EPA's Costs of Preparing Regulatory Impact Analyses

Pursuant to a congressional request, GAO reviewed the costs the Environmental Protection Agency (EPA) incurs in preparing regulatory impact analyses (RIA) to support EPA's implementation of the Clean Air Act Amendments of 1990. GAO noted that: (1) EPA's Office of Air and Radiation, which has four program offices, does not have a systematic way to identify and track all of its costs for preparing RIAs; (2) only two of the program offices are currently identifying and tracking the contract costs associated with preparing RIAs; (3) none of the program offices are identifying and tracking the in-house costs of preparing RIAs; (4) because none of the offices had a systematic way to identify and track total costs, GAO requested program officials to provide it their best available cost data for preparing the 27 RIAs issued after enactment of the Clean Air Act Amendments of 1990; (5) according to program officials, the data on contract costs were generally based on the cost estimates in the contract work assignments and the data on in-house costs were based on the project officers' best estimates; (6) total estimated cost to prepare the 27 RIAs exceeded $13 million; (7) costs to prepare specific RIAs ranged from $46,000 to $3.8 million; (8) the types of contract costs that project officers included varied for the 27 RIAs; and (9) according to Office of Air and Radiation program officials, the costs to prepare the 27 RIAs varied because: (a) some RIAs supported regulations that were controversial or complex; (b) some RIAs used data that were already available; and (c) some project officers were inconsistent in the type of cost data they included in their estimates.