3

The number of significant regulatory actions (SRAs) in seven
departments and agencies whose regulatory documents we examined has
been increasing over recent years.\7 Over the period 1985 to 1992,
the percentage of regulations issued under a mandated deadline has
increased, with the level in the 1990s being higher than in the
1980s, but the proportion of regulations issued under a deadline
remained below 50 percent for the seven major regulatory agencies we
examined. However, the proportion was highest at EPA, where the
majority of significant regulatory actions in recent years were
issued under a mandated deadline.

--------------------
\7 Significant regulatory actions are defined as the priority
regulatory activities of the agencies. SRAs may or may not have an
associated deadline mandated by the courts or by statute.

OBJECTIVES, SCOPE, AND
METHODOLOGY
------------------------------------------------------------ Letter :3

Our objective was to provide background information relevant to three
issues: (1) the cumulative costs that federal regulations place on
the economy, and more specifically, costs associated with
environmental regulations; (2) the cost-effectiveness of regulations
and variations between regulatory alternatives considered and those
finally adopted; and (3) trends in statutorily or judicially mandated
deadlines for significant regulations, along with significant
environmental regulations issued for each of the years since 1985.
We were asked to acquire and report on data in specific studies, and
we did no significant methodological review of the data presented in
those studies, due to time constraints. We prepared original
analyses, where appropriate, to address the objectives.

To review the cumulative costs placed on the economy by federal
regulations, we analyzed prior studies that have provided such
estimates. We were specifically asked to examine the work of Thomas
Hopkins, and we prepared additional analyses using data from his
work. We also analyzed data on the costs associated with
environmental regulations, drawing on information published by the
Bureau of the Census and the EPA. All cost figures throughout this
report have been converted to constant 1995 dollars.

To review the cost-effectiveness of regulations, we examined studies
that have analyzed the cost-per-life-saved projected for various
regulatory actions. We prepared some additional analyses from these
data comparing the projected cost-effectiveness of regulatory actions
that were considered, but never promulgated as rules, with those
actions that were issued within the same agencies. The actions
contained in these studies are typically the subset of actions for
which complete data were available to the authors on the projected
costs and lives saved. These should not be taken to be
representative of all agency actions, for which such
cost-effectiveness computations cannot be performed.

To review trends in statutorily or judicially mandated deadlines for
significant regulations, we analyzed information contained in the
Regulatory Program for all the years in which it was published
(1985-88, 1990-92).\8 This document provides information on all
"significant regulatory actions" issued by the major regulatory
agencies. We limited our analyses to seven agencies: the Department
of Agriculture, the Department of Energy, the Environmental
Protection Agency, the Food and Drug Administration, the Department
of the Interior, the Department of Labor, and the Department of
Transportation. These agencies were chosen because they represent
the seven largest regulatory agencies that have been cited in
discussions of regulatory reform.

Our review followed generally accepted government auditing standards
and was performed in February and March 1995. We did not obtain
formal agency comments on this report because of time limitations.
We obtained informal comments on our analyses from Dr. Thomas
Hopkins and Dr. Tammy Tengs, the two authors whose work we examined
in the greatest depth, and for which we present additional analyses
of their data. They concurred with our presentation of the
information.

We are sending copies of this report to the members of the Committee
and to other interested parties. Copies will also be made available
to others upon request.

The major contributors to this briefing report are listed in appendix
II. If you or your staff have any questions about this report,
please call me on (202) 512-3092.

Sincerely yours,

Kwai-Cheung Chan
Director of Program Evaluation
in Physical Systems Areas

--------------------
\8 Executive Office of the President, Office of Management and Budget
(OMB), Regulatory Program of the United States Government, 1985-88
and 1990-92.

CUMULATIVE COSTS OF REGULATIONS
============================================================ Chapter I

STUDIES OF REGULATORY COSTS
---------------------------------------------------------- Chapter I:1

(See figure in printed
edition.)

Different approaches are used to assess the costs imposed on the
economy by federal regulations. Depending upon the measures used and
the assumptions made, the estimates can vary widely. (See the
bibliography for a list of the studies we reviewed.)

We were specifically asked to review the work of Thomas Hopkins, an
economics professor at the Rochester Institute of Technology.\1 His
work is a compilation of other efforts in this area, drawing on many
studies to produce estimates of the cumulative cost of federal
regulations.

--------------------
\1 Thomas D. Hopkins, Cost of Regulation, A Report to the Regulatory
Information Service Center, Aug. 1991; "Federal Regulatory Burdens,"
RIT Public Policy Working Paper, Rochester, N.Y.: Rochester
Institute of Technology, 1993; and unpublished data.

