On Balance: U.S. Army Corps of Engineers Proposes Agency Specific Procedures (ASPs) for the Corps' Implementation of the Principles, Requirements, and Guidelines for Water Resources Investments

As a community of practice, we have the opportunity and even the responsibility to provide input during comment periods for federal and state agencies rule making prior to becoming entrenched in agency policy and application tools. One of these opportunities is currently open in the Federal Register for the US Army Corps of Engineers. The Army has broad responsibility and authority to build, maintain, enhance, and manage flood protection and reservoir projects across the country. The Army has been using a form of benefits exceeding costs test since the introduction of their first projects in the early 1900’s. The 2020 Water Resources Development Act instigated a re-evaluation of what is included in the army’s efficiency analysis and references many of the issues addressed at the last several SBCA conferences. Social and environmental costs are being discussed and how these and other concept can and should be quantified, qualified, and considered in alternatives analysis and final funding processes. This (SBCA) community of practice’s expertise on these topics, as well as the technical mechanics of BCA, valuation methods, and social welfare optimization make each of you a valuable contributor for the army as they collect comments and information to help them formulate practices and rules. Please consider reviewing the current solicitation for comments to ensure, those that know and do, are providing input, and that as a community we are helping guide the framework of the ecosystem within which many, with less experience and training, will be asked to participate on the project level.

Comments must be received on or before April 15, 2024Learn more>> or contact Duane.

On Balance: Some Clarifications Regarding Distributional Weighting

The proposed revisions to Circular A-4 recently put forward by the Office of Information and Regulatory Affairs include guidance on applying what are referred to as "distributional weights." Costs and benefits to households and individuals with lower income are multiplied by a number greater than one, while those to households and individuals with higher income are multiplied by a number less than one. In the public comments on the proposed revisions, a number of criticisms of distributional weighting have been put forth, including:

  • Distributional weighting conflates information about welfare with information about equity, undermining transparency.
  • Distributional weighting introduces subjective value judgments into BCA;
  • Distributional weighting puts a finger on the scale.

In our paper (Acland and Greenberg, 2023), we explicitly recommend that distributional weighting of the sort presented in the proposed revisions be adopted by federal agencies. As such, we feel that some clarification of our position is in order, in the hope that these criticisms may be better understood and laid to rest.

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On Balance: Benefit-Cost Analysis of Air Pollution, Energy, and Climate Regulations

Regulations to improve air quality, save energy, or reduce climate risks account for the largest share of benefits and costs of the US regulatory program.  We address the economic methods for evaluating this class of regulations in “Benefit-Cost Analysis of Air Pollution, Energy, and Climate Regulations.  This work was recently published as open access in the Cambridge Core Element Series in public economics. The methods considered are relevant for OMB’s ongoing revision of BCA guidance (Circulars A-4 and A-94), and EPA’s proposed changes for measuring the economic benefits of reducing greenhouse gas emissions.  

The work compares and contrasts Regulatory Impact Assessment (RIA) in the U.S. and Europe, and addresses five methodology issues: the estimation of costs, the estimation of benefits, discounting methods, distributional analysis, and the evaluation of less and more fundamental uncertainty. The intended audience is regulators and other constituencies interested in the nexus between scholarship and practice, analysts in government agencies and research organizations, and academic scholars and their graduate students.

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On Balance: How Is the US Pricing Carbon? How Could We Price Carbon?

Economists have for decades recommended that carbon dioxide and other greenhouse gases be taxed to provide incentives for their reduction. The United States does not have a federal carbon tax; however, many state and federal programs to reduce carbon emissions effectively price carbon—for example, through cap-and-trade systems or regulations. There are also programs that subsidize reductions in carbon emissions. At the 2022 meetings of the American Economic Association, the Society for Benefit-Cost Analysis brought together five well-known economists—Joe Aldy, Dallas Burtraw, Carolyn Fischer, Meredith Fowlie, and Rob Williams—to discuss how the United States does, in fact, price carbon already and how it could do so more effectively. Maureen Cropper chaired the panel.

