BENEFIT-COST A.NALYSIS IN 

ENVIRONMENTAL, HEALTH, AND 

SAFETY REGULATION 

A STATEMENT OF PRINCIPLES 

Kenneth J. Arrow, Maureen L. Cropper, 

George C. Eads, Robert W. Hahn, 

Lester B. Lave, Roger G. Noll, 

Paul R. Portney, Milton Russell, 

Richard Schmalensee, V. Kerry Smith, 

and Robert N. Stavins 

American Enterprise Institute, 

The Annapolis Center, and 

Resources for the Future 

1996 
Contents 

PREFACE 

EXECUTIVE SUMMARY 

PRINCIPLES 

PART ONE 

GUIDANCE FOR DECISIONMAKERS ON USING 

ECONOMIC ANALYSIS TO EVALUATE 

PROPOSED POLICIES 

PART TWO 

SUGGESTIONS FOR IMPROVING THE QUALITY 

OF ECONOMIC ANALYSIS USED IN 

REGULATORY DECISIONMAKING 

ABOUT THE AUTHORS 15 
Preface 

The direct costs of federal environmental, health, and safety 

regulations are probably on the order of $200 billion annually, or 

about the size of all federal domestic, nondefense discretionary 

spending. The benefits of those regulations are even less certain. 

Evidence suggests that some recent regulations would pass a 

benefit-cost test while others would not. 

The growing impact of regulations on the economy has led 

both Congress and the administration to search for new ways of 

reforming regulation. Many of those regulatory reform initiatives 

call for greater reliance on the use of economic analysis in the 

development and evaluation of regulations. Because ideological 

extremes have dominated debate on this topic, a dispassionate 

commentary may be particularly valuable. 

On September 29, 1995, a group of leading economists met to 

discuss the role of economic analysis in the development of 

environmental, health, and safety regulation. The meeting was 

sponsored jointly by the American Enterprise Institute, the 

Annapolis Center, and Resources for the Future and was cochaired 

by Robert W. Hahn and Paul R. Portney. We would like to thank 

Harrison H. Schmitt, chairman of the Annapolis Center, for 

providing us with the resources necessary to undertake this 

endeavor. 

The following economists participated in the meeting: 

Kenneth J. Arrow, Stanford University 

Maureen L. Cropper, World Bank 

George C. Eads, Charles River Associates, Inc. 

Robert W. Hahn, American Enterprise Institute 

Lester B. Lave, Carnegie Mellon University 

Roger G. Noll, Stanford University 

Paul R. Portney, Resources for the Future 

Milton Russell, University of Tennessee 

Richard Schmalensee, Massachusetts Institute of Technology 

V. Kerry Smith, Duke University 

Robert N. Stavins, Harvard University 
BENEFIT-COST ANALYSIS AND REGULATION 

The following report summarizes the key findings of our 

group. It consists of an executive summary along with a more 

detailed statement of the principles the group developed. The 

principles are divided into two sections. The first provides some 

guidance for decisionmakers on using economic analysis to 

evaluate laws and regulations. The second offers specific 

suggestions for improving the quality of economic analysis in 

regulatory decisionmaking. We hope that those findings will 

stimulate a reasoned discussion of the appropriate role of economic 

analysis in the development of regulations. 
Executive Summary 

Benefit-cost analysis can play a very important role in 

legislative and regulatory policy debates on improving the 

environment, healih, and safety. It can help illustrate the tradeoffs 

that are inherent in public policymaking as well as make those 

tradeoffs more transparent. It can also help agencies set regulatory 

priorities. 

Benefit-cost analysis should be used to help decisionmakers 

reach a decision. Contrary to the views of some, benefit-cost 

analysis is neither necessary nor sufficient for designing sensible 

public policy. If properly done, it can be very helpful to agencies 

in the decisionmaking process. 

Decisionmakers should not be precluded from considering the 

economic costs and benefits of different policies in the 

development of regulations. Laws that prohibit costs or other 

factors from being considered in administrative decisionmaking are 

inimical to good public policy. Currently, several of the most 

important regulatory statutes have been interpreted to imply such 

prohibitions. 

Benefit-cost analysis should be required for all major regulatory 

decisions, but agency heads should not be bound by a strict benefitcost test. Instead, they should be required to consider available 

benefit-cost analyses and to justify the reasons for their decision in 

the event that the expected costs of a regulation far exceed the 

expected benefits. Agencies should be encouraged to use economic 

analysis to help set regulatory priorities. Economic analyses 

prepared in support of particularly important decisions should be 

subjected to peer review both inside and outside government. 