FEDERAL SPENDING ON REGULATORY
PROGRAMS
---------------------------------------------------------- Chapter I:2

(See figure in printed
edition.)

Source: Data derived from
Hopkins, 1991; converted to
constant 1995 dollars.

(See figure in printed
edition.)

One indicator that Hopkins uses to assess the cost of federal
regulations is federal spending on regulatory programs. Drawing upon
estimates made by the Center for the Study of American Business, he
sums the budgets of the major federal "regulatory" agencies including
EPA, Coast Guard, FDA, and FAA.\2 Hopkins reports an estimate of
federal spending on regulatory programs increasing from approximately
$10 billion to about $14 billion from 1977 to 1992.

(See figure in printed
edition.)

Source: Data derived from
Hopkins, 1991, and Bureau of
Economic Analysis, 1994;
converted to constant 1995
dollars.

(See figure in printed
edition.)

As a percentage of GDP, however, federal spending remained relatively
constant over this period.

--------------------
\2 Warren, 1991 and 1994.

HOPKINS' ESTIMATES OF TOTAL
REGULATORY COSTS
---------------------------------------------------------- Chapter I:3

(See figure in printed
edition.)

Source: Data derived from
Hopkins, 1993; converted to
constant 1995 dollars.

(See figure in printed
edition.)

Hopkins computes an estimate of the total regulatory costs as his
primary indicator of the cumulative costs that federal regulations
place on the economy. Including all five cost categories
(environmental, other social, economic, transfers due to economic
regulation, and process costs), he estimates that cumulative
regulatory costs to the economy declined from $595 billion in 1977 to
$517 billion in 1986, rose slightly in 1987, then

(See figure in printed
edition.)

Source: Data derived from
Hopkins, 1993, and Bureau of
Economic Analysis, 1994;
converted to constant 1995
dollars.

(See figure in printed
edition.)

dipped in 1988 before increasing steadily to $647 billion in 1994.
This represents an increase of about 9 percent from 1977 to 1994.

At the same time, GDP grew steadily; hence, the percent of GDP
devoted to the costs of federal regulations decreased over the
period.

HOPKINS' ESTIMATES OF COSTS BY
CATEGORY
---------------------------------------------------------- Chapter I:4

(See figure in printed
edition.)

Source: Data derived from
Hopkins, 1993; converted to
constant 1995 dollars.

(See figure in printed
edition.)

The chart above provides Hopkins' estimates for the five categories
of costs he includes:

Efficiency costs of environmental regulations. These are the
direct costs imposed by the range of environmental regulations.
He incorporated an estimate of the impact of the 1990 Amendments
to the Clean Air Act.

Efficiency costs of other social regulations. These include
consumer safety, nuclear safety, worker health, and worker
security and pensions.

Efficiency costs of economic regulations. These include
agricultural, communications, transportation, energy, financial,
construction, and international trade regulations.

Transfers stemming from economic regulations. About half this
estimate arises from transfers to stimulate exports. Also
included in this category are transfers due to agricultural
price supports.

Process costs. This category is based upon the OMB estimate of
paperwork burden hours, multiplied by $20 per hour. Tax forms
account for about 80 percent of the estimate.

As can be seen in the chart, environmental regulations were estimated
as the fastest growing source of costs among the five categories.
The 1990 estimate for this category was $110 billion.

Other social regulation costs gradually rose between 1977 and 1980,
then declined until 1984, and resumed rising about 1987. The 1990
estimate for this category was $37 billion.

Economic regulation costs declined steadily until 1988. His estimate
for 1988 onward is $80 billion.

Transfers stemming from economic regulations declined steadily until
1988. He assumed they remained constant from that point forward at
$143 billion, in constant 1995 dollars.

Process costs were estimated at $191 billion for 1990.

HOPKINS' ESTIMATES OF TOTAL
COSTS, WITH ADJUSTMENTS
---------------------------------------------------------- Chapter I:5

(See figure in printed
edition.)

Source: Data derived from
Hopkins, 1993; converted to
constant 1995 dollars.

(See figure in printed
edition.)

Transfers are not considered to be "costs" to the economy by many
economists. Rather, they represent a loss to one group and a
corresponding benefit to another. As an example, the principal
effect of agricultural price supports is a payment to farmers by
consumers, not a net loss to the economy.

