Such an analysis should include the most current and reliable data possible, the AAR said. The STB should consider the cumulative impact of regulations when proposing and adopting new rules.
By incorporating cost-benefit analysis moving forward, the STB would put itself in good company with other independent agencies that have the power to substantially impact national commerce, such as the Federal Communications Commission, the AAR argued.
“Cost-benefit analysis would be a critical tool in fostering sound regulation and supports the Board’s efforts toward achieving its goals, including its mission to facilitate a fluid and reliable rail network,” Ian Jefferies, president and CEO of the AAR, said in a statement. “By adopting the process improvements sought in our petition, we believe the STB would be better positioned to meet its statutory mandate and bring its practices more in line with the spirit of past Executive Orders, which the Board has largely acknowledged to date.”