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" ... Regulators themselves decide what counts as major. As OMB said up front (p. 8), "As has been the practice for many years, all estimates presented ... are agency estimates of benefits and costs, or minor modifications of agency information performed by OMB." The OMB asserts that its report "does not purport to demonstrate all costs or benefits from federal regulation; instead, the report summarizes the anticipated costs and benefits that the Regulatory Impact Analyses (RIAs) of individual final rules reported for those rules." The administration acknowledges (p. 11) what it calls an “ often-overlooked detail”; that “the totals listed … include only the benefits and costs for the minority of rules for which both those categories of impacts were estimated.” While OMB references a 2004 claim that the “major” rules reviewed account for the bulk of regulatory costs (p. 10), other OMB reports had been more forthcoming about indirect and unfathomed costs. Those subject to regulation might have different opinions regarding what’s noteworthy. ... "
" ... So which is it? Earlier OMB reports had been more forthcoming about indirect and unfathomed costs. ... "