Including process costs may also be problematic because of
measurement concerns. Also, any change associated with this category
may be difficult to achieve, since the majority of the estimate
derives from completing tax forms. GAO recently pointed out that "a
reliable estimate of the overall costs of tax compliance is not
currently available," and in any event, "reducing (tax) compliance
burden would be a difficult undertaking because of the various policy
tradeoffs, such as revenue and taxpayer equity, that must be made."\4

Excluding these, Hopkins' 1990 estimate would drop from $562 billion
to $228 billion, or 3.6 percent of GDP.

What is clear is that the measures and assumptions used have large
impacts on the estimates, imposing a great deal of uncertainty on
them.

--------------------
\4 See Tax System Burden: Tax Compliance Burden Faced by Business
Taxpayers (GAO/T-GGD-95-42; Dec. 9, 1994).

STUDIES OF THE COSTS OF
ENVIRONMENTAL REGULATIONS
---------------------------------------------------------- Chapter I:6

(See figure in printed
edition.)

We were asked to consider additional information that would be
relevant to understanding the costs associated with environmental
regulations.

POLLUTION ABATEMENT AND CONTROL
EXPENDITURES
---------------------------------------------------------- Chapter I:7

(See figure in printed
edition.)

Source: Data derived from
Bureau of Economic Analysis,
1994; converted to constant
1995 dollars.

(See figure in printed
edition.)

Expenditures related to pollution abatement have increased from $60
billion to $113 billion, in constant dollars, from 1972 to 1992, a
90-percent increase. This period includes the enactment of almost
all the major environmental statutes.

(See figure in printed
edition.)

Source: Data derived from
Bureau of Economic Analysis,
1994; converted to constant
1995 dollars.

(See figure in printed
edition.)

Since the mid-1970s, these expenditures have remained relatively
constant as a percentage of GDP.

COST-EFFECTIVENESS OF REGULATIONS
=========================================================== Chapter II

DEFINING COST-EFFECTIVENESS
--------------------------------------------------------- Chapter II:1

(See figure in printed
edition.)

Several federal agencies issue regulations directing that actions be
taken to reduce risks, thereby saving lives. These agencies operate
under distinct statutory mandates requiring that decisions be made
using different analyses and decision rules. Some statutes require
both the costs and benefits of a regulation to be taken into account
before issuing a rule, while other statutes specifically prohibit
cost considerations to be used as a basis in decision-making. The
studies we examined looked at the cost-effectiveness of agency
actions, without regard to the type of decision rules called for by
the various statutes.

A low cost-per-life-saved should not be taken to indicate a low value
placed on life by an agency, however, as it may simply indicate that
there are inexpensive alternatives available that will save many
lives. Thus, an agency issuing a regulation with an associated cost
of $10,000 per life saved should not be assumed to value life as
worth only 10 percent of what another agency uses when it issues a
rule with an associated cost of $100,000 per life saved.

We reviewed several studies that have examined this issue. (See the
bibliography for a list of the studies included.) These studies
largely focus on lives saved by the regulations and do not include
other benefits that may accrue, such as reduced morbidity or
aesthetic improvements. The actions contained in these studies are
typically the subset of actions for which complete data were
available to the authors on the projected costs and lives saved.
These should not be taken to be representative of all agency actions,
for which such cost-effectiveness computations cannot be performed.

The studies indicate that

cost-effectiveness across agencies and statutes varies enormously,
and

agencies may be including cost considerations in many decisions.

We provide some additional analyses of the most recent comprehensive
work in this area, that of Tammy Tengs et al.\1 Tengs is affiliated
with the Center for Health Policy Research and Education at Duke
University.

--------------------
\1 Tammy Tengs et al., "Five-Hundred Life-Saving Interventions and
Their Cost-Effectiveness," forthcoming in Risk Analysis, June 1995;
and Tengs, unpublished data.

COST-EFFECTIVENESS OF SIX
AGENCIES' REGULATIONS
--------------------------------------------------------- Chapter II:2

(See figure in printed
edition.)

Note: Median values;
logarithmic scale; numbers
represent regulations issued
and considered, but not issued,
for each agency.

(See figure in printed
edition.)

Source: Data derived from
Tengs et al., 1995.

(See figure in printed
edition.)

Of the regulations included in the analysis, those issued by EPA were
estimated to have the highest cost-effectiveness ratio in general.
That is, it was more expensive, on average, to reduce mortality risks
a given amount than it was for regulations from the other agencies
included in the study. EPA had the greatest number of regulations
included in the analysis and also the greatest range of estimated
cost-effectiveness.

COST-EFFECTIVENESS OF
REGULATIONS ISSUED BY FIVE
AGENCIES
--------------------------------------------------------- Chapter II:3

(See figure in printed
edition.)

