OMB requirements that agencies conduct economics-based analyses of the costs and benefits of regulatory decisions have delayed several major environmental protections and prompted the Environmental Protection Agency to install working groups of economists for every major rulemaking, according to an internal EPA memorandum. Uncovered by Inside EPA, the memo from EPA Acting Deputy Administrator Steve Johnson instructs agency officials to adopt new rules that subordinate environmental decisions to economic considerations:

• A greater role for economists: The memo requires EPA program offices to establish, for every rule with large costs to industry, "an economics subgroup of each action development workgroup," to consist of economists from the program office itself and from the EPA's Office of Policy, Economics and Innovation (OPEI).
• Treating economics as a "science": Although it will be news to many scientists who specialize in biology, ecology and other empirical sciences, the memo treats economics as though it were such a science instead of a social theory depending in large measure on controversial a priori assumptions of human and institutional behavior. In its very first paragraph, it notes, "Science, including economics, is continually improving" (emphasis added). This conflation of economics with empirical science is necessary to make sense of the memo's insistence that the working groups of economists will be charged with "developing a plan to conduct economic analyses using the best available science." These "best available" methods include using opinion polls to calculate the value of endangered species, and some of the "best available" examples have recently been shown to lack scholarly integrity.
• Incorporating White House political values in the scientific process: This memo also forces the program offices to "meet with the Office of Management and Budget to communicate their regulatory and policy agenda for the remainder of the year." In preparation for those meetings, the program offices "should be prepared to describe the key underlying analytic assumptions or models used" for every economically significant rule on the agenda.

Another requirement, according to Inside EPA sources but not in the memo itself, is a redundant follow-up economics analysis. According to those sources, EPA is also requiring OPEI to review once again the rules that have already undergone economics analysis at the agency, been scrutinized (and perhaps reanalyzed) at OMB, received OMB approval, and been returned to the EPA for final sign-off. The report identifies several major rules already being subjected to these extra layers of economics analysis, which include safe drinking water rules regulating by-products from disinfection. Sources report that the new reviews could also delay a waste rule to create an electronic tracking system for shipments of hazardous wastes.