Trump White House quietly issues report vindicating Obama regulations

[GMDino]

https://www.vox.com/energy-and-environment/2018/3/6/17077330/trump-regulatory-agenda-omb#ampshare=https://www.vox.com/energy-and-environment/2018/3/6/17077330/trump-regulatory-agenda-omb

Quote:President Donald Trump’s administration has been on a deregulatory bender, particularly when it comes to environmental regulations. As of January, the New York Times counted 67 environmental rules on the chopping block under Trump.


This is not one of Trump’s idiosyncrasies, though. His administration is more ham-handed and flagrant about it, but the antipathy it expresses toward federal regulation falls firmly within the GOP mainstream. Republicans have been complaining about “burdensome” and “job-killing” regulations for so long that their opposition to any particular health, safety, or environmental regulation is now just taken for granted.


For instance, why would the Environmental Protection Agency close a programinvestigating the effects of toxins on children’s health? Is there some evidence that the money is wasted or poorly spent? Why would the EPA allow more unregulated disposal of toxic coal ash? Don’t people in coal regions deserve clean air and water? Is there any reason to think coal ash is currently well-regulated?


These questions barely come up anymore. Republicans oppose regulations because they are regulations; it’s become reflexive, both for the party and for the media the covers them.
One of Trump’s many executive order ceremonies, reversing Obama climate regulations. Ron Sach-Pool/Getty Images
As it happens, though, we know something about the costs and benefits of federal regulations. In fact, Trump’s own administration, specifically the (nonpartisan, at least for now) White House Office of Management and Budget (OMB), just released its annual reporton that very subject. (Hat tip to E&E.)

The report was released late on a Friday, with Congress out of session and multiple Trump scandals dominating the headlines. A cynical observer might conclude that the administration wanted the report to go unnoticed.


Why might that be? Well, in a nutshell, it shows that the GOP is wrong about regulations as a general matter and wrong about Obama’s regulations specifically. Those regulations had benefits far in excess of their costs, and they had no discernible effect on jobs or economic growth.


OMB, more like OMG, amirite?


OMB gathered data and analysis on “major” federal regulations (those with $100 million or more in economic impact) between 2006 and 2016, a period that includes all of Obama’s administration, stopping just short of Trump’s. The final tally, reported in 2001 dollars:

• Aggregate benefits: $219 to $695 billion
• Aggregate costs: $59 to $88 billion
  

By even the most conservative estimate, the benefits of Obama’s regulations wildly outweighed the costs.


According to OMB — and to the federal agencies upon whose data OMB mostly relied — the core of the Trumpian case against Obama regulations, arguably the organizing principle of Trump’s administration, is false.


Environmental regulations have the highest costs and highest benefits


At least since Reagan, conservatives have had particular and growing hostility toward environmental regulations. This has proven a source of great anguish to (older) environmentalists, who lament that such regulations used to be bipartisan.


But the right-wing turn against environmental rules is no great mystery. The OMB report reveals the core reason: Of all the regulations passed from 2006 to 2016, it is environmental regulations, specifically air pollution regulations, that had both the highest costs and the highest benefits.
OMB
EPA rules, OMB writes, “account for over 80 percent of the monetized benefits and over 70 percent of the monetized costs” of federal regulation during this period.


For example, new fuel economy standards for medium- and heavy-duty engines had (in 2001 dollars) between $6.7 billion and $9.7 billion in benefits. But they cost industry $0.8 billion to $1.1 billion.

The MATS rule, aimed at reducing toxic emissions from power plants, had between $33 billion and $90 billion in benefits (in 2007 dollars, for some reason), but it cost industry $9.6 billion.


In short, air quality rules secure enormous health benefits for the American public, but they also ask a great deal of industry.


To frame the same point another way: Air quality regulations serve as a downward redistribution of wealth, out of the pockets of industrialists and into the pockets of ordinary Americans, particularly the poor and vulnerable Americans (African Americans and Hispanics in particular) who tend to live closest to pollution sources. They shift costs, from the much higher health and social costs of pollution remediation to the comparatively smaller costs of pollution abatement.