Benefits and costs of proposed major regulations should be 

quantified wherever possible. Best estimates should be presented 

along with a description of the uncertainties. Not all benefits or 

costs can be easily quantified, much less translated into dollar 

terms. Nevertheless, even qualitative descriptions of the pros and 

cons associated with a contemplated action can be helpful. Care 

should be taken to assure that quantitative factors do not dominate 

important qualitative factors in decisionmaking. 
BENEFIT-COST ANALYSIS AND REGULATION 

The Office of Management and Budget, or some other 

coordinating agency, should establish guidelines that agencies 

should follow in conducting benefit-cost analyses. Those guidelines 

should specify default values for the discount rate and certain types 

of benefits and costs, such as the value of a small reduction in 

mortality risk. In addition, agencies should present their results 

using a standard format, which summarizes the key results and 

highlights major uncertainties. 

4 
Principles 

PART ONE 

GUIDANCE FOR DECISIONMAKERS ON USING ECONOMIC 

ANALYSIS TO EVALUATE PROPOSED POLICIES 

A benefit-cost analysis is a useful way of organizing a 

comparison of the favorable and unfavorable effects of 

proposed policies. 

Benefit-cost analysis can help the decisionmaker better 

understand the implications of a decision. It should be used to 

inform decisionmakers. Benefit-cost analysis can provide useful 

estimates of the overall benefits and costs of proposed policies. It 

can also assess the impacts of proposed policies on consumers, 

workers, and owners of firms and can identify potential winners 

and losers. 

In many cases, benefit-cost analysis cannot be used to prove 

that the economic benefits of a decision will exceed or fall short of 

the costs. There is simply too much uncertainty in some of the 

estimates of costs and benefits to make such statements with a high 

degree of confidence. 

Benefit-cost analysis should play an important role in 

informing the decisionmaking process, even when the information 

on benefits, costs, or both is highly uncertain, as is often the case 

with regulations involving the environment, health, and safety. 

The estimation of costs and benefits of a proposed regulation can 

provide illuminating evidence for a decision, even if precision 

cannot be achieved because of limitations on time, resources, or the 

availability of information. 

5 
BENEFIT-COST ANALYSIS AND REGULATION 

Economic analysis can be useful in designing regulatory 

strategies that achieve a desired goal at the lowest 

possible cost. 

Too frequently, environmental, health, and safety regulation 

has used a one-size-fits-all or command-and-control approach. 

Economic analysis can highlight the extent to which cost savings 

can be achieved by using alternative, more flexible approaches that 

reward performance. Performance standards and market-based 

approaches are generally preferable to command-and-control 

approaches because they can achieve the same objective at a lower 

total cost to society. , A recent example is the market-based 

approach used to reduce emissions that cause acid rain. That 

approach was estimated to be much less expensive than an 

alternative under consideration that would have required large 

power plants to install scrubbers. 

Congress should not preclude decisionmakers from 

considering the economic costs and benefits of different 

policies in the development of regulations. At the very 

least, agencies should be encouraged to use economic 

analysis to help set regulatory priorities. 

Sections of some statutes, such as parts of the Clean Air Act 

and the Delaney Clause, explicitly prohibit the balancing of 

benefits and costs in the development of regulations. Removing 

such prohibitions can help promote more efficient and effective 

regulation of the environment, health, and safety. 

To make better use of society's resources, Congress should 

encourage regulatory agencies to use economic analysis in planning 

their regulatory agenda. Current planning in most regulatory 

agencies places insufficient emphasis on the likely benefits and 

costs of regulations and excessive emphasis on politics and 

deadlines. Congress should consider changing that emphasis by 

explicitly asking agencies to consider the benefits and costs of 

policies in formulating agendas. 

9 
ARROW ET AL. 

Benefit-cost analysis should be required for all major 

regulatory decisions. 

While the precise definition of major requires some judgment, 

we believe that a major regulation should be one whose annual 

economic cost is expected to be greater than $100 million. We also 

believe that this requirement should be applied to independent 

agencies as well as to executive branch agencies. An important 

benefit of mandatory benefit-cost analysis is that it facilitates 

external monitoring of an agency's performance and thus makes it 

easier to hold agency heads accountable. 

