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Appendix G: Methods and Limitations of Regulatory Assessment
Pages 179-182

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From page 179...
... As noted below, DHS has employed breakeven analysis in much of its recent analyses of major regulatory actions to address terrorism threats. BCA, cost-effectiveness analysis, and breakeven analysis have gained acceptance in state and local policy making and among nongovernmental entities, but all three methods have limitations.
From page 180...
... discover which of various possible alternatives would be the most cost-effective," 231 but it notes that efficiency might not be the only or overriding public policy objective. OMB also warns that good regulatory analysis is not strictly formulaic; rather, it requires competent professional judgment, transparency, and well-documented supporting evidence, including a discussion of the sensitivity of the results to embedded assumptions.
From page 181...
... ANALYTICAL CHALLENGES Assessing the benefits of actions to prevent or reduce losses from terrorist attacks (e.g., estimates of potential reductions in deaths and injuries, property damage, or various social effects) under extremely uncertain conditions poses substantial challenges.236,237,285,286 Such an analysis would require an explicit characterization of the underlying risk of a terrorist attack and an understanding of the ways in which the regulations might affect that risk, which would, in turn, present analytical obstacles.
From page 182...
... Members of the policy community have recognized DHS's adoption of break-even analysis as a step forward in the evolution of analysis of terrorism security policy, but have called for further advancement.237 In a DHS-sponsored workshop held at the RAND Corporation in 2011, the agency itself sought to identify novel approaches to valuing benefits and, potentially, to move beyond break-even analysis.236 For example, DHS staff presented a fault tree approach that can be used to map existing security programs and policy mechanisms and to estimate event failure probabilities, such as the failure of existing efforts to stop the entry of terrorists into the United States. In developing these models, expert judgment is essential.

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