The Future of Cost-Benefit Analysis, with Michael Livermore and Richard Revesz

Notable Quotes

• Balancing the democratic process with agency expertise: “In the modern administrative state, there’s a basic fundamental tension—which is that on the one hand, we look to administrative agencies for expertise and impartiality. For that reason, we imbue them with substantial policymaking power. So, you have these expert agencies that are making important policy choices, like how to address climate change, or what’s the safety of our roads, or what kind of regulations are needed to protect and ensure the safety of vaccines … The tension is that we live in a democracy and we ultimately want policymaking power grounded in the will of the people. We want there to be democratic accountability.” —Michael Livermore (12:00)
• The Trump administration’s inconsistent interpretation of co-benefits: “The Trump administration vigorously embraces co-benefits [with vehicle emissions standards], but … it [also] says that the co-benefits of particulate matter reductions should be ignored. Not only is the Trump administration’s attack on co-benefits going against any plausible economic approach, but the Trump administration is being totally inconsistent and is basically saying, ‘We’ll embrace co-benefits or we’ll reject co-benefits, depending on what best serves our deregulatory agenda.’” —Richard Revesz (19:40)
• Equity must be considered in cost-benefit analysis: “We’ve never been successful at looking at distributional analysis, [by which] I mean the impacts of regulation on disadvantaged, vulnerable, and marginalized groups. We don’t have the techniques for doing that. But, given the commitments and platform of the Biden-Harris campaign, and given the particular time that we’re living in our society, it’s clear that attention to distributional issues will be a priority. Cost-benefit analysis will have to adapt its methodologies to make that inquiry possible.” —Richard Revesz (26:00)

Top of the Stack

• Reviving Rationality: Saving Cost-Benefit Analysis for the Sake of the Environment and Our Health by Michael A. Livermore and Richard Revesz
• Mindscape podcast
• Nice White Parents podcast

The Full Transcript

Kristin Hayes: Welcome to Resources Radio, a weekly podcast from Resources for the Future. I'm your host, Kristin Hayes. I have two guests with me today who have co-authored the book that will be the subject of our conversation. The first is Michael Livermore, who was the founding executive director of New York University's Institute for Policy Integrity and now serves as one of its senior advisors. He is a professor at the University of Virginia School of Law. The second is Richard (or Ricky) Revesz, the Lawrence King Professor of Law at NYU and the current director of the school's Institute for Policy Integrity.

Last week, Oxford University Press released Mike and Ricky's new book entitled Reviving Rationality: Saving Cost-Benefit Analysis for the Sake of the Environment and Our Health. Today, we'll hear from the authors about why they chose to invest their time in this project, what messages they intend the book to convey, and how they see the issues described in the book playing out over the next few years. Stay with us. Gentlemen, welcome to Resources Radio. It's very nice to talk with you this morning.

Michael Livermore: Pleasure to be here.

Richard Revesz: Thank you for having us.

Kristin Hayes: Of course. I'm looking forward to talking about this brand new publication, but before we do that, we always like to start our episodes by sharing who you are with our listeners and allowing them to get to know you a little bit better. So can you say just a bit about your backgrounds, including how you became interested in cost-benefit analysis as a research area? Ricky, why don't I start with you?

Richard Revesz: Sure. Thank you, Kristin. I've been a law professor for 35 years at NYU Law School. I served as dean of the Law School for 11 of those years, from 2002 to 2013, and I first became interested in the issues of this book—which I would characterize as the political economy of cost-benefit analysis in the mid nineties—when I served on the Environmental Economics Advisory Committee of the EPA Science Advisory Board, and we ended up being the group that did the peer review on EPA's first guidelines for the preparation of cost-benefit analysis.

And what struck me then, and led to a lot of subsequent work, was that in those meetings, trade associations for regulated industry came frequently to make their case before us, but no environmental group ever showed up. So, basically the mythological developments around cost-benefit analysis were seeded to the regulatory community without the other side having a voice, and that led me to this inquiry about why that was, how this imbalance could be eliminated, and what needed to be done to make cost-benefit analysis in the regulatory arena the even-handed analytical tool that it should be—and not a thumb against regulation. That got me embarked on a number of academic projects, an earlier book with Mike, and then also led to the book that we'll talk about today.