The scale of a benefit-cost analysis should depend on both the 

stakes involved and the likelihood that the resulting information 

will affect the ultimate decision. Other things equal, agencies 

should devote more resources to analyzing problems where the 

stakes are greater. A full-blown benefit-cost analysis, however, can 

be costly. Therefore, the agency should not perform the analysis 

unless there is some likelihood that doing so will actually inform 

the regulatory decision. Informing the decision could involve 

changing the goal of the regulation or the means by which a 

particular goal is achieved. 

Agencies should not be bound by a strict benefit-cost 

test, but should be required to consider available 

benefit-cost analyses. For regulations whose expected 

costs far exceed expected benefits, agency heads should 

be required to present a clear explanation justifying the 

reasons for their decision. 

There may be factors other than economic benefits and costs 

that agencies will want to weigh in decisions, such as equity within 

and across generations. In addition, a decisionmaker may want to 

place greater weight on particular characteristics of a decision, such 

as potential irreversible consequences. 

7 
BENEFIT-COST ANALYSIS AND REGULATION 

For legislative proposals involving major health, safety, 

and environmental regulations, the Congressional 

Budget Office should do a preliminary benefit-cost 

analysis that can inform legislative decisionmaking. 

Because laws give rise to regulations, some kind of benefit-cost 

analysis is likely to be useful in informing the policy process. Such 

a benefit-cost analysis will, of necessity, be quite rough since it is 

difficult to estimate the economic impact of a proposed law before 

the regulations based on that law are written. Although a fullblown benefit-cost analysis may not be warranted in many cases, 

a rough benefit-cost analysis will often be quite useful. 

PART TWO 

SUGGESTIONS FOR IMPROVING THE QUALITY OF ECONOMIC 

ANALYSIS USED IN REGULATORY DECISIONMAKING 

While benefit-cost analysis should focus primarily on 

the overall relationship between benefits and costs, a 

good benefit-cost analysis will identify important 

distributional consequences of a policy. 

Available data often permit reliable estimation of major policy 

impacts on important subgroups of the population. If a regulation 

results in economic spillovers that contribute to significant job 

losses or increased costs to a specific industry in a local economy, 

then it is appropriate to consider those in a benefit-cost analysis. 

Agencies should, however, weigh those impacts against positive 

impacts that result elsewhere in the larger economy. Usually, it is 

better to address concerns about local economic spillover effects of 

regulation by using tax and transfer policies rather than regulatory 

policy. 

Regulation typically affects the distribution of employment 

among industries rather than the general employment level. 

Usually, any specific regulation has a very minor effect on either 
ARROW ET AL. 

wages or employment in the industry to which it applies. 

Regardless of the size of the employment effect, the appropriate 

measure of regulatory costs is the transition costs of employees 

who are forced to switch jobs because of the regulation. In those 

few cases where regulation can have a significant impact on total 

employment, such as the minimum wage, the effect on consumers 

and producers should also be estimated. 

It is important to identify the incremental benefits and 

costs associated with different regulatory policies. 

A problem with many regulatory analyses is that they fail to 

specify a clear baseline. Doing so is a necessary first step in 

identifying the incremental benefits and costs of a proposed policy. 

Defining a clear baseline can help avoid problems with double 

counting. For example, some regulatory analyses have counted as 

benefits positive changes that would have occurred even if the 

regulations were not implemented. 

In addition to specifying a clear baseline, we think it is useful 

for the analyst to consider an array of practical alternatives for 

pursuing a particular statutory or regulatory objective, while 

carefully noting the incremental costs and benefits associated with 

those alternatives. For example, almost all of the harm from a 

polluting process can frequently be eliminated for a reasonable 

cost, while an astronomical cost is required to remove the last, 

small amount of harm. A benefit-cost analysis that considers only 

a no-treatment baseline and a full-treatment alternative may find 

that benefits exceed the costs under full treatment. If the analysis 

had considered a partial-treatment case, however, the net benefits 

to consumers could be higher still. In this example, separate 

consideration of low-cost and high-cost alternatives makes it easier 

for the decisionmaker to select the low-cost remedy when it is 

appropriate. 

vi 
BENEFIT-COST ANALYSIS AND REGULATION 

Benefits and costs of proposed policies should be 

quantified wherever possible. Best estimates should be 

presented along with a description of the uncertainties. 

