On November 9, the Office of Management and Budget issued a revised Circular A4 giving agencies guidance on the conduct of cost-benefit analysis. I know it is hard to write a more boring first sentence to an article, but bear with me — this is important. In 1981, President Ronald Reagan issued Executive Order 12291, which required federal agencies under the president’s control to conduct a “Regulatory Impact Analysis” (RIA) when issuing regulations with an economic impact of more than $100 million in any year. The order was modified by President Bill Clinton into Executive Order 12866, but the RIA requirement was largely maintained. As part of the RIA, agencies must, to the exten
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