Meredith Fowlie discussed problems that a carbon tax would present if levied on the US energy sector. As Fowlie pointed out, setting a carbon tax equal to the social cost of carbon assumes that the prices of carbon-intensive goods reflect suppliers’ marginal private costs. In many US states, however, regulated retail electricity and natural gas prices exceed marginal supply costs—in the case of electricity, sometimes by a factor of two to three. Electricity prices have risen to cover the costs of upgrading generation, transmission, and distribution systems and making the grid more resilient to extreme weather events. Adding a carbon tax to these prices would slow the pace of electrification for the clean energy transition and would burden low-income households. Fowlie discussed these issues and suggested that retail rate reform is needed.

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On Balance: Major Questions about West Virginia v. EPA and Benefit-Cost Analysis

On June 30, 2022, the Supreme Court of the United States decided West Virginia v. Environmental Protection Agency. The case was about whether EPA in the Clean Power Plan could set the carbon emissions standard for existing power plants at a level that would require the power plants to reduce coal use and shift to or subsidize natural gas or renewable-energy electricity generation (referred to as “generation shifting”). But the focus was not on whether such a level would be benefit-cost justified—but rather on whether the agency was allowed to set a standard requires generation shifting for compliance under this provision of the Clean Air Act. Writing for the majority, Chief Justice Roberts applied the “major questions” doctrine and concluded that EPA could not do this despite reasonable textual support for it; on issues like this one, which have “vast economic and political significance,” Congress must clearly authorize an agency to act in this way.

It is tempting to conclude that this decision about statutory interpretation has no relevance for benefit-cost analysis (BCA). But unfortunately, the decision contains language that suggests the Court misunderstands and disregards the value of using BCA in federal regulatory policy.

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On Balance: SBCA Continues to Expand Its Worldwide Influence

The primary way the Society pursues its mission to improve the theory and practice of benefit-cost analysis is by bringing people together, particularly during its annual meetings held each March. It is therefore very rewarding to note the recent increases in conference attendance and the associated increases in Society membership.

The first Society conference took place in 2008 and drew 79 people (Table 1). Attendance has grown steadily since then. In particular, the move to an online format in 2021 and 2022 resulted in very large increases in attendance, with attendance topping 600 people.

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On Balance: China's Belt and Road Initiative: New Research Agenda in Cost-Benefit Analysis

China is investing trillions of dollars in hundreds of projects, mainly infrastructures under its Belt and Road Initiative. This Initiative termed the BRI seeks to increase trade and contribute to global economic growth through increased connectivity, ports' development, building transport networks, pipelines, and other major infrastructures stretching from the northwestern part of China through Central Asia and Middle East through Africa and onwards to Europe.

We discuss some implications of this BRI in the context of new developments and key challenges it faces, not widely covered in the literature. Specifically, we identified three major areas which require immediate attention if any success of the BRI is to materialize. Such new areas may constitute the new research agenda for Cost-Benefit Analysis. One concern is the issue of NIMBYs (Not In My Backyard) which essentially deals with siting decisions. The second concern has to do with applying Cost-Benefit Analysis to BRI countries and that is whether the framework of conventional Cost-Benefit Analysis remain the same as with applications in developed countries. And, thirdly, the arrival of competing initiatives from the United States and European Union on the BRI. We discuss some conflict resolution instruments to siting issues and the role of auctions. Highlights from the new Health and Digital Silk roads are also presented.

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On Balance: Best Practices for Using Hedonic Property Value Models

Hedonic property value regression is a leading technique for estimating how much consumers are willing to pay for nonmarket amenities. The prevailing style of estimation has evolved in recent years to incorporate insights from the “credibility revolution” in applied economics, with high expectations for data quality and econometric transparency. At the same time, recent research has improved our understanding of how parameters identified by quasi-experimental designs relate to welfare measures. This post describes an article summarizing modern best practices for developing credible hedonic research designs and valid welfare interpretations of the estimates. I wrote the article together with Kelly Bishop, Spencer Banzhaf, Kevin Boyle, Kathrine von Gravenitz, Jaren Pope, Kerry Smith, and Christopher Timmins. It was published in the Summer 2020 issue of the Review of Environmental Economics and Policy as part of a symposium on best practices for using revealed preference methods for nonmarket valuation of environmental quality. A 20-minute video summary is posted here.

