87 research outputs found

    Проблемы информационного обеспечения в управлении предприятиями медиаиндустрии

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    Авторами статті визначено та узагальнено сучасні проблеми інформаційного забезпечення спеціалістів підприємств медіагалузі. На основі аналізу положень чинних нормативно-законодавчих актів та поточного стану медіагалузі визначено основні причини нестачі релевантної інформації для економіко-статистичного аналізу як діяльності окремих підприємств, так і галузі загалом.The authors of an article have identified and summarized the current problems of information support of media industry enterprise specialists, based on analysis of the articles of the current regulatory legislation and the current state of the media industry. The main reasons for the lack of relevant information for an economic and statistical analysis of both individual companies and the industry as a whole have been identified. The main problem is that the media industry is not a solid object of statistical studies of national statistics. A large number of informal segments of media products, the opacity of the industry in general, deepens it. Separately, the authors examined the question of the need to develop and expand the concept-categorical instrument of research methodology of media business, terminological clarification of many concepts. Indeed, as shown by analysis, application of the traditional scientific methodology of economic and statistical analysis for research is almost impossible.Авторами статьи определены и обобщены современные проблемы информационного обеспечения специалистов предприятий медиаотрасли. На основе анализа положений действующих нормативно-законодательных актов и текущего состояния медиаотрасли определены основные причины нехватки релевантной информации для экономико-статистического анализа, как деятельности отдельных предприятий, так и отрасли в целом

    Understanding Mechanical Properties in Fused Filament Fabrication of Polyether Ether Ketone

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    Using dynamic mechanical analysis (DMA), we investigate differences in the mechanical properties of a single-filament wall of polyether ether ketone (PEEK) constructed using fused filament fabrication (FFF) under a range of different printing conditions. Since PEEK is a semi-crystalline polymer, we employ a non-isothermal quiescent crystallization model, informed by infrared (IR)-imaging measurements, to understand our findings. We propose that, under typical FFF cooling conditions, the weld region between filaments remains amorphous. In contrast, the core of the filament has increased time above the glass transition temperature allowing for a signifocant crystal fraction to develop. We correlate the predicted crystal fraction to a storage modulus using the Halpin and Kardos model. With only a single model fitting parameter we can make reasonable predictions for the perpendicular and parallel storage moduli measured via DMA over a range of printing conditions. This work provides a foundation for optimising crystallization for the mechanical performance of the FFF printed PEEK

    Why are financial systems prone to crisis?

