Ruth Ruttenberg and Associates, Inc. Public Citizen. February 2004.
“Not Too Costly, After All” shows that regulators regularly overestimate the costs of their own regulations. “Regulatory agencies often overestimate the cost of regulatory compliance, sometimes substantially. There are dozens of examples of costs being inflated and the potential for innovation and productivity-enhancing activities ignored.”
Other than the reasons listed above, Public Citizen concludes that regulators often rely heavily on industry self-reporting, which is often “poor or inaccurate”, and the small-c conservative assumptions of regulators. The off-setting benefits and underestimation of innovation are also mentioned.