Note: Logarithmic scale; four
additional regulations (two by
CPSC, one by EPA and one by
OSHA) were estimated to have
"negative" costs; that is, they
would save the economy
resources, in addition to the
intended benefits to health and
the environment.

(See figure in printed
edition.)

Source: Data derived from
Tengs et al., 1995.

(See figure in printed
edition.)

Four of these agencies had at least one "action" in each category
(issued and not issued). For three of them, the issued regulations
were, on average, more cost-effective than those actions that did not
result in a regulation. This may suggest that these agencies
incorporate costs in their decisions. This point has been made in
other studies that have examined this issue.\2 Verifying this
conclusion would require additional analysis.

--------------------
\2 Notably, Travis et al., 1987(a); Travis et al., 1987(b); and Van
Houtven and Cropper, 1993.

COST-EFFECTIVENESS OF 82 EPA
"ACTIONS"
--------------------------------------------------------- Chapter II:4

(See figure in printed edition.)

Note: Logarithmic scale; one
additional regulation was
estimated to cost less than
zero; that is, there was a
projected net savings.

(See figure in printed
edition.)

Source: Data derived from
Tengs et al., 1995.

(See figure in printed
edition.)

This and the following two charts illustrate the range of predicted
cost-effectiveness of the 35 EPA regulations issued that were
included in Tengs' study. As can be seen, the range of
cost-effectiveness decreases when moving from all EPA regulations to
those issued within individual programs.

COST-EFFECTIVENESS OF 31
ASBESTOS "BANS"
--------------------------------------------------------- Chapter II:5

(See figure in printed
edition.)

Note: Logarithmic scale.

(See figure in printed
edition.)

Source: Data derived from
Tengs et al., 1995.

(See figure in printed
edition.)

Cost-effectiveness of individual regulations within this group was
estimated to range from about $13,000 per life-year saved to $66
million per life-year saved.

Cost-effectiveness of regulations for benzene was estimated to range
from about $456,000 to $19 million per life-year saved. There is
little overlap between estimated cost-effectiveness within the two
groups of benzene

COST-EFFECTIVENESS OF 14
BENZENE "ACTIONS"
--------------------------------------------------------- Chapter II:6

(See figure in printed
edition.)

Note: Logarithmic scale.

(See figure in printed
edition.)

Source: Data derived from
Tengs et al., 1995.

(See figure in printed
edition.)

"actions." The use of cost data in deciding which regulations to
promulgate may also be affected by court cases. One study notes that
the average cost-per-cancer-case-avoided in EPA's hazardous air
pollutant regulations increased after 1987, when the Natural
Resources Defense Council won a suit charging that EPA's use of costs
and benefits was a violation of the Clean Air Act.\3

--------------------
\3 Van Houtven and Cropper, 1993.

TRENDS IN MANDATED DEADLINES FOR
REGULATIONS
========================================================== Chapter III

MANDATED DEADLINES FOR
REGULATIONS
-------------------------------------------------------- Chapter III:1

(See figure in printed
edition.)

We reviewed data from the OMB Regulatory Program on regulatory
actions by seven agencies: the Department of Agriculture, the
Department of Energy, the Environmental Protection Agency, the Food
and Drug Administration, the Department of the Interior, the
Department of Labor, and the Department of Transportation. These
agencies were chosen because they represent the seven largest
regulatory agencies that have been cited in discussions of regulatory
reform.

SIGNIFICANT REGULATORY ACTIONS
BY SEVEN AGENCIES
-------------------------------------------------------- Chapter III:2

(See figure in printed
edition.)

Note: The Regulatory Program
was not published in 1989, so
it was not possible to separate
regulations issued in 1988 and
1989.

(See figure in printed
edition.)

Source: Data derived from OMB,
Regulatory Program (1985-88,
1990-92).

(See figure in printed
edition.)

The data available were on significant regulatory actions. These
were defined as the priority regulatory activities of the agencies
during the time period covered by our analysis. "Major" regulations
(those covered by Executive Order 12291 of 1981, whose criteria
included a projected economic impact of $100 million or more)
comprise a subset of these totals.\1 As can be seen in the chart
above, the number of significant regulatory actions has been
increasing over recent years.

--------------------
\1 The current Executive Order 12866 of 1993 defines significant
regulatory actions differently.

TRENDS IN MANDATED DEADLINES
FOR SEVEN REGULATORY AGENCIES
-------------------------------------------------------- Chapter III:3

(See figure in printed
edition.)

Note: The Regulatory Program
was not published in 1989, so
it was not possible to separate
regulations issued in 1988 and
1989.