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    At the peak of the Netherlands’ “tulip mania” in 1637, one tulip bulb sold for 5,500 guilders per bulb—roughly the cost of luxurious house in Amsterdam, or $25,000 today. More than three and a half centuries later, economists continue to debate why tulip prices skyrocketed to stratospheric levels in the 1630s, much in the same way that the 2008 Global Financial Crisis remains a source of contention. Why have financial systems been so vulnerable to crises, and what role has regulation played? In a chapter of the forthcoming Oxford Handbook of Financial Regulation, Frank Partnoy of the University of San Diego School of Law examines financial crises through an historical lens, arguing that scholars of crisis economics should move away from a heavily financial focus and place a heavier emphasis on the role of regulation in contributing to and preventing crises. Partnoy considers the key theories of the roots and causes of crises, and subsequently reviews the potential of policy and governance mechanisms to mitigate crises. Acknowledging that regulation plays a critical role in alleviating and exacerbating crises, Partnoy suggests that research could improve financial policy by focusing not only on what elements of the regulatory toolkit work but also on the risk that certain kinds of regulation can pose. Why do financial market crises arise? Partnoy argues that a combination of multiple causes likely explains the vulnerability of the financial system to crises. He points to the work of economists Charles Kindleberger, Hyman Minsky, Irving Fisher, and Charles Mackay, whose cognitive error theory proposes that panics proliferate in the financial system due to bounded rationality and investor psychology. According to the cognitive error theory, several stages characterize markets during the onset of a financial crisis: (1) a “displacement,” such as technological innovation, creating new opportunities for profit; (2) “credit expansion,” during which capital is heavily allocated to new profitable ventures; (3) “euphoria” as investors seize upon new opportunities to reallocate capital, entering a condition of speculative excess; (4) a “panic” whereby some signal such as a bank failure causes a few investors to sell, leading prices to plummet as more speculators exit the market; and (5) a “crash” whereby debts exceed what borrowers can pay off, causing the economy to contract. Alternatively to the cognitive error theory, Robert Shiller, Zvi Bodie and Robert Merton propose that moral hazard in the form of government guarantees distorts investor behavior, leading to excessive risk-taking. In other words, the blame for financial crises rests squarely on regulatory instruments such as insurance protections, not on behavior by private actors. Yet, Partnoy points out that moral hazard cannot completely account for crises, as financial crashes were much more common before the existence of deposit insurance and lender-of-last-resort regulation, occurring almost every decade before the 1930s and becoming virtually nonexistent from the 1940s until 2008. Partnoy next presents information asymmetry, agency costs, and the Efficient Market Hypothesis (EMH) as three additional market failures that potentially explain why the financial system remains crisis-prone. The information asymmetry argument proposes that the knowledge gap between investors and issuers—with the latter always possessing better information about asset prices and fundamentals than the former—primarily explains crises. Information gaps thus eventually lead to investor euphoria, ending in panic and crisis. However, Partnoy says that the theory does not take note of the fact that bank managers—much like investors—were also uninformed about mortgage and correlation risks prior to the 2008 crash. In addition to the agency costs problem—which posits that managers and investors have misaligned incentives, leading to excessive risk-taking at shareholders’ expense—the EMH argument posits that in an ideal world, share prices will incorporate all relevant information; however, in practice, factors such as poor government and macroeconomic policies may lead to a misallocation of credit, triggering a crash. Partnoy then asks how regulatory policy can help prevent and mitigate financial crises. First, he considers governance regulation in the form of imposition of monitoring and disclosure duties on boards of directors. While in theory these duties would help correct the incentive misalignment problem between managers and investors, Partnoy argues that such solutions are shortsighted in practice. In a large, publicly held company, he says, boards of directors are highly unlikely to have the capability to play an effective monitoring role. He highlights the Delaware Chancery Court’s decision in the Citigroup derivative case—which held the company’s board to a relaxed liability standard for monitoring and risk-related decisions—as an example of the reality that many risks simply cannot be identified or understood ex ante. Partnoy says that bank capital requirements and capital controls also have serious drawbacks as regulatory instruments. Although the voluntary set of bank capital standards suggested by the Basel Committee on Banking Supervision (BCBS) is more appealing in its flexibility than a heavy-handed approach, Partnoy argues that bank capital requirements’ overreliance on privately provided credit ratings creates distorted decision-making, and banks’ ability to use derivatives to circumvent those requirements means that risk nonetheless remains high. Likewise, capital controls such as restrictions on capital inflows and outflows simply create incentives for financial institutions to engage in regulatory arbitrage. Yet another regulatory technique—the creation of currency boards—is unappealing in its rigidity because it limits a country’s central bank from setting monetary policy according to domestic considerations. Partnoy concludes that financial stability is a “public good” that is non-rival in that one user’s consumption does not diminish another’s, and non-excludable in that it is difficult to exclude consumers from partaking in its benefits. Accordingly, financial stability—like other public goods—needs to be provided by regulation. Emphasizing the reality that financial crises are rooted in several types of market failures, Partnoy recommends that policymakers and academics carefully re-examine specific regulatory tools to see what works, while not forgetting about the potential risks of regulation

    Sociodemographic basis of tuberculosis knowledge in Bolivia.

