Document JQvjnK06jDkqRza258kVoq2e
20 M Street SE (2134 LM), Washington, DC 20003 office 202-912-7287; cell 202-341-4837; rwinthro@blm.gov
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"Stevens, William" <bpsteven@blm.gov>
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"Stevens, William" <bpsteven@blm.gov>
Thu May 25 2017 09:46:43 GMT-0600 (MDT)
"Winthrop, Robert" <rwinthro@blm.gov>
Hilary Zarin <hzarin@blm.gov>, James C Tichenor <jtichenor@blm.gov>, Jennifer Schein Dobb <jscheindobb@blm.gov>, Jessica Montag <jmontag@blm.gov>, Joshua B Sidon <jsidon@blm.gov>, Keith Brown <kmbrown@blm.gov>, Martin Hensley <mhensley@blm.gov>, Michael D Johnson <mdjohnso@blm.gov>, Mike Ford <mmford@blm.gov>, Rebecca Moore <rmoore@blm.gov>, Scott Rickard <srickard@blm.gov>, Stacey Fritz <SFritz@blm.gov>, Stewart Allen <sdallen@blm.gov>, "Suhr Pierce, Julie A" <jsuhrpierce@blm.gov>, Tessa Teems <tteems@blm.gov>, Tyson J Sackett <tsackett@blm.gov>
Re: program meeting topic: CBA and deregulation
I think it would be very useful.
On Thu, May 25, 2017 at 9:12 AM, Winthrop, Robert <rwinthro@blm.gov> wrote:
All:
I would really be interested in a short session on practical aspects of cost-benefit analysis in the context of deregulation. Over the next several years the BLM will likely undertake a number of regulatory actions aimed at modifying existing regulations. Reflecting significant policy disagreements between the Trump and Obama administrations, some of these intended regulatory changes may involve major changes or rollbacks of current requirements.
EO 12866 ("Regulatory Planning and Review"), Sect. 1(b)(6) states:
"Each agency shall assess both the costs and the benefits of the intended regulation and, recognizing that some costs and benefits are difficult to quantify, propose or adopt a regulation only upon a reasoned determination that the benefits of the intended regulation justify its costs."
To put things somewhat simplistically: the original rulemaking should have demonstrated that the estimated benefits of implementing the new regulation exceeded its costs. Presumably a rulemaking to modify an existing regulation must also demonstrate that the benefits of the change exceed its costs. We have at least two responsibilities here: to support the policy initiatives of the new departmental and bureau leadership, and to provide analyses that are objective and defensible to the best of our ability. Some discussion of the practical challenges of doing regulatory cost-benefit analysis might be helpful.
Is this a useful topic for the program meeting? Comments by phone or email would be welcome.
Rob
Rob Winthrop
Senior Social Scientist, Socioeconomics Program Decision Support, Planning and NEPA (WO-210) USDI - Bureau of Land Management 20 M Street SE (2134 LM), Washington, DC 20003 office 202-912-7287; cell 202-341-4837; rwinthro@blm.gov
Confidentiality Notice: This electronic communication is intended only for the use of the individual(s) or group(s) it was originally addressed to and may contain information that is privileged, confidential, and possibly exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it further. Please delete the received message and notify the sender.
Bill Stevens Outdoor Recreation Planner Moab Field Office (435) 259-2101
"Suhr Pierce, Julie" <jsuhrpierce@blm.gov>
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"Suhr Pierce, Julie" <jsuhrpierce@blm.gov>
Thu May 25 2017 12:16:57 GMT-0600 (MDT)
"Winthrop, Robert" <rwinthro@blm.gov>
Bill Stevens <bpsteven@blm.gov>, Hilary Zarin <hzarin@blm.gov>, James C Tichenor <jtichenor@blm.gov>, Jennifer Schein Dobb <jscheindobb@blm.gov>, Jessica Montag <jmontag@blm.gov>, Joshua B Sidon <jsidon@blm.gov>, Keith Brown <kmbrown@blm.gov>, Martin Hensley <mhensley@blm.gov>, Michael D Johnson <mdjohnso@blm.gov>, Mike Ford <mmford@blm.gov>, Rebecca Moore <rmoore@blm.gov>, Scott Rickard <srickard@blm.gov>, Stacey Fritz <SFritz@blm.gov>, Stewart Allen <sdallen@blm.gov>, Tessa Teems <tteems@blm.gov>, Tyson J Sackett <tsackett@blm.gov>
Re: program meeting topic: CBA and deregulation
I think it would be good.