There have been thousands of hedonic property value studies since the model was formalized in the 1970s and the pace has accelerated due to advances in data, econometrics, and computing power. The model’s enduring popularity is easy to understand. It starts with an intuitive premise that is economically plausible and empirically tractable. The model envisions buyers choosing properties based on housing attributes (e.g., indoor space, bedrooms, bathrooms) and on location-specific amenities (e.g., air quality, park proximity, education, flood risk). In the absence of market frictions, spatial variation in amenities can be expected to be capitalized into housing prices. When buyers face the resulting menu of price-attribute-amenity pairings, their purchase decisions can reveal their marginal willingness to pay (MWTP) for each of the amenities. In principle, estimating MWTP is straightforward. In practice, several key modeling decisions must be made. These include defining the market, choosing appropriate measures of prices and amenities, selecting an econometric specification, and developing a research design that isolates exogenous variation in the amenity of interest.

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On Balance: Modernizing Regulatory Review

Modernizing Regulatory Review, a Presidential memorandum published January 20, 2021, serves as a preface to the regulatory policies of the Biden Administration. As such, the memorandum complements three executive orders (E.O 13993: Revocation of Certain Executive Orders Concerning Federal Regulation; E.O. 13990: Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis; and E.O. 13979: Ensuring Democratic Accountability in Agency Rulemaking) that collectively rescind the previous administration’s regulatory policy. The regulatory policy foreshadowed in the memorandum and other documents, however, goes beyond rescinding the Trump administration’s program or restoring previous regulatory regimes.

Modernizing Regulatory Review calls for “improving and modernizing” regulatory review. Regulatory review includes, among other things, the benefit-cost and other analyses that Executive Order 12866 (Regulatory Planning and Review) requires for all significant executive branch regulations; agencies include these analyses in the Regulatory Impact Analyses or Economic Analyses reviewed by the Office of Information and Regulatory Affairs. Regulatory review as now practiced has been in place for 28 years, although there have been occasional hiccups, such as in the last administration when -- most notably -- E.O. 13771 made regulatory costs primary and created new regulatory categories in parallel to existing measures.

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On Balance: Quantifying the Non-Use Value of Biodiversity in Cost–Benefit Analysis

What is important cannot be measured?
According to a famous expression1, the most important things cannot be measured. This seemed also to be true for biodiversity in cost-benefit analysis, in particular for the impact on non-economic benefits of biodiversity. However, this is not true anymore, as for over a decade in the Netherlands a methodology known as biodiversity points is being applied for this purpose (see Bos and Ruijs, 2021). Biodiversity points are quite similar to the quality-adjusted life years (QALY) used for cost-effectiveness analysis of health care treatments. Biodiversity points provide a quality-adjusted measure of the changes in the quantity of biodiversity. It is not based on the preferences and information of consumers or citizens, but is based in a standardized way on the expert-opinion of ecologists. The unit of measurement is not dollars or euros but is the number of biodiversity points.

For many cost-benefit analyses (CBA), properly assessing the welfare effects of a policy measure on biodiversity is important. This does not only apply to CBA on conservation or stimulation of biodiversity, but also to CBA on other policy areas such as mobility, agriculture and water safety, as the policy measures in these policy areas often have impacts on biodiversity. For example, a new road connecting two cities through a forest is good for mobility but has also impact on the value of biodiversity. The value of the forest for various economic uses may increase due to the reduction in travel time for visitors but the non-use value, e.g. the existence value and the value for future generations of the forest and the biodiversity of its species, may be affected severely by fragmenting the forest and by increasing traffic, pollution and visitors.

