Request for Proposals: Retrospective Studies of Regulatory Performance

Resources for the Future (RFF) invites you to submit a proposal for research on the measurement of the outcomes of federal environmental regulation. RFF is soliciting research proposals that pursue creative new ideas for measuring actual, realized costs, and/or benefits of federal regulation. At present, up to $200,000 is available to support up to eight grants.

Please note that pre-proposals must be received by 11:59 pm US Eastern on Thursday, January 12, 2023. Applicants will be notified by January 31, 2023, if they are invited to submit final proposals. Final proposals must be received by 11:59 pm US Eastern on Wednesday, March 15, 2023. Awards will be announced by April 5, 2023.

For more than 60 years, Resources for the Future (RFF) has been a leader in economic analysis and regulatory and policy innovation for energy, environmental, and natural resource management. The RFF Regulatory Performance Project seeks to strengthen the measurement of the outcomes of federal environmental regulation. For a review of recent work see Aldy et al 2022.

For this new phase, RFF is soliciting research proposals that pursue creative new ideas for measuring actual, realized benefits and/or 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 in regulatory impact analyses, 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 Foundations for Evidence-Based Policymaking 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. Available ex post analyses often focus on metrics such as inspections or audits rather than on health, environmental or other 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 pollution, water pollution, appliance efficiency, and natural resource management. In a second phase, we limited the focus to retrospective analyses of environmental regulations mostly focused on air pollution.

We are particularly interested in proposals in four areas:

1. New in-depth studies on the actual performance of individual (or groups of) rules issued by the US Environmental Protection Agency. Preference will be given to those proposals using particularly innovative methods or data sources. Though we remain interested in studies on Clean Air Act (CAA) regulation, we are seeking proposals on other EPA-relevant topics as well, e.g., the Clean Water Act and the Safe Drinking Water Act. 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 are meant to illustrate but not limit the types of regulatory strategies that could be examined.
3. Further, we invite proposals on the aggregate effects of groups of regulations (as opposed to individual rules) as well as the distributional impacts across industries, regions, and population subgroups.
4. Beyond studies of direct regulation, we are also potentially interested in studies on the performance of federal subsidies, particularly as they relate to environmental or energy policy. Multiple types of subsidies may be considered, including grants, tax incentives (investment and production credits for business and consumer-oriented credits for households), loans or loan guarantees, and risk transfers.

• Examine the costs and benefits of spatially varying federal and state and local regulation of stationary sources (non-attainment areas) and mobile sources (fuels).
• Assess 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 retrospective analyses of some of the major unstudied areas of the Clean Air Act, including the adoption of State Implementation Plans, New Source Review, air toxics regulations, tier II auto standards, and heavy-duty truck standards.
• Develop retrospective studies on non-CAA rules issued by EPA, that could yield broad spillover benefits in improving environmental regulation. For example, these projects might 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 September 1, 2024.

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

Stage 1: Pre-proposal submission (November 30, 2022–January 12, 2023)

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 (single-spaced, one page 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 pm US Eastern on January 12, 2023.

Stage 2: Final Proposals (January 31–March 15, 2023)

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 eight grants. Applicants are encouraged to leverage this funding with other sources, consistent with RFF’s policy on outside support (note that RFF does not accept corporate support for specific projects).

The pre-proposal must be received by January 12, 2023. Applicants will be notified by January 31, 2023, if they are invited to submit final proposals. Final proposals must be received by March 15, 2023. Awards will be announced by April 5, 2023. 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])