And therein lies the source of industry and GOP rage toward EPA. It’s why EPA delayed and delayed air rules under Bush. It’s why the GOP Congress worked so furiously to block air rules under Obama. And it’s why EPA is weakening or repealing air rules as fast as possible under Trump.


The GOP is opposed to downward redistribution of wealth. If one policy goal has unified the right above all else, it is upward redistribution. Even as its base drifts further into a fog of xenophobic, reactionary ressentiment, its moneyed interests and policy leaders remain laser-focused on reducing taxes and regulatory burdens on the wealthy. Upward redistribution is what unites GOP health care policy, tax policy, financial sector policy, and environmental policy.


That is why Republicans hate EPA and its rules: They are a burden to industry, but worse, they are a burden to industry that is very obviously worth it. Industry makes a small sacrifice, public health improves, and economic growth continues apace. EPA rules are a living demonstration of the good that government can do.

Quote:[/url]


Brian Dabbs@briandabbs

.@MajorCBS : Is the philosophy …. to protect the environment or protect business. @EPAScottPruitt : Well it’s neither.

You're the head of the ENVIRONMENTAL PROTECTION Agencyhttps://www.cbsnews.com/video/scott-pruitt-talks-with-major-garrett-full-interview/ …
3:21 PM - Mar 1, 2018

Scott Pruitt talks with Major Garrett: Full interview
Environmental Protection Agency administrator Scott Pruitt talks with chief White House correspondent Major Garrett about the EPA and the first year of the Trump administration. He also argues that...
cbsnews.com

The “job-killing” thing is also nonsense


Okay, environmental regulations produce enormous health and social benefits, but don’t they kill jobs?


Not really. This is another myth that conservatives have simply repeated with such tenacity that no one bothers to scrutinize it anymore.


The OMB report has a long section looking into the employment effects of environmental regulations, assessing several studies and literature reviews. Mostly it is devoted to explaining how complex and vexed such analysis is. Jobs may be eliminated in one place/industry and created in another. Jobs may be eliminated in the short term but a larger number created in the long term. Effects on employment must be disentangled from contemporaneous social and economic trends, many of which have much larger effects. And so on.

The conclusion — which is in keeping with the broader literature, as I described in this post — is that there may be local and temporary employment effects from environmental regulations, either positive or negative, but at the aggregate national level, such regulations simply aren’t a significant factor in employment. Their effects are lost amid the noise of demographic shifts and macroeconomic drivers.


They don’t “kill jobs.” From the perspective of the overall economy, they don’t do much of anything to jobs, other than shift them from certain regions/industries to others. As it happens, those shifts are often unfavorable to GOP constituencies, but that’s not a license to, you know, lie about them.


There is no coherent policy justification for Trump’s deregulatory frenzy


If the GOP wants to explicitly align itself behind the interests of particular polluting businesses and against the broader public interest, well, it can. If it doesn’t think the costs to industry of reducing pollution are worth much larger benefits to public health, it can say so. If it wants to transfer wealth back from the public to industrialists by reversing all of Obama’s rules, that is its right as the party in power.


But GOP lawmakers shouldn’t be allowed to simply burp up the words “burdensome” and “job-killing” and move on. The OMB finds no evidence that federal regulations have any noticeable impact on aggregate national employment or economic growth. 


There is evidence that they produce public benefits well in excess of their costs.


If EPA head Scott Pruitt wants to say that defending children from toxics or rural communities from coal ash pollution is burdensome, he ought to offer some numbers, or evidence, or ... something. Goofy homilies are not enough. (His latest claim is that the Bible recommends the deregulatory agenda.)

Quote:


Emily Atkin

@emorwee

Pope Francis, on Scott Pruitt's faith-based brand of environmentalism: “This is not the correct interpretation of the Bible as intended by the Church.” https://newrepublic.com/article/147198/scott-pruitt-vs-pope …
1:12 PM - Feb 27, 2018

[url=https://t.co/NGAHzys3Kl]Scott Pruitt vs. The Pope
The EPA administrator has become the de facto spokesperson for a fringe version of Christian environmentalism.
newrepublic.com

Believing in the inherent costliness and ineffectiveness of federal regulation is not a religious matter. It’s not an article of faith. It’s an empirical assertion, an argument, and the available evidence indicates that it is incorrect.