(See figure in printed
edition.)

Source: Data derived from OMB,
Regulatory Program (1985-88,
1990-92).

(See figure in printed
edition.)

The percentage of regulations issued under a mandated deadline has
increased, with the level in the 1990s being higher than in the
1980s, but it remains below 50 percent for the seven agencies.

TRENDS IN MANDATED DEADLINES
FOR EPA REGULATIONS
-------------------------------------------------------- Chapter III:4

(See figure in printed
edition.)

Note: The Regulatory Program
was not published in 1989, so
it was not possible to separate
regulations issued in 1988 and
1989.

(See figure in printed
edition.)

Source: Data derived from OMB,
Regulatory Program (1985-88,
1990-92).

(See figure in printed
edition.)

However, within EPA, a majority of significant regulatory actions are
now issued under a mandated deadline. A more detailed list of these
EPA actions, listing the regulations by statute and indicating which
fell under a judicially or statutorily mandated deadline, is provided
in appendix I.

TRENDS IN MANDATED DEADLINES
FOR EPA AND SIX OTHER AGENCIES
-------------------------------------------------------- Chapter III:5

(See figure in printed
edition.)

Note: The Regulatory Program
was not published in 1989, so
it was not possible to separate
regulations issued in 1988 and
1989.

(See figure in printed
edition.)

Source: Data derived from OMB,
Regulatory Program (1985-88,
1990-92).

(See figure in printed
edition.)

As can be seen in the chart above, the proportion of significant
regulatory actions issued under a judicially or statutorily mandated
deadline remains below 40 percent for six of the seven agencies. At
EPA, however, the proportion of SRAs with a mandated deadline has
been consistently higher, with recent levels exceeding 50 percent
(and over 60 percent in 1992) after a drop in the late 1980s.

EPA'S SIGNIFICANT REGULATORY
ACTIONS
=========================================================== Appendix I

Table I.1

SRAs Having a Mandated Deadline as a
Proportion of All Regulations Issued\a

St
at
ut
e\ Statute
b 1985 1986 1987 1988/89 1990 1991 1992\c total
-- -------- -------- -------- -------- -------- -------- -------- --------
CA 1 of 1 1 of 2 2 of 3 1 of 6 1 of 5 4 of 6 14 of 17 24 of 40
A
CE 1 of 1 \d \d \d 3 of 4 \d 0 of 1 4 of 6
R
C
L
A
CW \d \d 1 of 1 1 of 1 2 of 2 1 of 2 2 of 2 7 of 8
A
FI \d 0 of 1 0 of 1 0 of 1 \d 1 of 3 0 of 1 1 of 7
F
R
A
RC 2 of 3 4 of 7 0 of 2 4 of 6 5 of 10 2 of 3 2 of 6 19 of 37
RA
SD \d \d 2 of 2 2 of 3 2 of 2 1 of 1 1 of 1 8 of 9
WA
TS \d 0 of 3 0 of 1 0 of 3 \d 0 of 1 1 of 1 1 of 9
CA
Ot 1 of 1 0 of 1 1 of 4 1 of 2 \d 1 of 2 0 of 3 4 of 13
h
e
r
==================================================================================
Ye 5 of 6 5 of 14 6 of 14 9 of 22 13 of 23 10 of 18 20 of 32
ar
t
o
t
a
l
\
----------------------------------------------------------------------------------
Legend

CAA Clean Air Act
CERCLA Comprehensive Environmental Response, Compensation, and
Liability Act
CWA Clean Water Act
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
RCRA Resource Conservation and Recovery Act
SDWA Safe Drinking Water Act
TSCA Toxic Substances Control Act

\a Details are provided in table I.2.

\b In several cases, two statutes were listed in the Regulatory
Program. In these cases, we selected the one that appeared more
pivotal.

\c Some of these regulations may have been issued after 1992.

\d None.

Table I.2

Status of Judicially or Statutorily
Mandated Deadlines of EPA's Significant
Regulatory Actions (1985-1992)

Year Statute Regulation J S None
---------------- ---------- ------------------------------------------------ -- ---- ---- ----
1987 AHERA Asbestos-In-Schools Inspection and Abatement X
Rule

