I’m pretty late to the party here, but I want to say I really enjoyed the piece! Your piece came out only three weeks before the big draft overhaul to the way that the U.S. does benefit-cost analysis came out, which is in a document called Circular A-4. I think there is a lot I’d change around the choices in the analysis, particularly in light of the new draft A-4 Guidance (most of which goes in favor of putting more weight on catastrophes):
The old A-4′s use of a 7% discount rate on capital didn’t make sense because the 7% includes other factors outside of time preference (in particular risk aversion). The new A-4 has a much better treatment of discounting capital: which is applying a shadow price of capital adjustment, which is somewhere between a factor of 1-1.2 (so it’s not too much of an adjustment in any case). The upshot of all of this is that, based on the new A-4, you should be using a 1.7% discount rate for impacts out to 30 years, which is drastically different than the 7% discount rate that you were using and which will put more weight on the future (and appropriately so from the descriptive point of view to reflect people’s tradeoffs between money now and money in the future in capital markets).
For impacts beyond 30 years, standard economic theory and the new A-4 suggest that you should be using a declining discount rate to account for future interest rate uncertainty (see my brief description here). The A-4 preamble has a proposed schedule of declining discount rates, which goes down to 1% 140 years in the future. This will also place more value on the future.
President Biden’s Presidential Memorandum and the new A-4 are quite clear (see summary of A-4′s temporal scope of analysis section) that the interest of future generations should be taken into account when they will be impacted by important benefits and costs from some policy. In fact, the U.S. had previously been accounting for the impacts of climate change out to 500 years in BCA (in the Obama, Trump, and Biden administrations) through the use of the Social Cost of Greenhouse Gases, so impacts on future generations had been taken into account in that context, and should be taken into account in these other contexts as well, as discussed in the new draft A-4.
Much of your analysis seems to only look at the direct impacts on Americans. However, A-4 has a robust discussion around the conditions under which it is important for analysts to include global impacts, such as “regulating an externality on the basis of its global effects supports a cooperative international approach to the regulation of the externality by potentially inducing other countries to follow suit or maintain existing efforts.” This recognizes that global externalities/risks like pandemics, biosecurity, climate change, etc. require international regulatory cooperation. If, e.g., a new global pandemic is caused by poor biosecurity regulatory oversight in other countries, this harms Americans. Both because Americans will get sick and die, but also because disruptions in other countries will cause significant harm to the global economy, global trade, and global stability that will in turn harm Americans. Just as poor biosecurity regulatory oversight in the U.S. causing a pandemic will cause harm in other countries for the same reasons. Note that this is also the approach that the U.S. Government has taken to account for climate change in BCA through the Social Cost of Greenhouse Gases by considering global damages from climate change and not just domestic damages. As that document states, global externalities like greenhouse gas emissions and biosecurity policy imply that the whole world enjoys the benefit of one country’s decisions to reduce the harm from the global externality, and therefore “the only way to achieve an efficient allocation of resources for emissions reduction on a global basis—and so benefit the U.S. and its citizens and residents—is for all countries to consider estimates of global marginal damages” from the externality as well as the global marginal benefits of taking actions to reduce the externality.
Although your post is about risks, I didn’t see mention of accounting for Risk Aversion, which is one of the most consistent features of human preferences and should be reflected in BCA. The draft A-4 instructs BCA practitioners to explicitly account for uncertaintywhen doing BCA as well as risk aversion across that uncertainty. This ends up placing more weight on the benefits that help to avoid catastrophes, and thus would tend to favor policies that reduce the probability of catastrophes (e.g. pandemic preparedness).
And finally, much of your analysis seems to hinge on probabilities for catastrophes that come from e.g. the EA community or Prediction Markets. Because you choose to account for a very limited scope of impacts across time and space at a very high discount rate, those probabilities end up having to do a lot of work for the analysis to yield net benefits. My sense is for the purposes of BCA for U.S. regulatory impact assessments, these probabilities may be viewed as too speculative (at least for anthropogenic risks) and may be challenged in getting through the various processes that BCAs for regulations must go through including public comment, OIRA review, and then ultimately litigation in court where most rules are inevitably challenged. Fortunately, A-4 has a tool that provides a way forward in this situation: Break Even Analysis. Break-even analysis provides a way forward when there is a high degree of uncertainty/ambiguity in important parameters, and you need to determine what those parameters would need to be for the policy to still yield positive net benefits. This is particularly relevant for catastrophic events: “For example, there may be instances where you have estimates of the expected outcome of a type of catastrophic event, but assessing the change in the probability of such an event may be difficult. Your break-even analysis could demonstrate how much a regulatory alternative would need to reduce the probability of a catastrophic event occurring in order to yield positive net benefits or change which regulatory alternative is most net beneficial.”
To Summarize, I think U.S. BCA practice actually offers a much wider variety of tools for assessing catastrophic risks, which benefits the interest and welfare of Americans, and those tools should be utilized.