Julie
On Thu, May 25, 2017 at 9:12 AM, Winthrop, Robert <rwinthro@blm.gov> wrote:
All:
I would really be interested in a short session on practical aspects of cost-benefit analysis in the context of deregulation. Over the next several years the BLM will likely undertake a number of regulatory actions aimed at modifying existing regulations. Reflecting significant policy disagreements between the Trump and Obama administrations, some of these intended regulatory changes may involve major changes or rollbacks of current requirements.
EO 12866 ("Regulatory Planning and Review"), Sect. 1(b)(6) states:
"Each agency shall assess both the costs and the benefits of the intended regulation and, recognizing that some costs and benefits are difficult to quantify, propose or adopt a regulation only upon a reasoned determination that the benefits of the intended regulation justify its costs."
To put things somewhat simplistically: the original rulemaking should have demonstrated that the estimated benefits of implementing the new regulation exceeded its costs. Presumably a rulemaking to modify an existing regulation must also demonstrate that the benefits of the change exceed its costs. We have at least two responsibilities here: to support the policy initiatives of the new departmental and bureau leadership, and to provide analyses that are objective and defensible to the best of our ability. Some discussion of the practical challenges of doing regulatory cost-benefit analysis might be helpful.
Is this a useful topic for the program meeting? Comments by phone or email would be welcome.
Rob
Rob Winthrop
Senior Social Scientist, Socioeconomics Program Decision Support, Planning and NEPA (WO-210) USDI - Bureau of Land Management 20 M Street SE (2134 LM), Washington, DC 20003 office 202-912-7287; cell 202-341-4837; rwinthro@blm.gov
Confidentiality Notice: This electronic communication is intended only for the use of the individual(s) or group(s) it was originally addressed to and may contain information that is privileged, confidential, and possibly exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it further. Please delete the received message and notify the sender.
Julie A. Suhr Pierce, Ph.D. Great Basin Socioeconomic Specialist Bureau of Land Management - Utah 440 West 200 South, Suite 500 Salt Lake City, UT 84101-1345 jsuhrpierce@blm.gov 801-539-4290 (office) 801-597-2335 (cell)
"Ford, Michael" <mmford@blm.gov>
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"Ford, Michael" <mmford@blm.gov>
Thu May 25 2017 12:20:26 GMT-0600 (MDT)
"Suhr Pierce, Julie" <jsuhrpierce@blm.gov>
"Winthrop, Robert" <rwinthro@blm.gov>, Bill Stevens <bpsteven@blm.gov>, Hilary Zarin <hzarin@blm.gov>, James C Tichenor <jtichenor@blm.gov>, Jennifer Schein Dobb <jscheindobb@blm.gov>, Jessica Montag <jmontag@blm.gov>, Joshua B Sidon <jsidon@blm.gov>, Keith Brown <kmbrown@blm.gov>, Martin Hensley <mhensley@blm.gov>, Michael D Johnson <mdjohnso@blm.gov>, Rebecca Moore <rmoore@blm.gov>, Scott Rickard <srickard@blm.gov>, Stacey Fritz <SFritz@blm.gov>, Stewart Allen <sdallen@blm.gov>, Tessa Teems <tteems@blm.gov>, Tyson J Sackett <tsackett@blm.gov>
Re: program meeting topic: CBA and deregulation
Yes, absolutely
On Thu, May 25, 2017 at 2:16 PM, Suhr Pierce, Julie <jsuhrpierce@blm.gov> wrote: I think it would be good.
