As we just posted below, it appears from the PART assessments of the Army Corps of Engineers that USACE has been employing cost-benefit analysis in its internal decisions about projects and priorities. Has cost-benefit analysis -- a game rigged against the public interest -- distorted priorities in USACE and contributed to the failure to protect New Orleans and the rest of the Gulf Coast areas affected by Hurricane Katrina? Here are some questions to ask USACE:

• How were "benefits" measured?
• Did the benefits monetize -- i.e., substitute a cash equivalent for -- human lives?
• If so, do the cash equivalents for human life operate on the "willingness to pay" principle -- under which the lives of the poor could count less than the lives of the wealthy?
• Did USACE use any measures such as life years saved or statistical life years -- measures in which the elderly (who have fewer "life years" remaining) count less than the young -- with the effect that areas with older populations would matter less than areas with younger populations?
• Did benefit measures depend on number of lives affected -- and, if so, was there any effort to account for census understatements (from which rural populations might be less well calculated than wealthier populations, thus potentially skewing prioritization in favor of wealthier areas)?
• Were benefits calculated in terms of property values -- meaning that some coastal areas (such as Louisiana, Mississippi, and Alabama) could count less than others (such as California)?
• Are cost measures skewed by cost differentials (from labor, etc.) in different parts of the country?
• Was the Clinton-era executive order for environmental justice -- intended to prevent unwitting environmental racism in federal government decisions -- applied in any USACE decisions in which cost-benefit analysis was also used?
• When calculating benefit measures such as lives spared from damage reduction or prevention efforts, did USACE include projections about poverty and its effects on the numbers of people who would (and could) take prevention efforts into their own hands vs. the numbers of people structurally disabled from self-help?

More info:

• OMB Watch Regulatory Policy Program Cost-Benefit Analysis Page
• Center for Progressive Reform Perspectives on CBA
• Pricing the Priceless - monograph on CBA by law professor Lisa Heinzerling and economist Frank Ackerman