I’m pretty late to the party here, but I want to say I really enjoyed the piece! Your piece came out only three weeks before the big draft overhaul to the way that the U.S. does benefit-cost analysis came out, which is in a document called Circular A-4. I think there is a lot I’d change around the choices in the analysis, particularly in light of the new draft A-4 Guidance (most of which goes in favor of putting more weight on catastrophes):
The old A-4′s use of a 7% discount rate on capital didn’t make sense because the 7% includes other factors outside of time preference (in particular risk aversion). The new A-4 has a much better treatment of discounting capital: which is applying a shadow price of capital adjustment, which is somewhere between a factor of 1-1.2 (so it’s not too much of an adjustment in any case). The upshot of all of this is that, based on the new A-4, you should be using a 1.7% discount rate for impacts out to 30 years, which is drastically different than the 7% discount rate that you were using and which will put more weight on the future (and appropriately so from the descriptive point of view to reflect people’s tradeoffs between money now and money in the future in capital markets).
For impacts beyond 30 years, standard economic theory and the new A-4 suggest that you should be using a declining discount rate to account for future interest rate uncertainty (see my brief description here). The A-4 preamble has a proposed schedule of declining discount rates, which goes down to 1% 140 years in the future. This will also place more value on the future.
President Biden’s Presidential Memorandum and the new A-4 are quite clear (see summary of A-4′s temporal scope of analysis section) that the interest of future generations should be taken into account when they will be impacted by important benefits and costs from some policy. In fact, the U.S. had previously been accounting for the impacts of climate change out to 500 years in BCA (in the Obama, Trump, and Biden administrations) through the use of the Social Cost of Greenhouse Gases, so impacts on future generations had been taken into account in that context, and should be taken into account in these other contexts as well, as discussed in the new draft A-4.
Much of your analysis seems to only look at the direct impacts on Americans. However, A-4 has a robust discussion around the conditions under which it is important for analysts to include global impacts, such as “regulating an externality on the basis of its global effects supports a cooperative international approach to the regulation of the externality by potentially inducing other countries to follow suit or maintain existing efforts.” This recognizes that global externalities/risks like pandemics, biosecurity, climate change, etc. require international regulatory cooperation. If, e.g., a new global pandemic is caused by poor biosecurity regulatory oversight in other countries, this harms Americans. Both because Americans will get sick and die, but also because disruptions in other countries will cause significant harm to the global economy, global trade, and global stability that will in turn harm Americans. Just as poor biosecurity regulatory oversight in the U.S. causing a pandemic will cause harm in other countries for the same reasons. Note that this is also the approach that the U.S. Government has taken to account for climate change in BCA through the Social Cost of Greenhouse Gases by considering global damages from climate change and not just domestic damages. As that document states, global externalities like greenhouse gas emissions and biosecurity policy imply that the whole world enjoys the benefit of one country’s decisions to reduce the harm from the global externality, and therefore “the only way to achieve an efficient allocation of resources for emissions reduction on a global basis—and so benefit the U.S. and its citizens and residents—is for all countries to consider estimates of global marginal damages” from the externality as well as the global marginal benefits of taking actions to reduce the externality.
Although your post is about risks, I didn’t see mention of accounting for Risk Aversion, which is one of the most consistent features of human preferences and should be reflected in BCA. The draft A-4 instructs BCA practitioners to explicitly account for uncertainty when doing BCA as well as risk aversion across that uncertainty. This ends up placing more weight on the benefits that help to avoid catastrophes, and thus would tend to favor policies that reduce the probability of catastrophes (e.g. pandemic preparedness).
And finally, much of your analysis seems to hinge on probabilities for catastrophes that come from e.g. the EA community or Prediction Markets. Because you choose to account for a very limited scope of impacts across time and space at a very high discount rate, those probabilities end up having to do a lot of work for the analysis to yield net benefits. My sense is for the purposes of BCA for U.S. regulatory impact assessments, these probabilities may be viewed as too speculative (at least for anthropogenic risks) and may be challenged in getting through the various processes that BCAs for regulations must go through including public comment, OIRA review, and then ultimately litigation in court where most rules are inevitably challenged. Fortunately, A-4 has a tool that provides a way forward in this situation: Break Even Analysis. Break-even analysis provides a way forward when there is a high degree of uncertainty/ambiguity in important parameters, and you need to determine what those parameters would need to be for the policy to still yield positive net benefits. This is particularly relevant for catastrophic events: “For example, there may be instances where you have estimates of the expected outcome of a type of catastrophic event, but assessing the change in the probability of such an event may be difficult. Your break-even analysis could demonstrate how much a regulatory alternative would need to reduce the probability of a catastrophic event occurring in order to yield positive net benefits or change which regulatory alternative is most net beneficial.”
To Summarize, I think U.S. BCA practice actually offers a much wider variety of tools for assessing catastrophic risks, which benefits the interest and welfare of Americans, and those tools should be utilized.
Thanks, Danny! This is all super helpful. I’m planning to work through this comment and your BCA update post next week.