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    The Effect of Income Disparity on Financial Regulation

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    As Occupy Wall Street protesters descended on Zuccotti Park in September 2011, the use of the phrase “income inequality” on major news networks, cable, and in leading newspapers grew four-fold. That same year, amid criticism that financial executives pocketed huge bonuses while shareholders faced losses, the Securities and Exchange Commission (SEC) adopted “say on pay” rules, letting investors vote on executive compensation. And in a speech in December 2013, President Barack Obama called income inequality “the defining challenge of our time.” What about a different kind of pay gap—that between the financial industry and their regulators? What is the magnitude of that gap, and could it have adverse consequences for financial regulation? In a forthcoming paper, Steven Schwarcz of Duke University School of Law demonstrates that a two-to-one income disparity exists between financial industry employees and their regulators. He argues that this pay gap impedes the ability of administrative agencies to hire competitively, thereby creating an information asymmetry between industry and regulators that may trigger failures in agency rulemaking, monitoring, and enforcement. Schwarcz says that while reducing the income disparity between industry and regulators would be a politically strenuous endeavor, potential solutions do exist and the United States would do well to consider them. The Bureau of Labor Statistics (BLS) reports that federal government employees, who are paid in accordance with the General Schedule or the Executive Schedule overseen by the Office of Personnel Management (OPM), receive twenty-five percent lower pay on average than private sector workers in comparative positions. Collating data from BLS surveys, USAJOBS, and the Office of the Controller of the Currency (OCC), Schwarcz finds that a much wider income differential exists between financial regulators and members of the industry they regulate. For example, entry-level Federal Insurance Deposit Corporation (FDIC) employees make 51,630onaverageandseniorpolicyanalystsstartat51,630 on average and senior policy analysts start at 145,757, he says, while entry-level investment bankers had a median annual salary of 90,560andhighlevelfinancialmanagersearned90,560 and high-level financial managers earned 160,900 in 2012. Schwarcz emphasizes that these figures do not account for a popular form of compensation in the financial industry: options and bonuses. The Office of the New York State Comptroller estimates that Wall Street bonuses averaged 139,940in2010.Withbonusesmuchrarerandmoremodestwithinthepublicsector,Schwarcznotes,seniorfinancialregulatorswouldearn139,940 in 2010. With bonuses much rarer and more modest within the public sector, Schwarcz notes, senior financial regulators would earn 147,757—as noted above—while their private sector counterparts would pocket $300,840, amounting to twice-as-high compensation for the financial industry over regulators. Schwarcz contends that this two-to-one income disparity impedes administrative agencies’ efforts to hire the best recruits, thereby leading to an asymmetry between regulators and the financial industry. In fact, a 2002 report by the General Accounting Office (GAO) in the wake Enron’s collapse and the SEC staffing crisis found that “inadequate compensation is the primary reason employees leave the agency.” All other things being equal, Schwarcz notes, people will always choose a job offering greater pay. He then asks, what are the circumstances under which the best financial employees would self-select lower-paying positions at any stage in their careers? Schwarcz uses the Public Service Motivation (PSM) framework to assess how human beings would make such job