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On Balance: Using Social Media and Machine Learning for Violence Prevention

The revelations of the Facebook Files have again focused public attention on the spread of misinformation, hate speech and incitement to violence on Facebook. Youths across the globe use Facebook's Instagram and similar platforms to share violent videos. The question inevitably arises if authorities could use these platforms for violence prevention.

Bystander programs represent an established prevention measure. They motivate people to intervene in violent situations and teach the skills for safe and effective intervention. Studies suggest that bystander programs could reduce violent victimization and perpetration. However, face-to-face programs are cost-intensive and difficult to scale. Online programs face the challenge of reaching enough relevant participants. Social media can help on both counts. They allow reaching large audiences at relatively low cost and precisely addressing individuals at risk, i.e. micro-targeting.

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On Balance: So You Want to Conduct a Benefit-Cost Analysis? Experts Share Their Stories

This blog series is a partnership of the Society for Benefit-Cost Analysis On Balance blog and Dr. Zoë Plakias’ Spring 2021 Benefit-Cost Analysis (AEDECON 5330) class at The Ohio State University. Students interviewed experts in benefit-cost analysis to learn about what they do and why they do it. All interviews have been edited for brevity and clarity with the help of Dr. Plakias and are shared with the approval of the interviewer and interviewee.

  • Expert: Dr. Charles Griffiths
  • Interviewer: Katrina Hadley

Dr. Charles Griffiths is a Senior Economist at the U.S. Environmental Protection Agency. He has also taught courses on benefit-cost analysis at Johns Hopkins University and the University of Maryland and served as a Senior Economist for Environment, Energy and Natural Resources on the Council of Economic Advisers during the George W. Bush administration.

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On Balance: Why aren’t BCAs Done in Sweden for Environmental, Energy and Climate Policy? And Can Something Be Done About It?

Monetizing the impact of regulation in order to weigh its benefits against its costs is comme il faut in the US, see, e.g., a recent blog post by Dan Ackland in On Balance. In Sweden, this is not the case. Three laws govern the requirements for background analyses ahead of regulation in Sweden: National Budget Law, Authority Regulation, and Ordnance on impact assessment in regulation. These stipulate that consideration must be taken of costs to the state budget, and to firms, but not to individual citizens or the society as a whole. As a consequence, if a benefit-cost analysis (BCA) is conducted ahead of environmental, energy, and climate policymaking (a big if), it is often of a very poor quality (Swedish Environmental Protection Agency, 2020; Hammes, Nerhagen, & Fors, 2021).


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On Balance: BCA, the Choice of Numéraire, and Weighted BCA

Benefit-cost analysis, as usually practiced, sums the monetary values of effects on individuals. It can be justified by the potential compensation test: if the total monetary gain to the “winners” (those who gain from a policy) exceeds the total monetary loss to the “losers” (those who are harmed), the “winners” could (in principle) pay compensation to the “losers” so that everyone would judge herself better off with the combined policy and compensation than without. The idea is that by summing the net benefits across individuals, BCA measures “efficiency” or the size of the social pie, and that questions about distribution can be evaluated separately. Logically, policies that expand the social pie permit everyone to have a bigger slice; a smaller pie guarantees that at least some people get a smaller slice. 


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On Balance: Benefit and Cost Considerations in Evidence-Based Foreign Policy

Over the course of the past few years, there has been greater attention and scrutiny as to the high cost of America’s “Endless Wars” and over the past few months, alarms have sounded at the estimated price tag of $2.313 trillion in treasure and approximate 243,000 in direct lives lost from the War in Afghanistan (2021, Brown University, Watson Institute Costs of War Project) as well as calls for resignations at the collapse of Kabul. Similarly, the question of what were the benefits, if any at all, and the associated and more philosophical question of “Was it Worth it?” are even more difficult to explain and justify. The answer to these questions will be for each individual and generation to ponder, but it is expected that government leaders and policymakers should fully consider and take into account the benefits and costs prior to the declaration of war – not years and certainly not decades after the fact.


