1. It contains a burdensome requirement for cumulative cost-benefit analysis that has no practical utility for public policy. For the last three years, Congress has enacted appropriations riders requiring OMB to conduct a cumulative cost-benefit analysis, expressed in monetized figures, for all federal regulation. In its two completed reports, OMB makes a special effort to point out that rulemaking decisions are made on a case-by- case basis, as they must be, and that throwing all of the government's diverse regulations, from environmental standards to economic controls, into the same pot has little practical utility for public policy. "[W]e still believe that the limitations of these estimates for use in making recommendations about reforming or eliminating regulatory programs are severe," OMB states in its second report, released in February. "Aggregate estimates of the costs and benefits offer little guidance on how to improve the efficiency, effectiveness, or soundness of the existing body of regulations." Further calling into question S. 59's applicability to policy-making is the inherent uncertainty involved in cumulative cost-benefit analysis. OMB discusses a litany of factors that, in its words, make it "difficult, if not impossible, to estimate the actual total costs and benefits of all existing Federal regulations with any degree of precision." 2. It seeks to dramatically expand analytical requirements contained in the previous appropriations riders and takes an all-things-are-possible approach. S. 59 � which has removed language from the previous appropriation rider requiring analysis only "to the extent feasible" � calls for OMB to estimate the annual costs and benefits of rules and paperwork (a) in the aggregate, (b) by agency, agency program, and program element, and (c) by major rule. In addition, OMB would have to assess the direct and indirect impacts of federal rules on federal, state, local and tribal governments, the private sector, small business, wages, and economic growth. The biggest problem with these new requirements is that much of the information called for is not currently generated during agency rulemakings, which goes against the understanding of the previous riders. 3. It would drain already scarce agency resources for unnecessary analysis. Many of the requirements in S. 59 would require totally new work for federal agencies, draining their ability to fulfill their core missions. For instance, under the Paperwork Reduction Act, agencies are not currently required to conduct cost-benefit analyses for paperwork; rather, the agency is to assess "practical utility" and burdens imposed. Nor do agencies currently conduct analysis by "program element," meaning a cluster of related rules. OMB has said that these, and other requirements, would mean that "agencies may have to be called upon to compile detailed data that they do not now have, and undertake analyses that they do not now conduct, using scarce staff and contract resources, regardless of any practical analytic need as part of the rulemaking process." 4. It contains slanted analytical requirements designed to boost cost estimates. The inclusion of the new subanalyses listed above are all aimed at elevating cost considerations. Estimates for "net benefits," as called for in the bill, are likely to be understated anyway because many benefits cannot be captured by monetized estimates, whereas it is much easier to do so for costs. But the slanted subanalyses make this even more likely to be the case. Notably, the bill calls for no such specificity in evaluating benefits, although there are certainly subcategories here worth considering � including effects on vulnerable populations, such as children, the elderly and the disabled. Moreover, S. 59 requires OMB to subject its findings, as well as new guidelines across agencies for cost-benefit analysis, to peer review provided by "a nationally recognized public policy research organization with expertise in regulatory analysis and regulatory accounting." There are only a handful of groups who would qualify under this language, and virtually all are more concerned with the cost side of the regulatory equation. This would allow a single, privileged organization to greatly bias results and achieve a disproportionate amount of influence over the future of agency cost-benefit analysis.