Ensuring Durability and Objectivity in Regulatory Analysis: Comments on OMB Circular A-4

Abstract This article is based on feedback I submitted in response to the Office of Management and Budget’s (OMB’s) April 2023 request for comments on its draft revisions to Circular A-4, “Regulatory Analysis.” Much has changed since I submitted my comments in June 2023. OMB issued a final circular in November 2023 and subsequently rescinded it in February 2025. This article includes my comments as submitted, along with an introductory “prologue” and an “epilogue” that reflects on the decision to abandon the 2023 revisions and return to the 2003 Circular. My comment addressed key elements of regulatory analysis, suggested areas where OMB could provide more guidance, and identified several aspects of the 2023 Circular that appeared to be internally inconsistent or contradictory. It concluded that some of the 2023 revisions were worthwhile, while others would have obfuscated for policymakers important information on the welfare effects of regulatory actions.