YSE Professors Help Federal Government Account for Environment in Regulatory System
YSE Professors Eli Fenichel and Kenneth Gillingham played key roles in updating a White House Office of Management and Budget (OMB) guide on how federal agencies calculate their regulations’ benefits and costs to account more fully for the environment.
All major regulations must undergo benefit-cost analysis (BCA), and the U.S. executive branch is responsible for doing BCA for programs and regulations. Fenichel, Knobloch Family Professor of Natural Resource Economics, worked to update Circular No. A-4, which is the federal government’s primary document for guiding BCA and was last revised in 2003. Circulars are the highest-level guidance issued by OMB.
“This document has tremendous influence over what government agencies consider, how they consider it, when they make regulatory decisions, and also over the ability of the government to defend or be challenged in court over those decisions,” Fenichel said.
The new update references "ecosystem services" 18 times and "environmental" 74 times, including five mentions of "environmental justice." The document is supported by new Guidance for Assessment Changes to Environmental and Ecosystem Services in benefit-costs analysis.
While on leave to the White House Office of Science and Technology Policy (OSTP), which works closely with the OMB, Fenichel was central to this historic effort to modernize regulatory guidance and helped draft these updates. The documents go through extensive public comment and peer review. Gillingham, professor of environmental and energy economics, was one of the official peer reviewers on the critical document. Yale Law Professor Zach Liscow led an update of a related federal guidance for BCA for programs and operation, OMB Circular A-94 (last revised in 1992), which Fenichel also helped to revise.
In a recent White House roundtable focusing on the first-of-its-kind report "Advancing the Frontiers of Benefit Cost Analysis: Federal Priorities and Directions for Future Research," Fenichel discussed the effort to develop environmental economic accounts to track the quantity and quality of natural resources, including air, water, land, wildlife, pollinators, energy, minerals, soils, forests, wetlands, environmental activities, urban green space, and other environmental assets.
"It was great to see projects from agencies with expertise in physical and natural sciences working with agencies with expertise in social science," Fenichel said at the roundtable. "We really need this systematic viewpoint. The natural capital accounts and the environmental economic statistics will work with other national economic statistics to create baselines that will allow us think about change and ultimately let us separate the unintended consequences of regulations that can be avoided because they are no longer unanticipated."
January 23, 2024
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Recipients of the award travel to Washington, D.C. for policy, communication and career training and they meet with lawmakers on Capitol Hill.
Gewirtzman, a National Science Foundation Research Fellow, investigates greenhouse gas cycling in forests and wetlands aimed at informing strategies for mitigating natural emissions and enhancing nature-based climate solutions.
“ESA has been an important community for me throughout my graduate career — a place to connect with ecologists across subfields and to build leadership experience as an officer of the Biogeosciences Section. I'm excited for the opportunity to learn firsthand from scientists and policymakers working at that interface,” Gewirtzman said.
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