In this presentation, I summarise the July 2014 performance audit report by the US Government Accountability Office (USGAO), on Environmental Regulation: EPA Should Improve Adherence to Guidance for Selected Elements of Regulatory Impact Analyses in 5 slides.

1. US GAO Audit Report on Environmental
Regulation Decision-making…
EPA regulations account for most of the benefits and costs
of US federal regulations.
The US GAO looked at how well the EPA used regulatory
impact statements to help rule-making decisions.
SEPTEMBER 2014

2. WHAT DOES IT SAY.
The EPA comes out of the audit looking OK.
The auditors found that the regulatory impact
statement informed decision-making, but wasn’t
used as the primary basis in most cases.
The EPA was usually required to consider other
factors in rule-making decisions – such as
government directions.
SEPTEMBER 2014

3. WHAT ELSE DOES IT SAY.
The RIS analysis was often used to educate decision-makers,
beyond simply laying-out decision-salient facts.
Some of those facts were also less useful for comparative
analysis. Data regarding employment effects was
sometimes 20 years old.
‘Resource and data limitations’ meant that some
environmental effects couldn’t be monetised.
SEPTEMBER 2014

4. WHAT ELSE DOES IT SAY.
The Office of Management and Budget (OMB)
comes out looking worse.
It seems they require agencies to comply with
guidance last updated in 2003!
OMB’s formal response to the audit looks shifty -
“neither agreed nor disagreed with the
recommendations but saw some merit in them”.
SEPTEMBER 2014

5. WHAT DOES IT MEAN.
• The auditor didn’t find really poor practice at
EPA.
• This audit took way too long (18 months),
and the audit criteria was way out-of-date
(2003!!).
• Don’t expect too much from a RIS –
economic analysis will only ever form part of
good political decision-making.
The comments on these slides are the views of Tim Kirby, Sydney.
You should always read the report itself before putting your reputation, or any money on the line.
Tim Kirby, Sydney CA, CIA, LA-EMS
au.linkedin.com/in/timkirbysydney
SEPTEMBER 2014