It is certainly not a belief to which journalists owe any particular deference.


Until Trump’s administration makes a case that its own OMB and agencies are wrong — not just by a little, but by tens of billions of dollars — the presumption of every journalist and politico in Washington should be that there is no coherent policy rationale for Trump’s deregulatory agenda.



It is, like his health, tax, and infrastructure initiatives, simply the polar opposite of populism: the targeted transfer of wealth to the already wealthy, at the public’s expense.

[BmorePat87]

Lots of copypasta, here's the goodies

Quote:OMB gathered data and analysis on “major” federal regulations (those with $100 million or more in economic impact) between 2006 and 2016, a period that includes all of Obama’s administration, stopping just short of Trump’s. The final tally, reported in 2001 dollars:

Aggregate benefits: $219 to $695 billion
Aggregate costs: $59 to $88 billion
By even the most conservative estimate, the benefits of Obama’s regulations wildly outweighed the costs.

According to OMB — and to the federal agencies upon whose data OMB mostly relied — the core of the Trumpian case against Obama regulations, arguably the organizing principle of Trump’s administration, is false.

[GMDino]

(03-08-2018, 09:26 AM)BmorePat87 Wrote: Lots of copypasta, here's the goodies

Thanks Pat.  I didn't want to summarize and have people misunderstand the entire thing.

[Belsnickel]

So, to use a term from The West Wing, they threw it out with the trash to hide it. They actually addressed how putting things out on Friday was generally a time used to mask things they didn't want a lot of attention to, so it's a well known and widely used tactic. Not at all surprising that they would do this.

As to the news itself, also not surprising. I won't get all wonky on this, but this if you look at policies like this using evidence based analyses, then you know that many of the blanket anti-regulation arguments are erroneous. This isn't to say there aren't bad regulations, but so much of the disagreement in Washington has been based on partisanship (or other factors) rather than the reality of the policy. It's a frustrating situation to be in. It's not new, it's not one sided, and it's going to be difficult to fix.

[Dill]

(03-07-2018, 11:09 PM)GMDino Wrote: https://www.vox.com/energy-and-environment/2018/3/6/17077330/trump-regulatory-agenda-omb#ampshare=https://www.vox.com/energy-and-environment/2018/3/6/17077330/trump-regulatory-agenda-omb

Until Trump’s administration makes a case that its own OMB and agencies are wrong — not just by a little, but by tens of billions of dollars — the presumption of every journalist and politico in Washington should be that there is no coherent policy rationale for Trump’s deregulatory agenda.

So Trump could fix this with some different staffing at the OMB. Also, if Congress can forbid federally funded research into gun violence, I don't see why they can't do the same for virtually all regulatory agencies monitoring their own cost-effectiveness.  The data could still be made to fit the ideology, if the Trump administration gets on the ball.

[Dill]

(03-08-2018, 10:48 AM)Belsnickel Wrote: So, to use a term from The West Wing, they threw it out with the trash to hide it. They actually addressed how putting things out on Friday was generally a time used to mask things they didn't want a lot of attention to, so it's a well known and widely used tactic. Not at all surprising that they would do this.

As to the news itself, also not surprising. I won't get all wonky on this, but this if you look at policies like this using evidence based analyses, then you know that many of the blanket anti-regulation arguments are erroneous. This isn't to say there aren't bad regulations, but so much of the disagreement in Washington has been based on partisanship (or other factors) rather than the reality of the policy. It's a frustrating situation to be in. It's not new, it's not one sided, and it's going to be difficult to fix.

Can we at least grant that this partisanship regarding data collection is asymmetrical?

[Belsnickel]

(03-09-2018, 08:26 PM)Dill Wrote: Can we at least grant that this partisanship regarding data collection is asymmetrical?

Data collection? Eh, not so sure. The lack of concern for evidence based policy is certainly bipartisan. It has as much to do with the democratic system as it does asshattery.

[Dill]

(03-09-2018, 09:24 PM)Belsnickel Wrote: Data collection? Eh, not so sure. The lack of concern for evidence based policy is certainly bipartisan. It has as much to do with the democratic system as it does asshattery.

Whether the lack is asymmetrical is my question.

Can you think of any federally funded research targeted/blocked by Democrat initiatives?

