Filed February 1, 2017
In addition, agencies must prepare “a qualitative and quantitative assessment of the anticipated costs and benefits of [a rule], including the costs and benefits to ... the private sector” whenever a rule will impose over $100 million in inflation-adjusted costs. 2 U.S.C. § 1532(a)(2). The APA’s requirement of “reasoned decision making” likewise requires agencies to “look at the costs as well as the benefits” of the rules they promulgate.