Be Brief, Be Consistent, Be Neutral: Comments on US Draft Circular A-4, “Regulatory Analysis”

Abstract

Ex ante, my primary concerns were about implementation across the wide expanse of federal applications, supporting the supplemental use of distributional weighting, trying to find a supportable middle ground on discounting using the expected value of bounds and a more consistent scope of analysis. Ex post, I felt heard if not followed, perhaps not uncommon for reviewers.