Also, can you think of a policy area--housing, health, crime, climate change, farm subsidies, etc.--in which Democrats are as dismissive of evidence-based policy?

Just wondering, as I know you study policy.  Maybe you have seen something up close that those of not directly involved in government have not.

[SunsetBengal]

OMB gathered data and analysis on “major” federal regulations (those with $100 million or more in economic impact) between 2006 and 2016, a period that includes all of Obama’s administration, stopping just short of Trump’s. The final tally, reported in 2001 dollars:
Aggregate benefits: $219 to $695 billion
Aggregate costs: $59 to $88 billion


Those are some pretty huge variance ranges.  I'd really like to see a breakdown of what they consider costs and benefits, before forming an opinion.

If anyone is wise on the topic, feel free to give me the Cliff Notes version.

[Belsnickel]

(03-09-2018, 09:38 PM)Dill Wrote: Whether the lack is asymmetrical is my question.

Can you think of any federally funded research targeted/blocked by Democrat initiatives?

Also, can you think of a policy area--housing, health, crime, climate change, farm subsidies, etc.--in which Democrats are as dismissive of evidence-based policy?

Just wondering, as I know you study policy.  Maybe you have seen something up close that those of not directly involved in government have not.

Nothing is going to perfectly symmetrical. but it certainly isn't lopsided. What we have seen happen with both parties since I have been alive (so this is based on data, not on personal experience) is less reliance on the policy analysts in government, the experts in their fields, and more reliance on lobbyists and the bright shiny issues. It started earlier with Republicans, but Clinton's end of the "era of big government" played a big role in the shift for Democrats and they have caught up in this.

Both parties have opted to rely on lobbyists to feed them their figures rather than relying on wonky staffers to do research, sending their personnel to local offices to do constituent outreach so they don't have to. I'm sure this Washington brain drain, again, isn't symmetrical, but that doesn't mean either side should get any sort of credit.

[Belsnickel]

(03-09-2018, 09:41 PM)SunsetBengal Wrote: OMB gathered data and analysis on “major” federal regulations (those with $100 million or more in economic impact) between 2006 and 2016, a period that includes all of Obama’s administration, stopping just short of Trump’s. The final tally, reported in 2001 dollars:
Aggregate benefits: $219 to $695 billion
Aggregate costs: $59 to $88 billion


Those are some pretty huge variance ranges.  I'd really like to see a breakdown of what they consider costs and benefits, before forming an opinion.

If anyone is wise on the topic, feel free to give me the Cliff Notes version.

I just downloaded the report. Give me some time to look through the 100 pages and I'll get back to you.

[SunsetBengal]

(03-09-2018, 09:50 PM)Belsnickel Wrote: I just downloaded the report. Give me some time to look through the 100 pages and I'll get back to you.

Thanks!  And, while you're at it, could you explain why they are expressing the values in "2001 dollars"?  

[Belsnickel]

Chapter 1, which covers this primarily:

Quote:This chapter consists of two parts: (A) the accounting statement and (B) a report on regulatory impacts on State, local, and tribal governments, small business, and wages. Part A revises the benefit-cost estimates in last year’s Report by updating the estimates through the end of FY 2016 (September 30, 2016). As in previous Reports, this chapter uses a ten-year lookback. Estimates are based on the major regulations (for which the regulatory agency monetized both benefits and costs) that were reviewed by OMB from October 1, 2006 to September 30, 2016.8 For this reason, rules reviewed from October 1, 2005 to September 30, 2006 (FY 2006) were included in the totals for the 2016 Report but are not included in this Report. A list of these FY 2006 rules can be found in Appendix B (see Table B-1). The removal of the seven FY 2006 rules from the ten-year window is accompanied by the addition of 16 FY 2016 rules.

As has been the practice for many years, all estimates presented in this chapter are agency estimates of benefits and costs, or minor modifications of agency information performed by OMB.9 This chapter also includes a discussion of major rules issued by independent regulatory agencies, although OMB does not review these rules under Executive Order 12866.10 This discussion is based solely on data provided by these agencies to the Government Accountability Office (GAO) under the Congressional Review Act.