In most instances, it should be possible to describe the effects 

of proposed policy changes in quantitative terms. Quantification 

of benefits and costs is useful, even where there are large 

uncertainties. Available methods and data generally imply ranges 

of possible values of costs and benefits, not single numbers. Benefitcost analysis contributes most to intelligent decisionmaking when 

those ranges are clearly described along with best estimates. Best 

estimates should reflect expected values. 

If the decisionmaker wishes to introduce a"margin of safety" 

into his decision, he should do so explicitly. Assumptions should 

be stated clearly rather than be hidden within the analysis. 

Not all impacts of a decision can be quantified or 

expressed in dollar terms. Care should be taken to 

assure that quantitative factors do not dominate 

important qualitative factors in decisionmaking. 

A common critique of benefit-cost analysis is that it does not 

emphasize factors that are not easily quantified or monetized. That 

critique has merit. There are two principal ways to address it: first, 

quantify as many factors as are reasonable and quantify or 

characterize the relevant uncertainties; and second, give due 

consideration to factors that defy quantification but are thought to 

be important. 

The more external review regulatory analyses receive, 

the better they are likely to be. 

External review includes peer-reviewed studies as well as studies 

reviewed by an agency other than the one doing the study. 

Historically, the Office of Management and Budget has played a 

key role in reviewing selected major regulations, particularly those 

10 
ARROW ET AL. 

aimed at protecting the environment, health, and safety. We think 

that such a role is appropriate for any regulation whose annual 

economic cost is expected to be greater than $100 million. 

Peer review of economic analyses should be used for 

regulations with potentially large economic impacts (for example, 

those whose annual economic cost exceeds $1 billion). The 

reviewers should be selected on the basis of their demonstrated 

expertise and reputation. 

Retrospective assessments of selected regulatory impact 

analyses should also be done periodically by an independent group 

of scholars to address systematic problems that have arisen. Because 

environmental, health, and safety regulatory decisions can have 

important impacts on the economy, it is useful to review 

periodically the quality of economic analysis that aids in the 

decisionmaking process. An outside panel of experts, primarily 

consisting of economists and other scientists, could provide 

recommendations on how such analyses could be improved. The 

panel could be selected by the National Academy of Sciences. 

A core set of economic assumptions should be used in 

calculating benefits and costs associated with 

environmental, health, and safety regulation. Key 

variables include the social discount rate, the value of 

reducing risks of dying and accidents, and the value 

associated with other improvements in health. 

There are benefits from being able to compare results across 

analyses, including potentially large gains in economic efficiency. 

A common set of economic assumptions facilitates such 

comparisons. For example, a common set of assumptions can be 

used to develop values for improvements in environmental quality. 

Agencies should be allowed to use alternative assumptions, so 

long as those assumptions are clearly stated. They should then 

compare the results based on those assumptions with the results 

based on the common set of assumptions. Where possible, agencies 

should explain the economic rationale for employing alternative 

assumptions. 

11 
BENEFIT-COST ANALYSIS AND REGULATION 

Information should be presented clearly and succinctly 

in a regulatory impact analysis. Transparency is 

necessary if benefit-cost analysis is to inform 

decisionmaking. 

It is very important in conducting a benefit-cost analysis that 

agencies spell out all key assumptions clearly and highlight 

uncertainties. Both the executive summary and the report itself 

should be easily accessible to people who are familiar with basic 

economic concepts. References for key estimates should be 

provided. 

The executive summary of the analysis should present key 

assumptions and results for the base case and sensitivity analyses. 

That summary should include information on the net present value 

of costs and benefits and the stream of costs and benefits for all 

cases that the analysis examines in detail. It should also highlight 

key factors that have been quantified as well as those that have not. 

Finally, the summary should identify incremental net benefits 

from selecting different alternatives. 

A single agency should set key economic values for 

evaluating regulations and should develop a standard 

format for presenting the results of a regulatory impact 

analysis. 

A single agency, such as the Office of Management and Budget, 

should specify key economic values for use in evaluating proposed 

regulations. That approach will ensure that there is some 

consistency across agency evaluations. Those values should be 

revised periodically on the basis of new information. 

A single agency, such as the Office of Management and Budget, 

should also develop a standard format for presenting key 

assumptions and results. That format should make it easier for 

decisionmakers and interested parties to review principal findings. 

12 
ARROW ET AL. 

Whenever possible, values used for monetizing benefits 

and costs should be based on tradeoffs that individuals 

would make, either directly or, as is often the case, 

indirectly in labor, housing, or other markets. 