Kristin Hayes: Okay, great. Great. And Mike, what about you?

Michael Livermore: So, I was a student in Ricky's environmental law class. I was a student at NYU.

Kristin Hayes: Okay.

Michael Livermore: Now, a number of years ago, but prior to law school, I worked for an environmental organization in New York for several years, and the issue that I spent most of my time on was toxic waste cleanup and brownfields and the state's Superfund system. George Pataki was governor at the time and there was a big legislative and policy discussion about those issues, and I was young, in my twenties. I remember being very impressed by the degree to which the environmental groups that I worked with were uncomfortable talking the language of economics, and the degree to which it seemed that that was a serious impediment to their ability to be effective in the legislature.

They had their allies, but it seemed to me that it constrained their coalition in ways that were not useful. And so when I came to law school and met Ricky, and I started to hear more about these issues, I kind of had that backdrop that really attracted me to this idea that cost-benefit analysis could be used in a more balanced fashion.

Kristin Hayes: Okay. Interesting. You guys have clearly had a long and fruitful relationship over these years, too. Ricky, I just wanted to pick up on something that you said, and I want to start our discussion by noting that this book is actually a sequel and you two previously collaborated on a 2008 publication entitled Retaking Rationality: How Cost-Benefit Analysis Can Better Protect the Environment and Our Health. As our very astute listeners will have heard, there are some marked similarities between the title of that first book and the title of this one. So I guess, Mike, let me ask you: Why the second book now?

Michael Livermore: Basically, the Trump administration is the explanation, in short, and the Obama administration was also influential. The basic premise of the original book is that, as Ricky mentioned, progressive groups had really not engaged in the conversation about how to conduct cost-benefit analysis, and that had hampered their ability to be effective. We made that argument in 2008.

What this book does is essentially update the perspective there, to take account of the Obama administration, and what we'll argue in the more recent book was that the Obama administration employed a largely successful approach of marrying respect for cost-benefit analysis with the progressive policy agenda. Then we discuss the reaction to that success of the Obama administration, and then ultimately to the Trump administration and what it's been doing with respect to cost-benefit analysis in the last four years.

Richard Revesz: In some sense, the second book was necessary because of the success of the first book. At least that's what I think on optimistic days—is that the first book actually played a role in spurring more significant engagement by environmental groups and other progressive groups in cost-benefit analysis. And that actually created a reaction on the other side, which was to walk away to a large extent from cost-benefit analysis and to some extent even malign it.

I guess the commitment of regulated industry to cost-benefit analysis was limited to the methodology as long as it supported anti-regulatory measures. But the methodology was actually used in a more even-handed way and showed how significant regulation brought large net benefits to society. Part of the other side just walked away and that created, we thought, the space and the need for the second book.

Kristin Hayes: That's great. And that really does help me understand how support for cost-benefit analysis has kind of ebbed and flowed over time under different administrations and different political persuasions. Before we dive into the book directly, is there any other context you'd want to provide about when cost-benefit analysis really became a primary tool in regulatory decisionmaking and how the various sides of the political spectrum have looked at it?

Richard Revesz: Sure. So cost-benefit analysis first became a really significant part of regulatory policy in 1981, following the election of Ronald Reagan when he promulgated an executive order requiring that cost-benefit analysis be performed for major federal regulations and created an institutional framework within the Office of Management and Budget. He launched the Office of Information and Regulatory Affairs to supervise how agencies conducted their cost-benefit analysis. Agencies were required by the executive order to submit both proposed and final rules for review by OIRA, the Office of Information and Regulatory Affairs, before the rules could be published.

And this was seen as part of Reagan's anti-regulatory agenda that he ran on. But what was interesting is that Bill Clinton, after being elected in 1993, promulgated his own executive order to replace the Reagan order. And a lot of Clinton supporters thought he would just repeal the order and that would be the end of the extensive use of cost-benefit analysis in regulation. But instead Clinton promulgated an order that is actually quite similar to the Reagan order, not identical, but quite similar, and that made cost-benefit analysis a bipartisan move in the regulatory state.

