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U.S. EPA, policy advocates should improve job impact analyses, says report

The ICI-BMACT rules were under fire by opponents as job-killers; the major CIBO/IHS jobs analysis of the impact of the ICI-BMACT rules was termed “flawed” by the Congressional Research Service (CRS), and readers were warned not to put much stock in the job-killer analysis.

Now the Institute for Policy Integrity weighs in with a new report, Regulatory Red Herring: The Role of Job Impact Analyses in Environmental Policy Debates, telling both USEPA and policy advocates that they need to do more to incorporate job impact analyses into their assessments of environmental regulations. The report can be downloaded at

Applying proper analytical tools and disclosing assumptions and modeling limitations will provide policymakers with the necessary data to develop regulations, Michael Livermore, executive director of the institute, says. Some analyses of USEPA regulations produce flawed jobs impact predictions because they apply “these models in ways they were never intended to be used,” said Livermore, who was lead author of the report.

“Nearly every controversial environmental policy proposed during the last several years has featured a debate over the possible employment effects,” the report said. “Unfortunately, few of the studies used to support either side in these debates meet the criteria for well-executed models, and even less frequently do the political debates mention the potential limitations of the results,” Livermore noted.

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