Benefit-cost analysis is premised on the notion that the values 

to be assigned to program effects—favorable or unfavorable—are 

those of the affected individuals, not the values held by economists, 

moral philosophers, or others. Valuation will be difficult, and in 

some cases impossible, when individuals are unwilling or unable to 

substitute one commodity or service for another. 

Because one seldom knows whose life will be prolonged or 

whose health will be improved by a regulatory program, it is 

generally appropriate to value small reductions in the risk of 

morbidity or premature mortality for each individual. Typically, 

individuals are willing to trade off other amenities, goods, or 

services for slight reductions in risk. The values they reveal depend 

on both the type of risk and the number of additional years of life 

they would enjoy from reduced risk. Other things being equal, a 

program that prevents a serious illness should be valued more 

highly than one that prevents a minor ailment. Similarly, a 

program that extends a life by thirty years should be valued more 

highly than one that extends it for three. Where policies are 

expected to extend a life, it is better to estimate the number of lifeyears extended than just the number of lives. 

Given uncertainties in identifying the correct discount 

rate, it is appropriate to employ a range of rates. Ideally, 

the same range of discount rates should be used in all 

regulatory analyses. 

Both economic efficiency and intergenerational equity require 

that benefits and costs experienced in future years be given less 

weight in decisionmaking than those experienced today. The rate 

at which future benefits and costs should be discounted to present 

values will generally not equal the rate of return on private 

13 
BENEFIT-COST ANALYSIS AND REGULATION 

investment. The discount rate should instead be based on how 

individuals trade off current for future consumption. 

14 
About the Authors 

Kenneth J. Arrow is the Joan Kenney Professor of Economics 

Emeritus at Stanford University. His research interests include 

foundations and applications of welfare criteria, general 

equilibrium analysis, and the economics of uncertainty and 

information. He has received the Nobel Memorial Prize in 

Economic Science, the John Bates Clark Medal, and the von 

Neumann Prize. He has also been president of several learned 

societies. 

Maureen L. Cropper is a principal economist at the World Bank, 

a professor of economics at the University of Maryland, and a 

senior fellow at Resources for the Future. Her research has focused 

on valuing environmental amenities—especially environmental 

health effects—from both an empirical and a theoretical 

perspective. She has also completed studies of the U.S. 

Environmental Protection Agency decisionmaking that infer the 

value of lives saved by various regulations, as well as the implicit 

value of Superfund cleanup options. Her current research centers 

on valuing the health impacts of pollution in developing countries 

and on the economics of deforestation. 

George C. Eads is a vice president for Charles River Associates, 

Inc. Before joining Charles River's Washington office, he was a 

vice president of General Motors and the corporation's chief 

economist. Mr. Eads was a member of President Carter's Council 

of Economic Advisers and oversaw the CEA's regulatory reform 

activities and chaired the Carter Administration's interagency 

Regulatory Analysis Review Group. In the mid-1970s he was the 

first assistant director for the Council on Wage and Price Stability 

and initiated that agency's policy of filing written comments on the 

economic impact of major proposed federal rules and regulations. 

Robert W. Hahn is a resident scholar at the American Enterprise 

Institute and an adjunct professor of economics at Carnegie Mellon 

University. From 1991 to 1994 he was an adjunct faculty member 

at the Kennedy School of Government, Harvard University. 

Before that he worked for two years as a senior staff inember of the 

15 
BENEFIT-COST ANALYSIS AND REGULATION 

President's Council of Economic Advisers. Mr. Hahn frequently 

contributes to general-interest periodicals and leading scholarly 

journals including the New York Times, Wall Street Journal, 

American Economic Review, and Yale Law Journal. In addition, he 

is a cofounder of the Community Preparatory School—an innercity middle school that provides opportunities for disadvantaged 

youth to achieve their full potential. 

Lester B. Lave is University Professor and the Higgins Professor 

of Economics in the Graduate School of Industrial Administration 

and professor of engineering and public policy in the College of 

Engineering and Public Policy at Carnegie Mellon University. He 

has consulted to the U.S. Environmental Protection Agency, the 

Occupational Safety and Health Administration, and other federal 

government agencies on the theory and application of benefit-cost 

analysis. His current assignment as head of the Carnegie Mellon 

Universitywide Green Design Initiative has resulted in analyses of 

electric cars, municipal solid waste recycling, and the weighting of 

toxic discharges that give practical demonstration to the 

controversies inherent in benefit-cost analysis. 

