Brian Mannix

Brian F. Mannix


Brian Mannix is a recognized national expert on energy and environmental policy and regulation.  From 2005 to 2009 he served as the Environmental Protection Agency's Associate Administrator for Policy, Economics, and Innovation; earlier he served as Deputy Secretary of Natural Resources for the Commonwealth of Virginia.  He has held appointments at a number of other federal and state agencies, and has held research positions at several public policy think tanks.  From 1987 to 1989 Mr. Mannix was the Managing Editor of Regulation magazine at the American Enterprise Institute.  Mr. Mannix earned  A.B. and A.M. degrees from Harvard University in Mathematics and Chemistry, and an M.P.P. from the Harvard Kennedy School of Government.

Brian Mannix CV


A.B. and A.M. degrees from Harvard University in Mathematics and Chemistry
M.P.P. from the Harvard Kennedy School of Government


Recent Research

Regulatory Reforms to Enhance Competition: Recommendations for Implementing Executive Order 13725, by Sofie E. Miller, Daniel R. Pérez, Susan E. Dudley, & Brian Mannix, May 11, 2016

Are Future Lives Worth More, Today, Than Our Own – Simply Because of Income Growth? Brian Mannix, March 7, 2016

CAFE and the Tension Between Optimization and Competition in Rulemaking, Brian F. Mannix in Regulation, Winter 2015-2016

Public Comment on OMB’s 2015 Draft Report to Congress on the Benefits and Costs of Federal Regulations, Sofie E. Miller, Susan Dudley, Brian Mannix, December 15, 2015

Public Comment: EPA’s Proposed Rule: Federal Plan Requirements for Greenhouse Gas Emissions From Electric Utility Generating Units, Brian Mannix, November 19, 2015

Public Comment on the EPA and NHTSA’s Proposed Rule: Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium and Heavy-Duty Engines and Vehicles – Phase 2, Brian Mannix, October 2, 2015

The Limits of Irrationality as a Rationale for Regulation, Brian Mannix & Susan E. Dudley, Journal of Policy Analysis and Management, Vol. 34 Issue 3, 2015.

Please Don't Regulate my Internalities,” Brian Mannix & Susan E. Dudley, Journal of Policy Analysis and Management, Vol. 34 Issue 3, 2015.

The Social Cost of Carbon, Susan E. Dudley & Brian Mannix, Engage Volume 15 Issue 1, 2014

Making the Social Cost of Carbon More Social, Susan E. Dudley, Brian F. Mannix, & Sofie E. Miller, Regulation, Winter 2013-2014

Recent Commentaries

Beyond the Speed Bump: The New IEX Stock Exchange, and What Happens Next?, Brian F. Mannix, June 22, 2016

Are Future Lives Worth More Than Our Own? Brian F. Mannix, March 14, 2016

Space-Time Trading: Special Relativity and Financial Market Microstructure, Brian F. Mannix, March 14, 2016

Are Chemical Risk Assessment and Benefit-Cost Analysis Compatible? Brian F. Mannix, January 6, 2016

The Tension between Optimization and Competition in Rulemaking: The Case of Proposed Fuel-Efficiency Standards for Trucks, Brian F. Mannix, October 8, 2015

"Alaska is Exempt!", Brian Mannix, Federalist Society Executive Branch Review Blog, September 8, 2015

Misbehavioral Economics?, Brian Mannix, June 17, 2015

In the News

FedSoc Executive Branch Review Blog, "Alaska is Exempt!", by Brian Mannix, September 8, 2015

The Hill, Debating the Nanny State, by Stuart Shapiro citing Susan Dudley & Brian Mannix, August 5, 2015

The Federalist Society, The Highs–and Lows–of High-Frequency Trading - Podcast, interview with Brian Mannix, August 5, 2014

Reuters, Antisocial genesis of the social cost of carbon, by Susan Dudley, Brian F. Mannix, & Sofie E. Miller, October 10, 2013

PODCAST: The Highs–and Lows–of High-Frequency Trading, with RSC Scholar Brian Mannix, Federalist Society, August 5, 2014

PODCAST: Benefit-Cost Analysis in Rulemaking: Ready for Prime Time? with RSC Research Scholar Brian Mannix, Federalist Society, May 21, 2012

Recent Articles

JBCA cover

Consumer’s Guide to Regulatory Impact Analysis: Ten Tips for Being an Informed Policymaker

August 02, 2017

By S. Dudley, R. Belzer, G. Blomquist, T. Brennan, C. Carrigan, J. Cordes, L. Cox, A. Fraas, J. Graham, G. Gray, J. Hammitt, K. Krutilla, P. Linquiti, R. Lutter, B. Mannix, S. Shapiro, A. Smith, W. .Viscusi & R. Zerbe in the Journal of Benefit-Cost Analysis
Regulatory impact analyses (RIAs) weigh the benefits of regulations against the burdens they impose and are invaluable tools for informing decision makers. We offer 10 tips for nonspecialist policymakers and interested stakeholders who will be reading RIAs as consumers.

