“Even if cost-benefit analysis is theoretically a neutral tool. . . it is biased against strong public protections.”

Recently, NHTSA announced statistics for 2016 traffic fatalities:

  • 37,461 people killed in crashes on U.S. roadways in 2016
  • Up 5.6% from 2015
  • Tucked in the back of the report, if you look for it, you will see that there were 4,317 fatalities in crashes involving large trucks — up 5.4% from 2015, the highest since 2007.
  • Of those, 722 (16.7%) were occupants of large trucks and 10.8% were nonoccupants
  • 72.4% of the truck crash fatalities were occupants of other vehicles, or 3,125.5 (Do I round that up to 3126? Now that really bothers me because this is about people who died in a crash with a truck last year and not merely statistics!)

If you look at NHTSA’s press release, here is their summary:

The 2016 national data shows that:

  • Distraction-related deaths (3,450 fatalities) decreased by 2.2 percent;
  • Drowsy-driving deaths (803 fatalities) decreased by 3.5 percent;
  • Drunk-driving deaths (10,497 fatalities) increased by 1.7 per­cent;
  • Speeding-related deaths (10,111 fatalities) increased by 4.0 percent;
  • Unbelted deaths (10,428 fatalities) increased by 4.6 percent;
  • Motorcyclist deaths (5,286 fatalities – the largest number of motorcyclist fatalities since 2008) increased by 5.1 percent;
  • Pedestrian deaths (5,987 fatalities – the highest number since 1990) increased by 9.0 percent; and
  • Bicyclist deaths (840 fatalities – the highest number since 1991) increased by 1.3 percent.

Do you see the 4,317 truck crash fatalities mentioned there? I don’t! Yet they accounted for 11.5% of the total traffic fatalities.

Is that indicative of what I tend to observe — the truck crash fatalities are considered a transportation issue and left to the trucking industry to solve? And so potential lives saved always lose out in any cost/benefit analysis, and we all know who ends up paying the price for this unresolved public health & safety crisis.

Along that line, check out this interesting read about cost/benefit analysis (which agencies have to do in rulemaking) related to safety regulations. . . https://www.foreffectivegov.org/node/2332

Even given the many uncertainties of cost-benefit analysis, proponents still argue that it acts as a neutral tool. Yet, as David Driesen points out, “if CBA only makes regulation weaker, and never strengthens overly weak regulation, it cannot improve priority setting and consistency in the manner its proponents envision.” Driesen lays to rest the argument of CBA’s neutrality by dissecting the use of CBA both in practice and theory. Driesen finds that both in OMB’s implementation of cost-benefit analysis as well as in the assumptions of the cost-benefit analysis itself, CBA is weighted in favor of the regulated industry and against health, safety and environmental protections.
 
Driesen focuses his look at cost-benefit analysis on the role of the Office of Information and Regulatory Affairs (OIRA), a subagency of the Office of Management and Budget (OMB) charged with carrying out cost-benefit analysis through Executive Order 12866. According to a Government Accountability Office (GAO) report, between June of 2001 and July of 2002, OMB “significantly affected 25” environmental, health and safety regulations. If cost-benefit analysis is in practice a neutral tool, then OIRA’s use of cost-benefit analysis to review regulation would sometimes strengthen protections and sometimes weaken them. Driesen found that none of OIRA’s changes made environmental, health or safety protections more stringent, and 24 out of the 25 weakened protections. Even if cost-benefit analysis is theoretically a neutral tool, in the hands of this administration, it is certainly biased against strong public protections.
 
 OMB tends to see cost-benefit analysis as a criterion under which the cost of implementing a regulation can never exceed the benefit. Another option is that cost-benefit analysis is used as a criterion under which cost must always equal benefit, optimizing the efficiency of the regulation. Driesen shows that in each case cost-benefit is not a neutral tool and will always favor the regulated community over the health, safety and environmental regulation.
 
Previous posts on this issue:

Leave a Reply

Your email address will not be published. Required fields are marked *