Sally Katzen


cost benefit analysis (CBA), rational regulatory decision making, Office of Management and Budget (OMB), administrative law


The Article addresses the criticism of cost benefit analysis (CBA). Although it accepts the monetization of costs will generally oppose regulation, it finds CBA is at least close to an objective standard. It argues the results of CBA are informative, but are not dispositive, and often the procedures used in CBA are imperfect. It concludes financial resources should be devoted to retrospective analyses and/or organization studies in order to achieve rational regulatory decision making.



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