Julie
On Thu, May 25, 2017 at 9:12 AM, Winthrop, Robert <rwinthro@blm.gov> wrote:
All:
I would really be interested in a short session on practical aspects of cost-benefit analysis in the context of deregulation. Over the next several years the BLM will likely undertake a number of regulatory actions aimed at modifying existing regulations. Reflecting significant policy disagreements between the Trump and Obama
administrations, some of these intended regulatory changes may involve major changes or rollbacks of current requirements.
EO 12866 ("Regulatory Planning and Review"), Sect. 1(b)(6) states:
"Each agency shall assess both the costs and the benefits of the intended regulation and, recognizing that some costs and benefits are difficult to quantify, propose or adopt a regulation only upon a reasoned determination that the benefits of the intended regulation justify its costs."
To put things somewhat simplistically: the original rulemaking should have demonstrated that the estimated benefits of implementing the new regulation exceeded its costs. Presumably a rulemaking to modify an existing regulation must also demonstrate that the benefits of the change exceed its costs. We have at least two responsibilities here: to support the policy initiatives of the new departmental and bureau leadership, and to provide analyses that are objective and defensible to the best of our ability. Some discussion of the practical challenges of doing regulatory cost-benefit analysis might be helpful.
Is this a useful topic for the program meeting? Comments by phone or email would be welcome.
Rob
Rob Winthrop
Senior Social Scientist, Socioeconomics Program Decision Support, Planning and NEPA (WO-210) USDI - Bureau of Land Management 20 M Street SE (2134 LM), Washington, DC 20003 office 202-912-7287; cell 202-341-4837; rwinthro@blm.gov
Confidentiality Notice: This electronic communication is intended only for the use of the individual(s) or group(s) it was originally addressed to and may contain information that is privileged, confidential, and possibly exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it further. Please delete the received message and notify the sender.
Julie A. Suhr Pierce, Ph.D. Great Basin Socioeconomic Specialist Bureau of Land Management - Utah 440 West 200 South, Suite 500 Salt Lake City, UT 84101-1345 jsuhrpierce@blm.gov 801-539-4290 (office) 801-597-2335 (cell)
Michael M. Ford Economist Bureau of Land Management mmford@blm.gov w: 202-912-7623
m: 202-774-8530
"Winthrop, Robert" <rwinthro@blm.gov>
From: Sent: To:
"Winthrop, Robert" <rwinthro@blm.gov> Thu May 25 2017 12:28:24 GMT-0600 (MDT) "Ford, Michael" <mmford@blm.gov>
Subject:
Re: program meeting topic: CBA and deregulation
Thanks, Mike.
Rob Winthrop
Senior Social Scientist, Socioeconomics Program Decision Support, Planning and NEPA (WO-210) USDI - Bureau of Land Management 20 M Street SE (2134 LM), Washington, DC 20003 office 202-912-7287; cell 202-341-4837; rwinthro@blm.gov
Confidentiality Notice: This electronic communication is intended only for the use of the individual(s) or group(s) it was originally addressed to and may contain information that is privileged, confidential, and possibly exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it further. Please delete the received message and notify the sender.
On Thu, May 25, 2017 at 2:20 PM, Ford, Michael <mmford@blm.gov> wrote: Yes, absolutely
On Thu, May 25, 2017 at 2:16 PM, Suhr Pierce, Julie <jsuhrpierce@blm.gov> wrote: I think it would be good.
Julie
On Thu, May 25, 2017 at 9:12 AM, Winthrop, Robert <rwinthro@blm.gov> wrote:
All:
I would really be interested in a short session on practical aspects of cost-benefit analysis in the context of deregulation. Over the next several years the BLM will likely undertake a number of regulatory actions aimed at modifying existing regulations. Reflecting significant policy disagreements between the Trump and Obama administrations, some of these intended regulatory changes may involve major changes or rollbacks of current requirements.
