EA - Planned Updates to U.S. Regulatory Analysis Methods are Likely Relevant to EAs by MHR
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Link to original articleWelcome to The Nonlinear Library, where we use Text-to-Speech software to convert the best writing from the Rationalist and EA communities into audio. This is: Planned Updates to U.S. Regulatory Analysis Methods are Likely Relevant to EAs, published by MHR on April 7, 2023 on The Effective Altruism Forum.The U.S. Office of Management and Budget (OMB) has proposed an update to Circular A-4, which provides guidance to federal agencies regarding methods of regulatory analysis. Changes to analysis methodology could substantially impact the type and content of future regulations, and the 2022 Legal Priorities Project writing competition examined potential ways to improve such analysis methods from an EA perspective.OMB's proposed update makes a significant number of changes to circular A-4. I have only taken a brief look at the proposal, but several sections seem quite significant for EA causes. in general, the proposed changes appear to benefit policies that improve future wellbeing, prevent catastrophic risks, and/or (in certain circumstances) improve the wellbeing of people outside the United States.Catastrophic RisksThe proposed update adds explicit discussion of catastrophic risks, which are not mentioned in the current version of Circular A-4. The updated guidance allows for the consideration of impacts on future generations when analyzing the benefits of policies that reduce the chance of catastrophic risks.The time frame for your analysis should include a period before and after the date of compliance that is long enough to encompass all the important benefits and costs likely to result from the regulation.19 See the section “Discount Rates†for more details on the appropriate time frame for an analysis. If benefits or costs become more uncertain or harder to quantify over time, that does not imply that you should exclude such effects by artificially shortening your analytic time frame; instead, consult—as appropriate—the discussion in the section “Treatment of Uncertainty.â€[19] For example, when assessing the benefits of a regulation that could prevent a catastrophic event with some probability, it may be appropriate for you to consider not only the near-term effects of averting the catastrophic event on those who would be immediately affected, but also the long-run effects on others—including future generations—who would be affected by the catastrophic event.Geographic Scope of AnalysisThe proposed update allows for the consideration of impacts to non U.S. citizens residing abroad as part of the primary analysis in certain circumstances, which was not allowed in the previous guidance.In certain contexts, it may be particularly appropriate to include effects experienced by noncitizens residing abroad in your primary analysis. Such contexts include, for example, when:Assessing effects on noncitizens residing abroad provides a useful proxy for effects on U.S. citizens and residents that are difficult to otherwise estimate;Assessing effects on noncitizens residing abroad provides a useful proxy for effects on U.S. national interests that are not otherwise fully captured by effects experienced by particular U.S. citizens and residents (e.g., national security interests, diplomatic interests, etc.);Regulating an externality on the basis of its global effects supports a cooperative international approach to the regulation of the externality by potentially inducing other countries to follow suit or maintain existing efforts; orInternational or domestic legal obligations require or support a global calculation of regulatory effects.Near-Term Discount RatesThe proposed update changes the default discount rate over the next 30 years to 1.7%, from 3% in the previous guidance.One approach assumes that the real (inflation-adjusted) rate of return on long-term U.S. government debt provides a fair approximation of the social rate of time preference. It is the rate available on riskless personal savings and is therefore...
