Abstract

This is a response to an article by Professor Dan Farber presented in a symposium about the Trump Administration and Administrative Law at Chicago-Kent School of Law. After agreeing with Professor Farber’s description, analysis and critique of the Trump Administration’s use and abuse of cost benefit analysis as an aid in making regulatory decisions, Professor Pierce makes four points: (1) President Trump will fail to implement his deregulatory agenda; (2) EPA’s proposed rule on transparency of scientific evidence is a good start on an important project; (3) the Clean Power Plan is a lost cause; and, (4) The Trump Administration may unintentionally end the practice of applying cost benefit analysis to regulatory decisions.

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