decisions. PSM, which posits that public employees act out of a desire to promote the public good, suggests that financial regulators would actively choose to earn less in order to work in public service rather than the private sector. However, empirical evidence has demonstrated that the theory does not always translate into practice, says Schwarcz. Although a study by former Secretary of the U.S. Department of Commerce and current chancellor of the University of Wisconsin-Madison, Rebecca Blank, has found that workers with higher levels of experience and education are more likely to self-select into the public sector, recent research suggests that PSM would be insufficient to overcome the two-to-one income disparity, according to Schwarcz. For example, a study by Gregory Lewis of Georgia State University shows that individuals who value income and would rather work for the public sector are more likely to work for the private sector. The Cornell Happiness Study finds that individuals are more likely to choose a higher-paying job with longer work hours than a lower-paying job with reasonable work hours. Schwarcz argues that the income disparity therefore triggers an information asymmetry between financial regulators and industry arising from a difference in employee abilities and intellect. In turn, that information asymmetry could have adverse consequences on agency rulemaking, monitoring, and enforcement. Without a clear understanding, Schwarcz says, regulators may not only implement inadequate rules but also misinterpret the financial innovations altogether, issuing potentially harmful rules. Absent a clear grasp of financial products, regulators may be unable to monitor them effectively, contributing to information-based market failures. Finally, lack of resources, staffing, and expertise may impede a regulator’s ability to enforce highly complex rules and regulations. Several ways to decrease the information asymmetry exist, says Schwarcz, but they are not without their own problems. For example, the United States could follow the example of the Monetary Agency of Singapore (MAS), which pegs its salaries to those of the financial industry. While the International Monetary Fund (IMF) has argued that MAS’s strategy has enabled it to attract and retain top regulatory talent, thus establishing Singapore as a financial center, Schwarcz says that the U.S. financial industry may simply respond by raising private salaries to exceed any public sector raises. Another way to reduce the information asymmetry, Schwarcz says, could involve increasing standardization of financial products or paying third parties to reduce the asymmetry. Pointing to the Dodd-Frank Act’s clearinghouse requirement, however, Schwarcz argues that because third parties, like clearinghouses, also concentrate risk, such standardization may inadvertently act to increase systemic risk. Increasing regulatory specialization is yet another solution, says Schwarcz, but it is imperfect. He points to the Financial Sector Assessment Program (FSAP)—in which the World Bank brought together a team of specialists to diagnose problems within the financial system—to illustrate that the ability of teams to capitalize synergistically on individual expertise fades over time. Perhaps simply accepting that ex ante financial regulation cannot alone prevent financial failures and focusing more resources ex post is the way to reduce the information asymmetry, says Schwarcz. Reducing the two-to-one income disparity between financial regulators and the industry they regulate is a politically challenging task, Schwarcz concludes, especially in a period of growing concern about budget deficits and growing federal debt. However, he argues that the existence of information asymmetries between regulators and industry is an arena that needs greater focus, so that future financial crises can be avoided