In the past, we have adjusted estimates to 2001 dollars, the requested format in OMB Circular A-4. We also report most of the numbers in this chapter in 2015 dollars as well, in order to provide estimates that reflect the most recent annual GDP deflator.

Aggregating benefit and cost estimates of individual regulations may produce results that are neither precise nor complete, nor, in some cases, conceptually sound. Six points deserve emphasis.

1. Individual regulatory impact analyses vary in rigor and may rely on different assumptions, including baseline scenarios, methods (including models), data, and measures of welfare changes (including approximations thereof). Summing across estimates involves the aggregation of analytical results that, for reasons we describe below, are not comparable. As one example, some agencies provide information on the stream of effects whereas other agencies provide information at specific points in time. As another, all agencies draw on the existing economic literature for valuation of reductions in mortality and morbidity, but the technical literature has not converged on uniform figures, and consistent with the lack of uniformity in that literature, such valuations vary somewhat (though not dramatically) across agencies. Later in this document we provide additional discussion of the uncertainty inherent in quantifying the value of a statistical life. More generally, OMB continues to investigate possible inconsistencies and seeks to identify and to promote best practices.

2. For comparisons or aggregations to be meaningful, benefit and cost estimates should correctly account for all substantial effects of regulatory actions including implementation periods, some of which may not be reflected in the available data. In addition to unquantified benefits and costs, agency estimates reflect the uncertainties associated with the agency’s assumptions and other analytic choices.

3. As we have noted, it is not always possible to quantify or to monetize relevant benefits or costs of rules in light of limits in existing information. For purposes of policy, non-monetized benefits and costs may be important. Some regulations have significant non-quantified or non-monetized benefits (such as protection of privacy, human dignity, and equity) and costs that are relevant under governing statutes and that may serve as a key factor in an agency’s decision to promulgate a particular rule.

4. Prospective analysis may overestimate or underestimate both benefits and costs; retrospective analysis can be important as a corrective mechanism.11 The implementation of Executive Orders 13771 and 13777, especially given the continued primacy of Executive Order 12866, requires such analysis, with the goal of improving relevant regulations through modification, streamlining, expansion, or repeal. The aim of retrospective analysis is to understand and improve the accuracy of prospective analysis and to provide a basis for potentially modifying rules as a result of ex post evaluations. Rules should be written and designed to facilitate retrospective analysis of their effects, including consideration of the data that will be needed for future evaluation of the rules’ ex post costs and benefits.

5. The OMB Circular A-4 states that “those who bear the costs of regulation and those who enjoy its benefits often are not the same people.”12 As such, agencies are encouraged to provide separate descriptions of distributive effects. For example, energy efficiency regulations tend to adversely affect lower-income consumers more than those who earn a higher income.13 If a regulation would disproportionately help or hurt particular groups of people, relevant law may require or authorize agencies to consider that fact. While analysis of these types of impacts is more limited, efforts to examine the distributive impacts of regulations is increasing. Additional analyses of this type could prove illuminating.14

6. The most fundamental purpose of an RIA is to inform policy options at the time a regulatory decision is being made; however, analytic approaches that serve this purpose may not readily lend themselves to aggregation. For example, suppose the Occupational Safety and Health Administration (OSHA) issues a regulation reducing the permissible exposure level (PEL) for some toxin. OSHA estimates regulatory benefits based on a projection that the affected industries will comply by changing their production processes to entirely avoid using inputs that contain the toxin. If OSHA subsequently revises the regulation and, at the time of the revision, the best available evidence shows that exposure to the toxin has not been entirely eliminated, the RIA for the new rule would appropriately calculate benefits or forgone benefits using the more recent exposure data, even though a multi-year sum of the estimated effects of OSHA rules would yield an inaccurate cumulative total as a result. For example, if the new rule further reduces the PEL, some health and longevity benefits that were already tallied in the first rule would be double counted in an aggregation of the second rule’s RIA with the first rule’s. Analogously, if the new rule increases the PEL, forgone benefits would be substantially overestimated if the original RIA’s projection of zero exposure were carried forward into the new RIA in spite of the more recent empirical evidence.

There is a ton more in the document (these are pages 5-9 and don't include the footnotes). The tl;dr version is that these estimates are primarily provided by the agencies to OMB, which is then compiled in this report. There are some adjustments made in analysis by OMB, but that is only a small portion of what is presented.

