Table 35 Alternative 4 Alternative 1 Alternative 2 Alternative 3 Benefit Baseline Final Rule Fee Unit Cost Across the Description Schedule Recovery Board Adjustment Secure Aggregate -- Revenue to -- Cover Aggregate Cost Fee Schedule -- -- -- Design Benefits Both the Final Rule Fee Schedule (Alternative 1) and Across the Board Adjustment (Alternative 3) secure sufficient aggregate revenue to cover aggregate cost. However, the only alternative that offers benefits beyond the current fee schedule design is Alternative 1. These benefits will be discussed in more detail in Section 4. Transfer Estimates OMB Circular A-4 details the importance of distinguishing between real costs and transfer payments. Circular A-4 states that and cost estimates should reflect real resource “benefit use. Transfer payments are monetary payments from one group to another that do not affect total resources available to society.” OMB’s Impact Analysis: A Primer” cites “Regulatory to government agencies for goods or services provided by the agency” as an example “fees of transfer payments. Circular A-4 states that transfer payments should be addressed a “in separate discussion of the regulation’s distributional effects.”
Table 35 Benefit Description Alternative 4 Baseline Alternative 1 Final Rule Fee Schedule Alternative 2 Unit Cost Recovery Alternative 3 Across the Board Adjustment Secure Aggregate Revenue to Cover Aggregate Cost -- -- Fee Schedule Design Benefits -- -- -- Both the Final Rule Fee Schedule (Alternative 1) and Across the Board Adjustment (Alternative 3) secure sufficient aggregate revenue to cover aggregate cost. However, the only alternative that offers benefits beyond the current fee schedule design is Alternative 1. These benefits will be discussed in more detail in Section 4. Transfer Estimates OMB Circular A-4 details the importance of distinguishing between real costs and transfer payments. Circular A-4 states that “benefit and cost estimates should reflect real resource use. Transfer payments are monetary payments from one group to another that do not affect total resources available to society.” OMB’s “Regulatory Impact Analysis: A Primer” cites “fees to government agencies for goods or services provided by the agency” as an example of transfer payments. Circular A-4 states that transfer payments should be addressed “in a separate discussion of the regulation’s distributional effects.”
Regulatory_Impact_Analysis.docx