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On Balance: So You want to Conduct a Benefit-Cost Analysis? Experts Share Their Stories

This blog series is a partnership of the Society for Benefit-Cost Analysis On Balance blog and Dr. Zoë Plakias’ Spring 2021 Benefit-Cost Analysis (AEDECON 5330) class at The Ohio State University. Students interviewed experts in benefit-cost analysis to learn about what they do and why they do it. All interviews have been edited for brevity and clarity with the help of Dr. Plakias and are shared with the approval of the interviewer and interviewee.

  • Expert: Dr. James Hammitt
  • Interviewer: Loryssa Lake

Dr. James Hammitt is a Professor of Economics and Decision Sciences at Harvard University. He is also the director for the Harvard Center for Risk Analysis and has affiliations with the Harvard University Center for the Environment, Harvard School of Public Health, Harvard Center for Risk Analysis, Harvard Environmental Economics Program, the Harvard China Project, and a joint appointment at the Toulouse School of Economics

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On Balance: So You want to Conduct a Benefit-Cost Analysis? Experts Share Their Stories

This blog series is a partnership of the Society for Benefit-Cost Analysis On Balance blog and Dr. Zoë Plakias’ Spring 2021 Benefit-Cost Analysis (AEDECON 5330) class at The Ohio State University. Students interviewed experts in benefit-cost analysis to learn about what they do and why they do it. All interviews have been edited for brevity and clarity with the help of Dr. Plakias and are shared with the approval of the interviewer and interviewee.

  • Expert: Dr. Sandra Hoffmann
  • Interviewer: Melissa Ferruso

Dr. Sandra Hoffmann is a Senior Economist with the Food Economics Division of the USDA Economic Research Service (ERS). She received her undergraduate education at Iowa State University and went on to earn a J.D. from the University of Michigan Law School. She holds a Ph.D. from the Department of Agricultural and Resource Economics, University of California, Berkeley and an M.A. in Agricultural Economics from the University of Wisconsin-Madison.  She worked on pesticide regulation as an attorney.  She also served on faculty at the University of Wisconsin-Madison and was a research fellow at Resources for the Future before joining USDA Economic Research Service. Most of her work with the USDA concentrates on food safety and on valuation of the health benefits related to public policies. I had the wonderful opportunity to meet with Dr. Hoffmann to discuss her work with the USDA, as well as the career and education paths that brought her to where she is today.

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On Balance: 120 Million Crimes in the US in 2017 Imposed Losses Valued at $2.6 Trillion: First Estimates of Total Costs in 25 Years

Benefit-cost analyses of criminal justice policies, early childhood education, at-risk youth programs, and other interventions that reduce crime have moved beyond the academic arena into applications by both state and federal policy makers (Welsh, Farrington, & Gowar, 2015). Despite this growing interest in benefit-cost analysis, our recent article in the Journal of Benefit-Cost Analysis (Miller, Cohen, Swedler, Ali, & Hendrie, 2021), provides the first estimates in 25 years of the numbers and total costs of crime against individuals in the US. 


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On Balance: So You want to Conduct a Benefit-Cost Analysis? Experts Share Their Stories

This blog series is a partnership of the Society for Benefit-Cost Analysis On Balance blog and Dr. Zoë Plakias’ Spring 2021 Benefit-Cost Analysis (AEDECON 5330) class at The Ohio State University. Students interviewed experts in benefit-cost analysis to learn about what they do and why they do it. All interviews have been edited for brevity and clarity with the help of Dr. Plakias and are shared with the approval of the interviewer and interviewee.

  • Expert: Lisa A. Robinson
  • Interviewer: Katherine Bowman

Lisa A. Robinson is Deputy Director of the Center for Health Decision Science and Senior Senior Research Scientist at the Center for Health Decision Science and Center for Risk Analysis at the Harvard T.H. Chan School of Public Health. She served as the President of the Society for Benefit-Cost Analysis in 2014.

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On Balance: What Should OIRA Do about Equity, Justice, Dignity and Moral Responsibility?

On his first day in office, President Biden issued a memorandum titled “Modernizing Regulatory Review,” directing the director of the Office of Management and Budget to produce a set of recommendations for how to improve regulatory review. 

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