Steven Kelman

"At the broadest and vaguest level, cost-benefit analysis may be regarded simply as systematic thinking about decision-making. Who can oppose, economists sometimes ask, efforts to think in a systematic way about the consequences of different courses of action? The alternative, it would appear, is unexamined decision-making. But defining cost-benefit analysis so simply leaves it with few implications for actual regulatory decisionmaking."

"If both a legal rule and its opposite can be efficient because neither affected party can induce the other to waive the initially assigned rights, then either seems to be wealth maximizing."

"As the field of organization studies has grown enormously over the last decades, the attention the field pays to public organizations and public policy problems has withered. This despite the fact that the public sector, as a percentage of GNP, is much larger now than it was when these classics were written."

"My own judgement is that modest efforts to assess levels of benefits and costs are justified, although I do not believe that government agencies ought to sponsor efforts to put dollar prices on non-market things. I also do not believe that the cry for more cost-benefit analysis in regulation is, on the whole, justified. If regulatory officials were so insensitive about regulatory costs that they did not provide acceptable raw material for deliberative judgments (even if not of a strictly cost-benefit nature), my conclusion might be different. But a good deal of research into costs and benefits already occurs-actually, far more in the U.S. regulatory process than in that of any other industrial society. The danger now would seem to come more from the other side."