1985 CAA Review of the national Ambient Air Quality X
Standard for Carbon Monoxide

1986 CAA Guideline on Air Quality Models (Revision) X

1986 CAA (1977) Industrial Boilers -Particulate Matter and NOx X

1987 CAA (1987) NSPS: Industrial Boilers -SO2 X

1987 CAA NSPS: Residential Wood Combustion X

1987 CAA NSPS: Bubble for Central Illinois Public Service X
Company

1988 CAA Alternative Rural Fugitive Dust Policies for X
PM10

1988 CAA Development of EPA's Stratospheric Ozone X
Protection Plan

1988 CAA Fugitive Emissions/Surface Coal Mines and Air X
Quality New Source Review

1988 CAA Gasoline Volatility: Evaporative Hydrocarbon X
Emissions

1988 CAA NESHAP: Benzene X Reconsideration X

1988 CAA Standards and Test Procedures for Emissions From X
Methanol-Fueled Vehicles

1990 CAA Development of a Strategy for Expeditious X
Attainment of the National Ambient Air Quality
Standards for Ozone and Carbon Monoxide

1990 CAA Diesel Fuel Quality X

1990 CAA New Source Performance Standards: Municipal X
Waste Combustion

1990 CAA Prevention of Significant Deterioration (PSD) X
Increments for Particulate Matter -10 Micrometer
(PM10)

1990 CAA Trading and Banking of Heavy-Duty Engine NOx and X
PM Emission Credits

1991 CAA (1990) Cold Ambient Temperature Carbon Monoxide X
Emission Standards for Motor Vehicles

1991 CAA (1990) Control of Gasoline Refueling Emissions X

1991 CAA (1990) Motor Vehicle Compliance and Fuel Economy Fees X

1991 CAA (1990) Operating Permit Regulations X

1991 CAA (1990) Revised Motor Vehicle Emissions Standards X

1991 CAA (1990) Revision of Rules for Prevention of Significant X
Deterioration and New Source Review

1992 CAA (1990) Acid Rain Allowance System X

1992 CAA (1990) Acid Rain Phase 2 Allocations and Phase 1 X
Reserve

1992 CAA (1992) Acid Rain Program Permits and Excess Emissions X
Regulations

1992 CAA (1990) Acid Rain Continuous Emissions Monitoring X
Regulation

1992 CAA (1990) Control Techniques Guidelines for Sources of X
Volatile Organic Compound Emissions

1992 CAA (1990) Heavy-Duty Engine Standards X

1992 CAA Motor Vehicle Evaporative Emissions X

1992 CAA (1990) National Emission Standards X for Hazardous Air X
Pollutants: Dry-Cleaning Facilities

1992 CAA NESHAP: Emissions of Radionuclides to the Air X

1992 CAA New Source Performance Standards: Municipal X
Solid Waste Landfills

1992 CAA (1990) Onboard Diagnostic Systems for Motor Vehicles X

1992 CAA (1990) Phaseout of Lead in Gasoline and Test Procedure X
for Lead Substitutes

1992 CAA (1990) Reformulated Gasoline X

1992 CAA Registration Requirements for X Fuels and Fuel X
Additives

1992 CAA (1990) Requirements for Basic and Enhanced Inspection/ X
Maintenance Programs

1992 CAA Review of National Ambient Air Quality Standards X
for Sulfur Oxides

1992 CAA (1992) Winter Oxygenated Fuel Programs X

1985 CERCLA Proposed Revisions to the National Oil and X
CWA Hazardous Substances Pollution Control Plan

1990 CERCLA Hazard-Ranking System for Uncontrolled Hazardous X
(1986) Substance
SWDA

1990 CERCLA National Priorities List for Uncontrolled X
(1986) Hazardous Waste Sites

1990 CERCLA Procedures for Planning and Implementing Off- X
(1986) Site Response Actions
RCRA

1990 CERCLA Reportable Quantities for Releases of Hazardous X
(1986) Sustances

1992 CERCLA Reporting and Liability Exemptions for Federally X
Permitted Releases

1987 CWA Current Effluent Guidelines X

1988 CWA (1987) National Pollution Discharge Elimination System X
Sewage Sludge Permit Regulations State Sludge
Management Program Requirements

1990 CWA (1987) National Pollutant Discharge Elimination System X
(NPDES) Permit Application Regulations for
Storm-Water Discharges

1990 CWA The National Pollution Discharge Elimination X
System: General Pretreatment Regulations for
Existing and New Sources

