Telecom & Network Industries

 

 

 

STB's Rate Review and Market Dominance -- Reply Comment

January 13, 2020

By: Jerry Ellig
This reply comment addresses issues raised during two recent proceedings where the Surface Transportation Board proposed a streamlined approach to assessing whether a railroad has market dominance and a final offer process for small rate disputes.


STB's Railroad Revenue Adequacy

December 02, 2019

By: Jerry Ellig
The Surface Transportation Board will hold a hearing on December 12 to discuss recommendations from the STB's Rate Reform Task Force. This comment addresses several of the task force's proposals, and provides additional recommendations for the STB to improve its revenue adequacy regulations.


Rail Regulators Ponder Benefit-Cost Analysis

November 18, 2019

Although regulatory impact analysis would certainly not automate STB regulatory decisions, it would provide a coherent and organized framework for discovering and presenting information about the likely consequences of regulatory alternatives.


STB's Market Dominance and Final Offer Rate Review

November 06, 2019

By: Jerry Ellig
The two rulemakings this comment addresses are the Surface Transportation Board’s (STB’s) latest efforts to develop simpler and less costly rate complaint processes. These two proceedings provide an excellent opportunity for the STB to “test drive” the framework for benefit-cost analysis that is most commonly employed by federal agencies: the analytical principles and requirements articulated in President Clinton’s Executive Order 12866 and OMB Circular A-4. The most common and accurate term for this type of analysis is “Regulatory Impact Analysis” (RIA), because a full RIA involves more than just estimation of benefits and costs. This comment briefly explains the RIA framework and demonstrates how it could be used to answer key factual questions the STB must answer in order to accomplish its statutory goals.


Restoring Internet Freedom as an example of How to Regulate

June 3, 2019

By: Jerry Ellig
Thomas Lambert’s How to Regulate contains some simple but critical pieces of advice for regulators: (1) Diagnose the problem before settling on a solution, (2) Compare the merits (benefits and costs) of alternatives, and (3) Recognize that regulators, like the rest of us, respond to the incentives created by the organization in which they are embedded. The FCC’s Restoring Internet Freedom order presents an example of how to apply those principles in practice.


Measuring Costs and Benefits of Privacy Controls: Conceptual Issues and Empirical Estimates

January 30, 2019

By: Joseph J. Cordes & Daniel R. Pérez
Co-director Joe Cordes and senior policy analyst Daniel Pérez's article published in The Journal of Law, Economics & Policy draws on the economics of privacy literature to summarize why the costs and benefits of privacy controls should be measured in principle, discusses previous attempts to do so, and generates useful estimates of consumers' valuation of privacy.