Request for Proposals: Retrospective Studies of Regulatory Performance

For more than 60 years, Resources for the Future (RFF) has been a leader in improving environmental, energy, and natural resource decisions through impartial economic research and policy engagement. The RFF Regulatory Performance Initiative (RPI) seeks to strengthen the measurement of the outcomes of federal environmental regulation. RFF is soliciting research proposals that pursue creative new ideas for measuring actual, realized benefits and costs of federal regulation. In particular, the project is focused on investigations that compare observed outcomes with a range of credible baselines and prospective or ex ante estimates.

RFF seeks applications for research and policy analysis on the performance of federal environmental regulations in the United States. Notwithstanding the extensive ex ante analyses conducted for new federal rules, relatively little is known about the actual performance of regulations. For instance, do they achieve substantial gains? If so, how do the realized gains compare with the anticipated gains? Are the realized costs in line with the expected costs? Are there unintended consequences, either favorable or unfavorable?

In recent years, there has been increasing interest in the retrospective evaluation of federal regulation, including a series of presidential executive orders in both the Obama and Trump administrations promoting such analyses by federal agencies. (For example, see E.O. 13563, January 18, 2011; E.O. 13610, May 10, 2012; and E.O. 13777, February 3, 2017. The introduction to the Fall 2017 Regulatory Agenda also highlights retrospective review.) The 2018 Evidence Based Policy Act is an important step forward, and the pending SMART Act has the potential to further advance the ex post analysis of federal regulation.

At the same time, many challenges hinder development of reliable, comprehensive measures of the performance of regulations and regulatory programs. The available ex post analyses often focus on metrics such as inspections or audits rather than on outcomes more directly connected to human welfare. When retrospective analyses do adopt welfare-oriented outcomes, they often do so in a manner that is subject to selection bias and disproportionately focused on costs as opposed to benefits or measures of physical effectiveness.

Previously, RFF sponsored new retrospective studies in the areas of food safety, air and water pollution, appliance efficiency, and natural resource management). In the second phase, we limited the focus to retrospective analyses of regulations issued by the US Environmental Protection Agency.

The present RFP seeks proposals in two areas:

1. New in-depth studies on the actual performance of individual (or groups of) rules issued by the US EPA. Our recent focus has been on Clean Air Act (CAA) regulation, but we are potentially open to other topics as well. Preference will be given to those proposals using particularly innovative methods or data sources.
2. New studies that examine the performance of different types of regulatory strategies; for example, a comparison of the performance of market-based vs traditional (command and control) regulation; a comparison of the performance of different types of market-based approaches (taxes vs emissions trading); or an evaluation of the performance of information-based (labeling) vs some type of mandatory regulation (e.g., traditional, command-and-control regulation or incentive-based approaches). These examples, and the examples below, are meant to illustrate but not limit the types of regulatory strategies that could be examined.

Sample Project Descriptions

• Examine further some of the major policy questions that have emerged in our earlier work to the extent that they would provide spillover benefits in terms of improved regulatory programs. Examples include the costs and benefits of spatially-varying regulation of stationary sources (non-attainment areas) and mobile sources (fuels), and the costs and benefits of refined designs for emissions trading schemes, e.g., the use of multiple v. single trading ratios across the regulated areas.
• Conduct new retrospective analyses of some of the major unstudied areas of the Clean Air Act, including the adoption of State Implementation Plans (SIPs), New Source Review (NSR), air toxics regulations, tier II auto standards, and heavy-duty truck standards.
• Develop new retrospective studies on other EPA regulations, i.e., non-CAA rules, that would yield broad spillover benefits in improving environmental regulation. For example, these projects could focus on environmental regulations involving energy and water issues.

Selection of proposals will be based on the originality and scientific merit of the proposed research, compatibility with the research theme of this RFP, and the demonstrated research competence of the applicants. The project description should outline the plan of work and offer a discussion of its broader implications for federal environmental regulation.

Grant recipients are expected to publish their research in both peer-reviewed journals and popular outlets.

Applicants must have demonstrated expertise in the relevant area of study.

The grant performance period is up to 15 months. The starting date is flexible, but applicants are urged to target a completion date no later than December 31, 2021.

The application process is relatively simple and proceeds in two stages:

Stage 1: Pre-proposal submission (May 18 through June 15, 2020)

The pre-proposal must include the following: (1) full name, title, and professional address (including telephone number and email address) of each investigator; (2) the title of the project; (3) a brief, concise description (one page, single-spaced, or less) of the problem to be addressed by the project, the innovation offered by the project, and the anticipated products of the project (for example, a journal article, report, monograph, etc.); (4) a list of the major tasks involved in the project; (5) the proposed dates for start and completion of the project; and (6) a CV or brief statement of prior experience of the project leader. Applicants are welcome to contact one of the PIs (listed below) to discuss project ideas in advance of submission of a pre-proposal. Pre-proposals must be submitted via email to [email protected] by 11:59 p.m. Eastern Time on June 15, 2020.

Stage 2: Final Proposals (June 30 through August 31, 2020)

Final proposals will be invited after review by the PIs. Final proposals must be limited to five pages and should augment the information contained in the pre-proposal, including a more detailed description of the proposed research, anticipated contribution of the project, and a detailed outreach plan.

At present, up to $200,000 is immediately available to support up to six grants. Applicants are encouraged to leverage this funding with other sources, consistent with RFF’s policy on outside support.

The pre-proposal must be received by June 15, 2020. Applicants will be notified by June 30, 2020 if they are invited to submit final proposals. Final proposals must be received by August 31, 2020. Awards will be announced by September 15, 2020. All pre-proposal and final proposal materials should be sent electronically as PDF files to the RFF Principal Investigators, as listed below.

For more information, please contact the RFF Principal Investigators:

• Arthur Fraas ([email protected])
• Richard Morgenstern ([email protected])