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Regulatory Impact Analysis Guidelines: Introduction to Special Issue

Published online by Cambridge University Press:  24 July 2025

Susan E. Dudley Open the ORCID record for Susan E. Dudley [Opens in a new window]  and
Thomas Kniesner Open the ORCID record for Thomas Kniesner [Opens in a new window]
Susan E. Dudley*
Affiliation:
Trachtenberg School of Public Policy and Public Administration, GW Regulatory Studies Center, George Washington University, Washington, DC, USA
Thomas Kniesner
Affiliation:
Economics, Claremont Graduate University, Claremont, CA, USA
*
Corresponding author: Susan E. Dudley; Email: sdudley@gwu.edu
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Abstract

This article provides a brief Introduction to this special Journal of Benefit–Cost Analysis issue dedicated to comments filed by former presidents of the Society for Benefit Cost Analysis and editors of this journal on the Office of Management and Budget’s draft Circular A–4 on regulatory impact analysis guidelines.

Keywords

benefit-cost analysisbest practicesregulatory impact analysisD6H4

Information

Type
Introduction
Information
Journal of Benefit-Cost Analysis , Volume 16 , Special Issue S2: Regulatory Impact Analysis Guidelines , Summer 2025 , pp. 150 - 151
Creative Commons
Creative Common License - CCCreative Common License - BY
This is an Open Access article, distributed under the terms of the Creative Commons Attribution licence (http://creativecommons.org/licenses/by/4.0), which permits unrestricted re-use, distribution and reproduction, provided the original article is properly cited.
Copyright
© The Author(s), 2025. Published by Cambridge University Press on behalf of Society for Benefit-Cost Analysis

This is an unusual issue of the Journal of Benefit–Cost Analysis in that each of the articles (except for the last one) was initially submitted as a public comment to the Office of Management and Budget (OMB) on its proposed revisions to the federal government’s guidance on conducting regulatory impact analysis, “Circular A-4.”

OMB issued draft revisions to Circular A-4 in June 2023. Its request for comment yielded almost 4,500 submissions, but most of those were associated with mass comment campaigns, followed a template, and shared identical or nearly identical content (Xie et al., Reference Xie, Hay and Hirsch2023). The comments OMB received included 185 unique submissions that contained substantive content. In addition to this public request for comment, OMB solicited peer review comments from a select group of experts on specified issues. In November 2023, OMB released a final Circular; however, in February 2025, OMB revoked it and reinstated the 2003 Circular.

Several former presidents of the Society for Benefit–Cost Analysis and editors of the Journal of Benefit–Cost Analysis provided input on the draft Circular, either as peer reviewers or through public comments. In addition, all former SBCA presidents sent a letter to OMB commenting on the draft guidelines. Because elected presidents of the Society for Benefit–Cost Analysis and editors of this Journal bring unique expertise on the subject of regulatory impact analysis, this issue reproduces their comments as submitted. In addition, each author has supplemented their original submission with a prologue and/or epilogue. The Society for Benefit–Cost Analysis does not take institutional positions on issues, and these articles reflect the views of their respective authors.

The issue begins with an August 2023 letter from all the former presidents of the Society and several of the editors of the Journal to OMB’s Administrator of the Office of Information and Regulatory Affairs, Ricky Revesz. In the second article, Glenn Blomquist provides a synopsis of feedback on key issues from OMB’s selected panel of peer reviewers and compares that to the final 2023 Circular. Articles by each of the former SBCA and JBCA officials follow, in order of their service. A final article, by Febrizio, Hay, and Xie, provides a comparison of the draft and final Circulars.

  1. 1. Letter from former SBCA Presidents and JBCA editors

  2. 2. Glenn Blomquist* (SBCA 2022, JBCA)

  3. 3. Joseph Cordes* (SBCA 2012)

  4. 4. Lisa Robinson (SBCA 2014)

  5. 5. W. Kip Viscusi* (SBCA 2015)

  6. 6. Donald Kenkel (SBCA 2018)

  7. 7. Susan Dudley (SBCA 2016)

  8. 8. Dale Whittington (SBCA 2021)

  9. 9. Glenn Blomquist* (SBCA 2022, JBCA)

  10. 10. Scott Farrow* (JBCA)

  11. 11. Febrizio, Hay & Xie Comparing the Draft and Final Circular A-4

* indicates invited peer reviewer.

References

Xie, Zhoudan, Hay, Sarah, and Hirsch, Henry. 2023. “Care to Comment? Topics Discussed in Revised Circular A4 Public Comments.” Regulatory Policy Commentary, the George Washington University Regulatory Studies Center. https://regulatorystudies.columbian.gwu.edu/care-comment-topics-discussed-revised-circular-a4-public-comments.Google Scholar