    How to Prevent Another Measles Outbreak

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    In 1950s America, approximately 3.5 million children contracted measles each year, resulting in 48,000 hospitalizations, 4,000 cases of acute brain inflammation and 500 deaths on average, according to the Centers for Disease Control and Prevention (CDC). But after the introduction of the measles vaccine and the passage of the Vaccination Assistance Act in 1963—providing federal support to state and local mass immunization campaigns for the first time in history—measles incidence shrank dramatically. With over 90% of children receiving the MMR vaccine in the 1990s, the CDC victoriously declared in 2000 that measles had been eliminated. Flash-forward to 2014, when the U.S. suffered a record-breaking, multi-state measles outbreak: 668 cases in 27 states. What prompted the return of a disease that had virtually vanished more than a decade ago? In a recent article, Georgetown University’s Lawrence Gostin argues that overbroad exemptions to state vaccination requirements are to blame. Every state requires children older than five years of age enrolled in state-licensed day care centers, public schools and—in most states—private schools to receive certain vaccinations. Although a team of 15 medical and public health experts called the Advisory Committee on Vaccination Practices (ACIP) develops federal recommendations for routine administration of vaccines, only states have the power to mandate them, Gostin explains. Yet, state immunization laws and regulations are also riddled with exemptions, says Gostin. All states grant physician-certified medical exemptions for children who have immune deficiencies, allergic reactions and other contraindications. Additionally, all but West Virginia and Mississippi presently allow exemptions on the basis of religious belief, and 20 states permit exemptions due to “personal,” “moral,” or “other” beliefs. There is nothing inherently wrong with vaccination exemptions, says Gostin. The problem, he contends, lies in states’ grossly varying requirements for obtaining non-medical exemptions. To receive a philosophical exemption in Arkansas, for example, parents must submit a notarized request, undergo immunization counseling, and secure the health department’s approval. In contrast, Vermont’s Immunization Regulations require only a parent’s signature on a preprinted form. Although vaccine-exempt children constitute a small percentage of the school-age population, concedes Gostin, the number of exemptions has been increasing. As a consequence, vaccination rates are plummeting and vaccine-preventable diseases are on the rise, says Gostin. He points to a 2012 study by Emory University researchers demonstrating that exemption rates are 2.3 times lower in states with more rigorous exemption processes. Moreover, a 2006 study by Johns Hopkins University and CDC researchers revealed that states that easily grant non-medical exemptions have 50% higher pertussis rates, he emphasizes. Gostin attributes these trends to the erosion of “herd immunity.” In other words, when most individuals in the community are immunized against a contagious disease, the probability that non-immune individuals will come into contact with an infectious individual is small. Thus, even with few free riders, everyone is protected. But if large numbers of people invoking religious or philosophical beliefs in one community exempt themselves from vaccination, the cycle of herd immunity is broken, allowing a contagious disease to infiltrate the population. A safe neighborhood becomes a tragedy of the commons, says Gostin. Courts have long held compulsory vaccination programs to be well within states’ police powers due to the overriding public health interest at stake. For example, the Supreme Court upheld a smallpox mandate in 1905 and ruled that vaccinations required for school entry do not violate constitutional rights in 1922. But while medical exemptions are constitutionally required, waivers on religious and philosophical grounds are not, says Gostin. As such, allowing non-medical exemptions is—above all else—a political choice, he argues. According to Gostin, parents opposing mandatory vaccinations and seeking exemptions on philosophical and religious grounds cite a variety of concerns, particularly health risks. Even as the measles outbreak was underway, for instance, Senator Rand Paul, who believes vaccines should remain voluntary, claimed to have “heard of many tragic cases of walking, talking, normal children who wound up with profound mental disorders after vaccines.” Yet, as Gostin points out, the paper that launched the modern anti-vaccine movement—disbarred surgeon Andrew Wakefield’s 1998 study falsely linking the MMR vaccine to autism—has been retracted. Vaccines are certainly not risk-free, says Gostin, but the risks are generally mild, extremely rare, and well worth accepting to live in a society where outbreaks of potentially deadly diseases are uncommon. Gostin counsels states against adopting draconian solutions such as fining and imprisoning parents or resorting to tort litigation, arguing that these measures would create a backlash to vaccine policy. Although some states might opt to eliminate non-medical exemptions altogether, the better solution, Gostin says, is develop rigorous procedures for claiming non-medical exemptions. In the words of legal scholar Cass Sunstein, a “nudge” in the form of better education and tougher exemptions may be all that is required to raise vaccination rates, Gostin says. The recent measles outbreak rekindled a historic, impassioned debate about balancing public health and private choice. But when an individual’s rights put the lives of the larger community at risk, there is no debate, Gostin says. By ensuring that immunization exemptions are granted in rare, necessary circumstances, Gostin concludes, states can prevent another measles outbreak and protect the lives of children. And that is something he believes everyone can get behind