These ranges reflect only the costs and benefits that can actually be quantified. Those that cannot be quantified are not included.

Now, analyses like this are always going to be based on a range because analysts, as much as we like to think we can, cannot predict the future. These ranges are based on statistical modelling and will have a margin of error and a confidence level attached to them. The range is likely so large because that is what puts them in the 95% confidence level, which is typically the standard. What this means is that the in 95% of the scenarios they could run, the costs and benefits will fall within those ranges. Yes, there is [generally] wiggle room in there, but that is accounting for anomalies and outliers and what would actually happen has a slimmer than 5% chance of actually falling outside of those ranges.

[Dill]

(03-09-2018, 09:48 PM)Belsnickel Wrote: Nothing is going to perfectly symmetrical. but it certainly isn't lopsided. What we have seen happen with both parties since I have been alive (so this is based on data, not on personal experience) is less reliance on the policy analysts in government, the experts in their fields, and more reliance on lobbyists and the bright shiny issues. It started earlier with Republicans, but Clinton's end of the "era of big government" played a big role in the shift for Democrats and they have caught up in this.

Both parties have opted to rely on lobbyists to feed them their figures rather than relying on wonky staffers to do research, sending their personnel to local offices to do constituent outreach so they don't have to. I'm sure this Washington brain drain, again, isn't symmetrical, but that doesn't mean either side should get any sort of credit.

I think I understand a little better what you mean, regarding both sides affinity for lobbyists who already shape information/issues for their targets. And then both sides are prone to use this "shaped" research for policy decisions.

Still, I can't think of an instance in which the Dems have actually blocked federally funded research in critical areas like gun stats and climate change.

[Belsnickel]

(03-09-2018, 09:53 PM)SunsetBengal Wrote: Thanks!  And, while you're at it, could you explain why they are expressing the values in "2001 dollars"?  

Typically, when looking at multiple years we like to use a baseline for the dollar value to compensate for the impacts of inflation.

[Belsnickel]

(03-09-2018, 10:04 PM)Dill Wrote: I think I understand a little better what you mean, regarding both sides affinity for lobbyists who already shape information/issues for their targets. And then both sides are prone to use this "shaped" research for policy decisions.

Still, I can't think of an instance in which the Dems have actually blocked federally funded research in critical areas like gun stats and climate change.

Oh, yeah, they like to throw money at those things but then they don't rely on the research as much as they should.

[SunsetBengal]

(03-09-2018, 10:05 PM)Belsnickel Wrote: Typically, when looking at multiple years we like to use a baseline for the dollar value to compensate for the impacts of inflation.

I get why they use a specific base point.  But why 2001?  The dollar was really strong, then.  Why not 2008, when Obama took charge?  The dollar was pretty weak, at that point.

[BmorePat87]

(03-09-2018, 10:14 PM)SunsetBengal Wrote: I get why they use a specific base point.  But why 2001?  The dollar was really strong, then.  Why not 2008, when Obama took charge?  The dollar was pretty weak, at that point.

I'm not sure why 2001 was chosen as the specific baseline, but just to clarify the report is for 2006-2016, so it's not just Obama (just mostly Obama )

[SunsetBengal]

(03-09-2018, 11:02 PM)BmorePat87 Wrote: I'm not sure why 2001 was chosen as the specific baseline, but just to clarify the report is for 2006-2016, so it's not just Obama (just mostly Obama )

Yeah, I don't understand.  Heck, if I measure my income in 2001 dollars, I'm doing well.  If I use today's dollar, I'm struggling.

[Belsnickel]

(03-09-2018, 11:05 PM)SunsetBengal Wrote: Yeah, I don't understand.  Heck, if I measure my income in 2001 dollars, I'm doing well.  If I use today's dollar, I'm struggling.

That's not really how it works. If you had $100 last year, it's value in 2001 dollars was $72.35. So when you look at your income based on 2017 dollars it looks better than 2001 dollars. Am I making sense?

As for why choose that year, a strong dollar base is a good one to choose, but honestly it could've just been as simple as it being the first year of the millennium. You don't want to use a year in the range, so 2001 makes sense for a number of reasons.