ABSTRACT
Critics allege that regulatory impact analyses (RIAS) serve as little more than a fig leaf to hide the contributions of controversial participants in the rulemaking process and provide an illicit entry point for the White House to tinker with agency decisions when an RIA indicates that the agency's proposal is too costly. Others argue that RIAs provide an unaccountable forum for conservative-leaning economists to hijack or at least delay agency policies by requiring analyses that use inherently under protective economic methods and assumptions. The Clean Air Interstate Rule (CAIR) RIA now provides strong evidence for a third, somewhat overlapping source of concern: namely, that RIAS may serve primarily as a mechanism for promoting agency decisions rather than scrutinizing them.