    The Case for FDA Regulation of Laboratory-Developed Diagnostic Tests

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    Before they can be commercially available, high-risk, life-sustaining medical devices such as pacemakers, HIV tests, and automated external defibrillators (AED) must undergo the Food and Drug Administration’s (FDA) premarket approval process—an extensive series of steps involving rigorous testing for safety and efficacy. Until recently, however, a decades-old exemption enabled a subset of diagnostic devices called Laboratory-Developed Tests (LDTs) to bypass this process completely. As a result, more than 11,000 medical diagnostic tests on the market have never been tested for accuracy, risks, or side effects. But last July—in a move that drew both high praise and fierce opposition—the FDA announced that it would consider placing LDTs under federal oversight for the first time in history. In a recent article, Joshua Sharfstein—Associate Dean at the Johns Hopkins School of Public Health and former Secretary of the Maryland Department of Health and Mental Hygiene— argues that the agency’s proposal is a long-overdue victory for patients. When medical device regulation began in the 1970s, lab-developed tests generally entailed hospital laboratories manually assessing individual patients, explains Sharfstein. LDTs were truly customized and used on a limited basis. But with the advent of technological innovation, private laboratory companies began widely marketing risky, highly complex, and automated LDTs that were largely indistinguishable from traditional medical devices, says Sharfstein. Sharfstein shows that these changes have generated myriad new concerns for patients. He says that the FDA has uncovered problems with lab-developed tests such as falsification of data and empirically unsupported claims. These problems, according to the FDA, could have led to over- or under-treatment for heart disease, cancer patients’ receipt of incorrect or ineffective care, erroneous autism diagnoses, or superfluous antibiotics treatment. Most worrisome to Sharfstein is the fact that the FDA cannot know the full extent of these problems because laboratories producing LDTs in an unregulated environment are not required to report adverse reactions, side effects, and the like. In a similar vein, the absence of regulatory oversight for lab-developed tests cripples physicians’ and patients’ ability to make informed critical decisions about diagnosis and treatment, Sharfstein says. In particular, while the FDA requires a traditional device manufacturer to verify a product’s effectiveness via clinical study, a company producing its own LDT is free to make claims without supporting them with research. As a result, Sharfstein states, patients and physicians may be compelled to rely on a faulty diagnostic test when making important health-related decisions. Sharfstein also provides a response to critics of regulating LDTs. Opponents—which include the American Hospital Association, the American Clinical Laboratory Association, and the American Medical Association—make three chief arguments. They argue that FDA regulation is redundant because the 1988 Clinical Laboratory Improvement Act (CLIA)—which regulates all laboratory testing except basic research and clinical trials—already establishes quality assurance standards, inspection and personnel requirements, recordkeeping regulations, and other standards for LDTs. Sharfstein replies that CLIA falls short because it fails to require external review before clinical use, verification of the clinical validity of a test, reporting of adverse effects, and compliance with standards for manufacturing quality. Critics of new LDT oversight also contend that the burden of regulation would eliminate essential LDTs that are otherwise unavailable to the public. However, Sharfstein notes that the agency’s draft guidance provides for a gradual phase-in period and exempts tests for rare diseases. Finally, although opponents claim that onerous FDA regulation would stifle progress in the arena of personalized medicine, Sharfstein claims that this argument is rooted in a fundamental misunderstanding of the nature of innovation. The drug innovations at the turn of the 20th century, he says, did not take off until the FDA implemented key safety and effectiveness requirements. Likewise, ensuring that LDTs minimize patient risks and maximize clinical validity will grease the wheels of innovation, driving investment in high-quality products that are safe and effective for patients. Thus, the right regulatory framework for lab-developed tests, concludes Sharfstein, will only propel the medical field forward

