1 Feb 2008
Objectivity in Risk Assessment:
The National Intelligence Estimate on Iran, Part 4
by Richard Belzer
in Regulatory Science, Regulatory Policy
The subject of the 2007 National Intelligence Estimate of Iran's nuclear weapons program is not the dominant subject of news reporting that it was when we first posted on it. However, a conventional narrative has developed to the effect that Iran's nuclear ambitions and developmental efforts are no longer a legitimate concern.
Today we hope to finish our series on this subject showing why this narrative is based on value-based preferences that various people and interest groups hold, and is not supported by the NIE itself.
More...
6 Dec 2007
Objectivity in Risk Assessment:
The National Intelligence Estimate on Iran, Part 3
by Richard Belzer
in Information Quality, Regulatory Policy
The web is chock full of commentary on the recently released summary of the National Intelligence Estimate on Iran. (We emphasize summary because the body of the NIE remains classified.) We've posted here and here on the NIE as a risk assessment document, noting that it claims to be an objective assessment not confounded by risk management (i.e., policy or political) concerns.
We've read much (but by no means all) of this news and commnetary and drawn some inferences we hope are useful. More...
4 Dec 2007
Objectivity in Risk Assessment:
The National Intelligence Estimate on Iran, Part 2
by Richard Belzer
in Regulatory Policy
Early today we posted the unclassified summary of the recent National Intelligence Estimate on Iran's nuclear intentions and capabilities. We said that while we could not comment on its substance -- the details leading to the published judgments remain classified -- the document itself appeared to be notable for its transparency of language, recognition of uncertainty, and the clarity with which it defined the probabilistic language used to describe both the substantive judgments reported and analysts' confidence in them.
Today's news reporting on the NIE shows why it is so important that risk assessments be performed in an objective manner: risk managers, other political actors, and the press often want risk assessments to support predefined narratives and policy views. In less than a day, many of them have stripped away the NIE's careful calibration of uncertainty, suggested that its judgments are colored by the expectation that it would be made public, and undermined the case for performing risk assessment by using it for partisan political purposes. More...
Objectivity in Risk Assessment:
National Intelligence Estimate of Iran's Nuclear Weapons Program
by Richard Belzer
in Regulatory Science
An unusual example of risk assessment appeared today in the news: the disclosure of an unclassified summary of the November National Intelligence Estimate (NIE) concerning Iran's nuclear weapons program. The document, which for obvious reasons is not transparent and reproducible, nevertheless is remarkably clear about the uncertainties which underlie its estimates. More...
16 Nov 2007
Can States Regulate Immigration? Part 4b
NY Governor abandons 3-tiered driver license plan
by Richard Belzer
in Regulatory Economics, Regulatory Policy
This week, New York Governor Elliot Spitzer abandoned his plan for a three-tiered driver license program that would have allowed illegal aliens to obtain an inferior-form license. More...
19 Sep 2007
OMB's Principles for Risk Analysis:
OMB's initial response to the National Academy of Sciences
by Richard Belzer
in Regulatory Policy, Regulatory Science
Today the Office of Management and Budget issued a memorandum to agency heads directing them to adhere to certain principles of risk analysis. The memorandum is OMB's initial response to the report of a National Research Council panel that OMB asked to review a 2006 proposed bulletin on risk assessment. That report called the proposed text "fundamentally flawed" and gave seven recommendations, one of which was that it be withdrawn.
A fair reading of the new memorandum is that OMB followed this specific recommendation. More...
13 Aug 2007
Benefit-cost Analysis and Real World Decision Making:
The case of homeland security equipment maintenance
by Richard Belzer
in Regulatory Economics
Critics say benefit-cost analysis is a bad tool for choosing whether to
regulate. Supporters say it's a good tool because it
mimics how people and institutions normally make rational
decisions. Today's example is homeland security equipment purchased by
the federal government but left unmaintained by local governments.
More...
27 Jul 2007
Who Pays the Cost of Regulation?
Insights from corporate income tax incidence
by Richard Belzer
in Regulatory Economics
Regulation is widely understood as a tax on the activity or person being regulated. Where these activities repair genuine market failures, benefits from regulation may result. If there are benefits from, say, automobile safety regulation, one would expect the beneficiaries to be persons who otherwise would have been killed or injured at the pre-regulatory safety level.
But what about the costs of regulation? Who bears them? More...
22 Jul 2007
TSA Relaxes Restrictions on Butane Lighters
Why risk-based security regulations can be hard to implement
by Richard Belzer
in Regulatory Economics
On August 4, the federal Transportation Security Administration will permit butane lighters in carry on baggage. Why is TSA allowing them now? Why were they banned in the first place?
More...
11 May 2007
Government-wide Information Quality Guidelines:
Does journal peer review achieve "adequate" objectivity?
by Richard Belzer
in Glossary, Information Quality, Peer Review
Federal guidelines require information disseminated by federal agencies to satisfy a few broad criteria, one of which is objectivity. These guidelines give a "rebuttable presumption" to scientific information published in scholarly journals.
- Do all scholarly journals transmit this rebuttable presumption of objectivity? What about scholarly journals that also have an advocacy mission?
- What is the burden of proof for mounting a successful rebuttal?
More...
9 May 2007
Federal Agency Guidance Documents:
What's "significant"?
by Richard Belzer
in Regulatory Policy
OMB has new procedures for agencies to follow in making significant guidance documents transparent.
We posted an extensive discussion on OMB's Bulletin on Good Guidance Practices, and recently OMB issued an implementation memorandum. Yesterday we commented on the first task facing federal regulatory agencies: assembling and publishing online lists of guidance documents.
Today we address another fundamental question: What constitutes a "significant" guidance document, an d how is this determination made? More...
8 May 2007
Federal Agency Guidance Documents:
Building the inventory
by Richard Belzer
in Regulatory Policy
Executive Order 13422 and OMB's Bulletin on Good Guidance Practices will lead to major changes in the way federal agencies issue guidance.
The first step for each agency is to develop and publish inventories of their significant guidance documents. The deadlines for agency compliance are July 24, 2007 (for significant guidance documents issued on or after January 25, 2007) and August 23, 2007 (for all significant guidance documents). More...
7 May 2007
The New OMB Regulatory Review Procedures:
A primer on implementation
by Richard Belzer
in Regulatory Policy
On April 25 OMB issued guidance to agencies concerning the implementation of Executive Order 13422. More...
14 Mar 2007
Risk Management Under Uncertainty
Preventing terrorism
by Richard Belzer
in Regulatory Policy, Regulatory Science
The classic risk management problem consists of making decisions under uncertainty. Any decision, no matter how carefully considered and well informed, can err in either of two ways:
- By failing to prevent a risk from occurring
- By preventing a risk through the creation of a different risk
14 Feb 2007
Executive Order 13422, Part 5a
The House subcommittee oversight hearings
by Richard Belzer
in Regulatory Policy
Today we start a series summarizing the testimony from all eight witnesses who appeared yesterday before two separate House oversight subcommittees. More...