Trump EO

Shining a Light on Regulatory Costs

April 04, 2017

By Brian Mannix
President Trump’s Executive Order 13771, "Reducing Regulation and Controlling Regulatory Costs," has caused some confusion among the analysts, inside and outside federal agencies, who forecast the economic effects of regulations. Which effects should count as costs and which as benefits? It sounds like it should be an easy question, but it is not. In this Regulatory Insight, Brian Mannix examines some of the obstacles.

Eisenhower Building

Public Comment on OMB’s Interim Guidance Implementing Section 2 of the Executive Order Titled “Reducing Regulation and Controlling Regulatory Costs”

February 13, 2017

By Susan E. Dudley, Brian F. Mannix, Sofie E. Miller, & Daniel R. Pérez
In this comment on the Office of Information and Regulatory Affairs’ (OIRA) interim guidance on Executive Order 13771, GW Regulatory Studies Center scholars acknowledge that the Order represents a significant departure from past practice, however, they emphasize that the additional budgeting constraints it imposes need not supplant longstanding requirements to examine regulatory benefits as well as costs and to achieve regulatory objectives as cost-effectively as possible. The comment reinforces OIRA’s draft questions and answers, and offers some suggestions for clarification and improvement.

Nudge Theory

One Standard to Rule Them All: The Disparate Impact of Energy Efficiency Regulations

October 12, 2016

Chapter by Sofie E. Miller and Brian F. Mannix
Federal regulations restrict the energy that everyday products can use, for everything from cars to microwaves. While these rules impose significant costs on consumers, the benefits are harder to identify. Agencies claim that restricting consumers’ choices provides consumers with large benefits, but this reasoning is hard to reconcile with the fact that consumers have many legitimate reasons to prefer the appliances they buy and the cars they drive. This chapter explores the reasoning behind energy efficiency regulations and why these reasons are insufficient to support the large costs they impose on consumers, especially low-income consumers.

White House

Public Comment to the National Economic Council on The President’s Executive Order 13725: Steps to Increase Competition and Better Inform Consumers and Workers to Support Continued Growth of the American Economy

May 12, 2016

By Sofie E. Miller, Daniel R. Pérez, Susan E. Dudley & Brian Mannix
This public comment suggests several areas of regulatory policy where federal regulations have hindered, rather than helped, competition, and recommends that agencies take this opportunity to reduce these regulatory barriers to competition.


Are Future Lives Worth More, Today, Than Our Own – Simply Because of Income Growth?

March 07, 2016

By Brian Mannix
The EPA has presented its Environmental Economics Advisory Committee a series of questions that relate to an analytical procedure for estimating the value of statistical lives saved in the future – possibly the distant future – as a result of regulations imposed today. Intertwined with the detailed analytical questions, however, is a fundamental ethical and methodological question: Is it right to force a relatively poor population to pay an inflated price – higher than they are willing to pay to save their own lives – to save the lives of a richer population, on the theory that rich people’s lives are more valuable?

OMB seal

Public Comment on OMB’s 2015 Draft Report to Congress on the Benefits and Costs of Federal Regulations

December 15, 2015

The Office of Management and Budget’s 2015 Draft Report to Congress provides information on costs and benefits for certain final rules issued between FY 2004 and FY 2014. The Report provides the public valuable information both on estimates of the effects of major executive branch regulations, and also on OMB’s focus and priorities. This comment offers recommendations for improving regulatory impact assessments, writing rules to encourage retrospective review of regulations, and the use of “private benefits” to justify energy efficiency standards.

Regulation magazine

CAFE and the Tension Between Optimization and Competition in Rulemaking

December 14, 2015

By Brian Mannix
Choosing regulatory options that maximize net benefits is a sound principle, but it needs to be applied with an appropriate measure of humility. Regulators may be tempted to think that they can use benefit-cost analysis to determine what is “best” for the economy, and then simply mandate it. The collateral damage to competition and innovation can easily turn an otherwise well-intentioned rule into an economic disaster. Regulatory specification of a particular technology can be especially damaging when the technology is proprietary, because then the law may simultaneously lock out competitors and lock in customers.