1991 CWA Denial or Restriction of Disposal Sites in U.S. X
Waters

1991 CWA Required Clean Water Act and Safe Drinking Water X
(1987) Act Indian Regulations
SDWA
(1986)

1992 CWA (1987) Sewage Sludge Use and Disposal Regulations X

1992 CWA Water Quality Standards for Toxic Pollutants X

1992 ESA Endangered Species X
FIFRA

1987 FFDCA Scientific and Regulatory Issues Underlying X
FIFRA Pesticide Use Patterns and Agricultural
Innovation

1987 FFDCA User Charges for Pesticide Registration X

1986 FIFRA Pesticide Inert Ingredient Strategy X
FFDCA

1987 FIFRA Pesticide Registration and Classification X
Procedures (Revision)

1988 FIFRA Labeling Requirement for Pesticides and Devices X
(Revision)

1991 FIFRA Accelerated Reregistration of Pesticides X
(1988)

1991 FIFRA Pesticides in Groundwater Strategy X

1991 FIFRA Worker Protection Standards for Agricultural X
Pesticides (Revision)

1992 FIFRA Restricted-Use Classification for Groundwater- X
Contaminating Pesticides

1988 FRA Federal Radiation Protection Guidance for Public X
Exposure to Radiofrequency Radiation

1991 IRAA Radon User-Fee Rule X

1986 MPRSA Ocean Incineration Regulation X

1991 MWTA Management of Medical Waste X

1985 NWPA Environmental Radiation Protection Standards for X
Management and Disposal of Spent Fuel, High-
Level and Transuranic Radioactive Wastes

1992 OPA Oil Pollution Prevention Regulation: SPCC Phase X
CWA 1 Revisions

1985 RCRA Burning and Blending Administrative Controls: X
(1984) Burning and Blending Technical Controls

1985 RCRA Loss of Interim Status for Land-Disposal X
(1984) Facilities

1985 RCRA Standards for Storage or Treatment of Hazardous X
(1984) Waste in Tank Systems

1986 RCRA Guidance on Retrofitting Interim-Status Surface X
(1984) Impoundments

1986 RCRA Liner, Leachate Collection, and Leak Detection X
(1984) System Standards for Hazardous Waste Land
Disposal Facilities

1986 RCRA Mining Waste Regulatory Determination X

1986 RCRA Preliminary Assessment/Site Investigation X
(1984) Guidance to Implement Corrective Action
Requirements

1986 RCRA Restrictions of Land Disposal of Certain X
(1984) Hazardous Wastes

1986 RCRA Subtitle C Corrective Action Policy X
(1984)

1986 RCRA Used Oil Listing and Standards X

1987 RCRA Financial Responsibility for Corrrective Action X
(1984) for Continuing Releases at Hazardous Waste
Management Facilities

1987 RCRA Landfill, Surface Impoundment, and Waste Pile X
CERCLA Closures for Hazardous Waste Management
Facilities

1988 RCRA Double Liner and Leachate Collection Systems for X
(1984) Hazardous Waste Land Disposal Units

1988 RCRA Identification of Hazardous Wastes by Toxicity X
(1984) Characteristic and Listing of Additional Organic
Toxicants

1988 RCRA Liners and Leak Detection for Hazardous Waste X
(1984) Land Disposal Units

1988 RCRA Permit Modifications for Hazardous Waste X
Management Facilities

1988 RCRA Permitting Mobile Hazardous Waste Treatment X
Units

1988 RCRA Underground Storage Tanks -Technical X
(1984) Requirements

1990 RCRA Burning of Hazardous Waste in Boilers and X
(1984) Industrial Furnaces

1990 RCRA Corrective Action for Solid Waste Management X
(1984) Units at Hazardous Waste Management Facilities

1990 RCRA Corrective Action for Releases to Groundwater X
(1984) From Regulated Hazardous Waste Units

1990 RCRA Determination on Solid Waste X From Selected X
Metallic Ore-Processing Operations

1990 RCRA Emergency and Hazardous Chemical Inventory Forms X
(1986) and Community Right-to-Know Reporting
Requirements; Implementation of Reporting
Requirements for Indian Lands

1990 RCRA Emission Controls for Hazardous Waste X
Incinerators

1990 RCRA Location Standards for Hazardous Waste X
(1984) Facilities

1990 RCRA Mining Waste Management Under Resource X
CERCLA Conservation and Recovery Act Subtitle D

1990 RCRA Petroleum Refinery Primary Treatment Sludge X
(1984) Listing

1990 RCRA Wood Preserving and Surface Protection Waste X
Listings

1991 RCRA Groundwater Monitoring at Hazardous-Waste X
Facilities

1991 RCRA Management of Used Oil X
(1984)

1991 RCRA Solid Waste Disposal Facility Criteria X
(1984)

1992 RCRA Corrective Action for Solid Waste-Management X
(1984) Units at Hazardous-Waste Management Facilities,
Subpart S

1992 RCRA Disposal of Containerized Liquids in Hadardous- X
(1984) Waste Landfills

1992 RCRA Final Determination of the Applicability of the X
Toxicity Characteristic Rule to Underground
Storage Tanks Contaminated Media and Debris

