Public Comments to OIRA on Proposed Guidance for Assessing Changes in Environmental and Ecosystem Services in Benefit-Cost Analysis

The Guarini Center, together with the New York University Wild Animal Welfare Program (WAW), submitted comments to the Office of Management and Budget, Office of Information and Regulatory Affairs (OIRA) on its Proposed Guidance for Assessing Changes in Environmental and Ecosystem Services in Benefit-Cost Analysis. In the comments, the Guarini Center and WAW urge OIRA to modify the Guidance to:

1. Encourage agencies to recognize that changes in the environment or ecosystems affecting individual animals (as well as species) may affect human welfare;
2. Ensure that important contributions of wild and farmed animals to human welfare are captured in the causal pathways in the Guidance; and
3. Refer to the potential impacts on the welfare of animals for their own sakes due to changes in the environment or ecosystems.