Brad Z said:
14 of the 87 pages of the final rule was devoted to cost benefit analysis. See the regulatory evaluation section. Obviously there are tons of assumptions but you can't say they didn't attempt an analysis.
Interesting. I looked and I can't find anything that constitutes a proper cost-benefit analysis of the sort I described, where you figure out what is the costs per life or injury avoided. I am looking at FAA-2019-0001. Please correct me if I missed it.
The executive summary provides three scenarios of estimated costs (which are considerable, ranging from $584M as the base scenario). Some benefits are mentioned later monetarily, such as the costs of airport closures because people are trying to enforce regulations about drones or are worried about them, but even here, there is no attempt to estimate the frequency of such events, with and without drone id, and then compare to the costs. There are NO estimated numbers of lives saved or injuries avoided. No actual comparison of costs versus primary benefits of the proposed intervention.
So while one can perhaps claim that they did do some cost estimation, they made NO attempt to weigh in a quantitative way the value of the primary benefits versus the costs. That is what a serious cost-benefit analysis does.
If this is the idea of the FAA for a cost-benefit analysis they are seriously not thinking about what they are doing, which is supposed to be enhancing safety. This just completely misses the point from an overall cost-benefit point of view. I guess one could generously say they did "attempt an analysis", but then I think one would have to conclude they are grossly incompetent (or don't want to do a proper analysis because it would likely show that the effective cost per life saved in this proposal is grossly out of proportion to any reasonable number).
Did it even cross the minds of the FAA regulators that they should have to justify spending about 1/2 billion dollars of other people's money in terms of what they are doing? I think they tend to operate as "safety at any cost", which is just not possible in the real world.
I don't mean to bash on the FAA exceptionally here. None of this is particular to the FAA, in fact it is completely consistent with what Mises pointed out in "Bureaucracy" is one of the primary problems with regulatory schemes -- the incentives are just not there to behave in a rational manner.