European Power Plant

Public Comment: EPA’s Proposed Rule: Federal Plan Requirements for Greenhouse Gas Emissions From Electric Utility Generating Units

November 19, 2015

By Brian Mannix
This Public Interest Comment, filed last year in response to EPA’s proposed Clean Power Plan, addresses the relative merits of a “mass-based” or “rate-based” emissions trading program in state plans required by EPA’s rule. This same question has arisen again in the context of EPA’s development of Federal Implementation Plans (FIPs) that might be imposed on noncomplying states. The comment (which has now been filed in the FIP rulemaking) concludes that a rate-based trading program, similar to the EPA’s successful program for trading lead in gasoline in the 1980s, has compelling advantages over a mass-based program.

Truck fleet

Public Interest Comment on EPA and NHTSA's Proposed Rule: Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium and Heavy-Duty Engines and Vehicles – Phase 2

October 02, 2015

by Brian Mannix, Research Professor
Contrary to claims, EPA and NHTSA’s proposed standards to regulate greenhouse gas emissions and fuel efficiency for medium and heavy-duty engines and vehicles is not “a win-win-win.” The agencies’ RIA forecasts large benefits, mostly in the form of private fuel savings but, fails to recognize that competitive markets are far better informed, and far better motivated, to pursue these fuel savings efficiently. The net effect will be higher costs, not savings. Other external benefits might be used to justify the standards, but an honest RIA would acknowledge that these come at a price.

JPAM journal cover

Point/Counterpoint: Valuing Internalities in Regulatory Impact Analysis

May 13, 2015

By Brian Mannix & Susan Dudley
In this Point/Counterpoint article series with Cass Sunstein & Hunt Allcott, Mannix & Dudley argue that allowing regulators to control consumers 'for their own good' – based on some deficiency in the consumers themselves rather than any failure in the marketplace – is to abandon any serious attempt to keep regulatory policy grounded in any objective notion of the public good.


The Social Cost of Carbon

August 07, 2014

By Susan E. Dudley & Brian F. Mannix
First, we endorse the administration’s effort to arrive at a uniform social cost of carbon (SCC), to help ensure at least internal consistency across a portfolio of policies directed at reducing carbon emissions. Second, we applaud OMB’s effort to seek public comment on its technical support document (TSD), and urge the administration to follow through with scientific peer review and with other measures to ensure transparency in regulatory decisions. Third, we caution that the task of estimating the SCC was undertaken with an apparent bias that needs to be corrected before it can be taken as objective. Finally, the logical next step is not for regulatory agencies to incorporate the SCC into Regulatory Impact Analyses. Rather, the next step is to seek an international consensus on the value of the SCC and to negotiate a coordinated global policy response, which is the only way that the theoretical benefits of government actions to reduce global carbon emissions can be translated into actual results.


Making the Social Cost of Carbon More Social

December 03, 2013

By Susan E. Dudley, Brian Mannix, & Sofie E. Miller
On November 1, 2013, the White House released updated values for the “social cost of carbon” (SCC) to be used by various agencies when evaluating the benefits of emissions regulations, energy efficiency standards, renewable fuel mandates, technology subsidies, and other policies intended to mitigate global warming. Use of a uniform SCC reflects an effort to bring some consistency to a vast portfolio of different policies aimed at reducing carbon emissions from sources ranging from power plants, to cars, to household products.

high frequency trading

Races, Rushes, and Runs: Taming the Turbulence in Financial Trading

January 03, 2013

By Brian Mannix
Many participants, regulators, and observers of commodity and security markets have a sense that something in recent years has gone awry: that the explosive growth of high-frequency digital trading is somehow excessive, costly, unfair, and/or destabilizing. Several ideas for changing the rules have been discussed. Without a coherent explanation of exactly what is wrong, however, it can be very difficult to develop a promising remedy.

brian mannix

Regulatory Subsidies: A Primer

March 12, 2012

By Brian Mannix
Subsidies are a commonplace feature of government programs, and can be found in regulatory programs as well as in budget expenditures and in the tax code. An accurate accounting of regulatory subsidies, accessible to the general public, could improve government
regulation by helping to ensure that such subsidies are used only when, and to the degree that, they serve a sound public purpose. This is easier said than done, however. This paper explores the concept of a regulatory subsidy and review some examples. A more technical Appendix examines some of the obstacles to creating a clear accounting of regulatory subsidies, and suggest areas where useful studies might be pursued.