1992 RCRA Identification and Listing of Hazardous Wastes: X
Concentration-Based Exemption Levels: Hazardous
Waste Identification Rule (HWIR)

1992 RCRA Resource Conservation and Recovery Act: Air X
(1984) Emissions From Hazardous Waste Treatment
Storage, and Disposal Facilities

1992 RCRA Underground Storage Tanks Containing Petroleum; X
(1984, Financial Responsibility Requirements; Financial
1986) Test for Self-Insurance by Local Government
Entities

1987 SARA Emergency and Hazardous Chemical Inventory Forms X
(1986) and Community Right-To-Know Reporting
Requirements

1987 SDWA Revised Primary Drinking Water Regulations for X
Volatile Synthetic Organic Chemicals (Phase I)

1987 SDWA Wellhead Protection Guidance X
(1986)

1988 SDWA Criteria for Identifying Critical Aquifer X
(1986) Protection Areas

1988 SDWA Guidelines for Classifying Groundwater Under the X
EPA Groundwater Protection Strategy

1988 SDWA National Primary Drinking Water Regulations: X
Filtration and Disinfection, Turbidity, Giardia
Lambia, Viruses, Total Coliform, Legionella, and
Heterotrophic Bacteria

1990 SDWA National Primary Drinking X Water Regulations: X
Synthetic Organic Chemical and Inorganic
Chemical, Monitoring for Unregulated
Contaminants (Phase 2, 38 Contaminants)

1990 SDWA Regulation of Corrosion Byproducts in Drinking X
Water (Lead and Copper)

1991 SDWA National Primary Drinking X Water Regulations: X
(1986) Synthetic Organic Chemical and Inorganic
Chemicals (Phase 5, 24 Contaminants)

1992 SDWA National Primary Drinking X Water Regulations: X
Radionuclides

1986 TSCA 2-Ethoxyethanol, 2-Methoxyethanol, and Their X
Acetates (Glycol Ethers)

1986 TSCA Dioxin and Furan Rulemaking X

1986 TSCA Rulemaking Concerning Asbestos Abatement X

1987 TSCA User Fees for TSCA Reviews X

1988 TSCA Action Concerning Commercial and Industrial Use X
of Asbestos

1988 TSCA Procedural Rule for Expedited New Chemical X
Followup

1988 TSCA Toxic Substances Control Act Section 8(a) X
Comprehensive Assessment Information Rule

1991 TSCA Regulatory Investigation of Chlorinated Solvents X

1992 TSCA Regulatory Investigation of X Dioxin in Pulp and X
Paper Mill Sludge

1988 UMTRCA Prevention of Significant X Deterioration (PSD) X
Increments for Nitrogen Oxides (NOx)

1992 UMTRCA Groundwater Protection Standards for Inactive X
Uranium Tailings Sites
----------------------------------------------------------------------------------------------------
Legend

J Judicial
S Statutory

AHERA Abestos Hazard Emergency Response Act
CAA Clean Air Act
CERCLA Comprehensive Environmental Response, Compensation, and
Liability Act
CWA Clean Water Act
ESA Endangered Species Act
FFDCA Federal Food, Drug, and Cosmetic Act
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FRA Federal Radiation Authority
IRAA Indoor Radon Abatement
MPRSA Marine Protection, Research, and Sanctuaries Act
MWTA Municipal Waste Treatment Act
NESHAP National Emission Standards for Hazardous Air Pollutants
NPDES National Pollution Discharge Elimination System
NSPS New Source Performance Standard
NWPA Nuclear Waste Policy Act
OPA Oil Pollution Act
PDS Prevention of Significant Deterioration
RCRA Resource Conservation and Recovery Act
SARA Superfund Amendments and Reauthorization Act
SDWA Safe Drinking Water Act
TSCA Toxic Substances Control Act
UMTRCA Uranium Mill Tailings Radiation Control Act

MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II

PROGRAM EVALUATION AND METHODOLOGY
DIVISION

Marcia Crosse, Assistant Director, (202) 512-3407
Dan Engelberg, Project Manager
Brian Ellison, Evaluator

BIBLIOGRAPHY
=========================================================== Appendix 0

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STATUTORY AND JUDICIAL DEADLINES

U.S. Executive Office of the President, OMB, Regulatory Program of
the United States Government, 1985-88, 1990-92.

Executive Order 12866: Regulatory Planning and Review, Sept. 30,
1993.

Executive Order 12291: Federal Regulation, Feb. 17, 1981.