    The Democratic Case for Job Impact Analysis

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    When the Environmental Protection Agency (EPA) finalized its Mercury and Air Toxics Standards (MATS) and Cross-State Air Pollution Rule (CSAPR) in 2011, the American Coalition for Clean Coal Electricity (ACCCE) forecasted a 1.4 million job-year loss due to the costs the rules were expected to impose. By contrast, the Political Economy Research Institute (PERI) predicted a 1.4 million job-year gain as a result of these same regulations. Utility lobbyists and environmental groups pitted the two advocacy analyses against each other during congressional hearings, igniting a heated policy debate. Absent from that debate, though, was any rigorous, balanced, and transparent analysis, say legal experts Michael Livermore and Jason Schwartz in a chapter appearing in a new book produced by the Penn Program on Regulation. Livermore and Schwartz argue that regulatory analyses incorporating employment effects hold value beyond their use in calculating the benefits and costs of new regulations. They believe that the value of job impact analysis lies in its potential to serve as a deliberative tool that would inject reason into the jobs and regulation debate—a debate that has grown clouded with muddled political rhetoric. While including job effects would add a layer of complexity to cost-benefit analysis and come at an opportunity cost, such analysis would enlighten the political discourse and inform the public, say Livermore and Schwartz. By enabling citizens to assess regulations in light of job effects, federal agencies would be better able to justify regulatory choices to the public—an activity fundamental to a democracy. Livermore and Schwartz argue that efficiency grounds alone do not warrant resource-intensive job impact analysis in most cases. For example, they point to the EPA’s cost-benefit analysis of the Cross-State Air Pollution Rule, in which the agency estimated that the rule would generate 280billioninannualnetbenefits,avoidingupto34,000prematuredeathsperyear.Estimatedemploymenteffectsweremuchmoremodestbycomparison.Theagencyprojectedthatnewregulatorycomplianceprogramswouldcreateapositive2,230jobyearsandestimatedthattheannualneteffectonregulatedindustrieswouldrangefrom1,000to+3,000jobyears.Similarly,foritsBoilerMACTRule,whichinstitutedemissionlimitsonhazardousairpollutantsfromindustrialboilers,EPAputestimatedannualnetbenefitsbetween280 billion in annual net benefits, avoiding up to 34,000 premature deaths per year. Estimated employment effects were much more modest by comparison. The agency projected that new regulatory compliance programs would create a positive 2,230 job years and estimated that the annual net effect on regulated industries would range from -1,000 to +3,000 job years. Similarly, for its Boiler MACT Rule, which instituted emission limits on hazardous air pollutants from industrial boilers, EPA put estimated annual net benefits between 25.2 and $65.5 billion and premature deaths avoided at 8,000. However, net employment effects fell between -4,000 and +8,300 jobs. As the academic literature notes, and Livermore and Schwartz confirm, save for rare cases, employment effects are unlikely to shift a rule’s cost-benefit calculus. Nonetheless, Livermore and Schwartz argue, opponents and proponents of regulation have in recent years deployed exaggerated and unsubstantiated claims about employment impacts, particularly in the arena of environmental regulation. Advocacy groups’ economic reports have proliferated in public discourse, fueling an overheated, politicized debate on jobs and regulation. Yet, while these advocacy reports have been quick to provide seemingly definitive numbers to bolster competing claims, a discussion of the studies’ assumptions, uncertainties, and limitations has been absent from the political debate. Livermore and Schwartz examine two industry reports released in August 2010 predicting that the Boiler MACT Rule would result in hundreds of thousands of jobs lost. The first, produced by the Council of Industrial Boiler Owners (CIBO), estimated that the rule would put 800,000 jobs “at risk,” while the second, by the American Forest and Paper Association (AFPA), claimed that 90,000 jobs were “at risk.” Despite these assertions, both were riddled with shortcomings, Livermore and Schwartz say. For example, in addition to never defining what “at risk” meant, the CIBO report apparently chose an improper econometric model for the analysis, failing to take long-term, structural changes into account. According to Livermore and Schwartz, the AFPA’s number was a guess, at best: the study assumed that an increase of 12.5 percent or more to a mill’s production costs would put all of that mill’s workers “at risk.” Both studies were repeatedly cited in congressional hearings and press releases, say the authors, with the AFPA study becoming the basis of a bill to delay the rule. Livermore and Schwartz argue that job impact analysis would enable administrative agencies to restore reason, clarity, and transparency to the public debate on regulation. According to the authors, an agency’s analysis could function as a check on the more extreme claims made by interest groups and help those without a technical background make a balanced, informed assessment of a rule’s impacts. Moreover, although employment effects may not change a given rule’s efficiency calculus, their incorporation could highlight salient distributional effects that cannot be seen in an aggregate analysis. Finally, while individual regulatory policies may not significantly shift labor demand or supply, some have argued that collectively, they may affect employment. Examining cumulative employment effects, Livermore and Schwartz say, would allow agencies to test these claims. Overall, job impact analysis can not only ensure more targeted, appropriate policy responses from the government but also provide the public with a broader, more balanced perspective on regulatory policies. Integrating employment effects into regulatory impact analysis is a complex, challenging endeavor, acknowledge Livermore and Schwartz. However, they argue that it is a worthwhile one, helping to restore reason to the jobs and regulation debate. Livermore and Schwartz’s work appears as a chapter in the recently published book, Does Regulation Kill Jobs?, edited by Cary Coglianese, Adam Finkel and Christopher Carrigan. This essay is part of The Regulatory Review’s six-part series, Does Regulation Kill Jobs
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