Roger G. Noll is the Morris M. Doyle Professor of Public Policy 

in the Department of Economics at Stanford University. At 

Stanford, he is also the director of the Public Policy Program, the 

director of the Program in Regulatory Policy in the Center for 

Economic Policy Research, and a professor by courtesy in the 

Graduate School of Business and the Department of Political 

Science. Professor Noll's research interests include government 

regulation of business and public policies regarding research and 

development. Currently, he is evaluating the role of federalism in 

regulatory policy and is conducting international comparative 

studies of the performance of regulatory institutions and 

infrastructural industries. 

Paul R. Portney is president of Resources for the Future. From 

1989 to 1995, he was RFF's vice president and was the director of 

its Center for Risk Management and its Quality of the 

Environment Division. Before joining RFF, Mr. Portney was chief 

16 
ARROW ET AL. 

economist at the Council on Environmental Quality in the 

Executive Office of the President. He is currently a member of the 

Executive Committee of EPA's Science Advisory Board and 

chairman of the SAB's Environmental Economics Advisory 

Committee. He lectures frequently on developments in U.S. and 

international environmental policy. His most recent publication is 

Footing the Bill for Superfund Cleanups: Who Pays and How? 

Milton Russell is professor of economics at the University of 

Tennessee, Knoxville, the director of the Joint Institute for Energy 

and Environment, and a collaborating scientist at Oak Ridge 

National Laboratory. He was an assistant administrator of the U.S. 

Environmental Protection Agency, a senior fellow at Resources for 

the Future, and a senior staff inember of the Council of Economic 

Advisers. His research centers on environmental policy and 

decisionmaking, most recently as applied to hazardous waste 

remediation. He was elected a fellow of the Society of Risk 

Analysis in 1994. 

Richard Schmalensee is the Gordon Y. Billard Professor of 

Economics and Management at the Massachusetts Institute of 

Technology and director of MIT's Center for Energy and 

Environmental Policy Research. He was a member of the 

President's Council of Economic Advisers from 1989 through 

1991. Before joining the council, Professor Schmalensee was area 

head for Economics, Finance, and Accounting at the MIT Sloan 

School of Management. His academic work has centered on 

industrial organization economics and its application to a wide 

range of antitrust and regulatory issues. Professor Schmalensee is 

a member of the U.S. Environmental Protection Agency's 

Environmental Economic Advisory Board and is chairman of its 

Clean Air Act Compliance Analysis Council. 

V. Kerry Smith is the Arts and Sciences Professor of 

Environmental Economics at Duke University and a university 

fellow for the Quality of the Environment Division at Resources 

for the Future. Professor Smith is a past president of the Southern 

Economic Association and the Association of Environmental and 

17 
BENEFIT-COST ANALYSIS AND REGULATION 

Resource Economists. His advisory and consulting activities have 

focused on natural resource damage assessment, evaluation of 

regulations for air and water quality, valuation of risk reductions 

from hazardous waste policies, and environmental costing. His 

current research centers on modeling how individuals deal with 

risks—such as radon, pesticide residues, and cholesterol—differing 

in their temporal effects and prospects for mitigation. 

Robert N. Stavins is associate professor of public policy at the 

John F. Kennedy School of Government at Harvard University. 

He is a university fellow for Resources for the Future, a member 

of the Environmental Economics Advisory Committee of the U.S. 

Environmental Protection Agency's Science Advisory Board, a 

member of the Intergovernmental Panel on Climate Change, and 

a member of the Eco-Efficiency Task Force of the President's 

Council on Sustainable Development. Professor Stavins's current 

research includes analyses of the innovation of energy-efficiency 

technologies, methods for valuing environmental amenities, the 

design and implementation of incentive-based approaches to 

environmental protection, and alternative strategies for mitigating 

global climate change. 

18 
This work was jointly sponsored by the American Enterprise 

Institute, the Annapolis Center, and Resources for the Future. 

Funding was provided by the Annapolis Center. We would like to 

thank Elizabeth Drembus and Jonathan Siskin for their editorial 

assistance and Richard Seibert, Meaghan Hayward, and Mary 

Moran for their administrative support. The views in this 

document represent those of the authors and do not necessarily 

represent the views of the institutions with which they are 

affiliated. 

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