EO 12866 ("Regulatory Planning and Review"), Sect. 1(b)(6) states:
"Each agency shall assess both the costs and the benefits of the intended regulation and, recognizing that some costs and benefits are difficult to quantify, propose or adopt a regulation only upon a reasoned determination that the benefits of the intended regulation justify its costs."
To put things somewhat simplistically: the original rulemaking should have demonstrated that the estimated benefits of implementing the new regulation exceeded its costs. Presumably a rulemaking to modify an existing regulation must also demonstrate that the benefits of the change exceed its costs. We have at least two responsibilities here: to support the policy initiatives of the new departmental and bureau leadership, and to provide analyses that are objective and defensible to the best of our ability. Some discussion of the practical challenges of doing regulatory cost-benefit analysis might be helpful.
Is this a useful topic for the program meeting? Comments by phone or email would be welcome.
Rob
Rob Winthrop
Senior Social Scientist, Socioeconomics Program Decision Support, Planning and NEPA (WO-210) USDI - Bureau of Land Management 20 M Street SE (2134 LM), Washington, DC 20003 office 202-912-7287; cell 202-341-4837; rwinthro@blm.gov
Confidentiality Notice: This electronic communication is intended only for the use of the individual(s) or group(s) it was originally addressed to and may contain information that is privileged, confidential, and possibly exempt from disclosure under applicable law. If you have received this communication in error, pfease do not distribute it further. Please delete the received message and notify the sender.
Julie A. Suhr Pierce, Ph.D.
Great Basin Socioeconomic Specialist Bureau of Land Management - Utah 440 West 200 South, Suite 500 Salt Lake City, UT 84101-1345 jsuhrpierce@blm.gov 801-539-4290 (office) 801-597-2335 (cell)
Michael M. Ford Economist Bureau of Land Management mmford@blm.gov w: 202-912-7623
m: 202-774-8530
"Fritz, Stacey" <sfritz@blm.gov>
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Subject: Attachments:
"Fritz, Stacey" <sfritz@blm.gov>
Thu May 25 2017 12:56:54 GMT-0600 (MDT)
"Ford, Michael" <mmford@blm.gov>
"Suhr Pierce, Julie" <jsuhrpierce@blm.gov>, "Winthrop, Robert" <rwinthro@blm.gov>, Bill Stevens <bpsteven@blm.gov>, Hilary Zarin <hzarin@blm.gov>, James C Tichenor <jtichenor@blm.gov>, Jennifer Schein Dobb <jscheindobb@blm.gov>, Jessica Montag <jmontag@blm.gov>, Joshua B Sidon <jsidon@blm.gov>, Keith Brown <kmbrown@blm.gov>, Martin Hensley <mhensley@blm.gov>, Michael D Johnson <mdjohnso@blm.gov>, Rebecca Moore <rmoore@blm.gov>, Scott Rickard <srickard@blm.gov>, Stewart Allen <sdallen@blm.gov>, Tessa Teems <tteems@blm.gov>, Tyson J Sackett <tsackett@blm.gov>
Re: program meeting topic: CBA and deregulation
Amicus Brief EO 13771 eliminate 2 for 1.pdf
Yes, absolutely.
You may have seen this https://www.eenews.net/eenewspm/2017/05/24/stories/1060055099
and it is about EO 13771 (not 12866) but I think it is relevant to 12866 and interesting attaching the amicus brief here.
On Thu, May 25, 2017 at 10:20 AM, Ford, Michael <mmford@blm.gov> wrote: Yes, absolutely
On Thu, May 25, 2017 at 2:16 PM, Suhr Pierce, Julie <jsuhrpierce@blm.gov> wrote: I think it would be good.
Julie
Stacey Fritz Anthropologist/Subsistence Specialist BLM Arctic Office 222 University Ave. Fairbanks, AK, 99709 NPR-A Subsistence Advisory Panel Website fax: (907) 474-2282 work phone: (907) 474-2309 cell phone: (907) 687-6549