Now, it was not going to ebb and flow with administrations. At least a commitment to having regulations be justified through cost-benefit analysis became bipartisan. And so after the Clinton order, cost-benefit analysis became an entrenched part of the federal rulemaking apparatus. Now, having said that—while the Clinton executive order remains in effect today, George Bush kept it in place, Barack Obama kept it in place, Donald Trump kept it in place—it doesn't mean that the commitment on the ground to performing it fairly remained constant during this time.

And as I already indicated, and we can explore that more later because that is really an important part of the book, the right started casting aspersions on cost-benefit analysis and started grasping at ways of moving the conversation in different directions.

Kristin Hayes: Well, yeah, let's turn to the book. I feel like I've sort of been holding people with bated breath before we get to the book itself, but so let's turn there. This feels like a good moment. And I will note that the book is organized into three primary sections. They are titled “Guardrails,” “Charade,” and “Rebuilding,” and I was thinking maybe we could take those in turn.

So let me start with “Guardrails,” and the chapters in this section focus on how we got where we are, the evolving set of norms and guidelines for the use of cost-benefit analysis and rulemaking, as you've started to talk about a little bit, Ricky. And those have been built up over many years and many administrations, and I would summarize your argument as that this sort of decades-long accumulation of knowledge and experimentation and practice really formed the backbone of kind of an important set of guardrails in the cost-benefit analysis process. And so I wanted to ask, Mike, I'll ask you. In your view, why do those years of experience matter? And maybe even more importantly, what were, or are, these guardrails protecting us from?

Michael Livermore: Great. So I'll take the second part of the question first.

Kristin Hayes: Okay.

Michael Livermore: So with respect to the guardrails, the way I think of this is that in the modern administrative state, there's a basic fundamental tension. Which is that on the one hand, we look to administrative agencies for expertise and impartiality. And for that reason, we imbue them with substantial policymaking power. And so you have these expert agencies that are making important policy choices, like how to address climate change, or what's the safety of our roads, or what kind of regulations are needed to protect and ensure the safety of vaccines. So we're doing this on the one hand, but then the tension is that we live in a democracy and we ultimately want policymaking power grounded in the will of the people. We want there to be democratic accountability.

There's obviously a role for Congress and elections in all of this. And so this is the tension. The way we've more or less resolved that is that we invest in administrative agencies with substantial amounts of power, but they're subject to political oversight by the president and the White House and by Congress. And what we want to achieve is a balance where we have an appropriate amount of responsiveness to political oversight, but not so much that it turns into what amounts to partisan meddling and just the politicization of science and process that undermines expertise and the legitimacy of administrative decisionmaking. So what the guardrails protect us against is exactly that. They create a space for the legitimate exercise of political oversight, and then the guardrails ensure that decisionmaking stays within that space and doesn't crash out into the zone of partisan meddling, undermining science.

So, what the guardrails are for, and why the years of experience matter, are two things. One is that doing cost-benefit analysis isn't easy, actually. It turns out there's lots of challenges and it's hard stuff. And so in a difficult task, you get better at it over time. And over the years we've developed methodologies to address different kinds of questions, but there's another thing too, which is that you get something like a common law of cost-benefit analysis, a set of best practices that have been endorsed by both administrations of both political parties that just have been around for a long time. It doesn't actually necessarily mean they're right. But what it does mean is that they create a default and what the default does is help ensure that the methodology is not being manipulated in a particular circumstance to get to a favored outcome, right?

You're not looking at the answer that you want to get and then doing the work to get to that answer; you're doing the work and then letting that guide you. So what that does is that means that when you see an administration or an agency departing from those longstanding practices, that's a red flag that says, “Wait a second.” Especially if it's not justified: Why are you doing it this way, rather than that way when this way is the way that the Bush administration did it, and the Reagan administration did it, and the Clinton administration did it? If you can't give us a good reason why, and then, Oh, lo and behold, it happens to favor a special interest group at the expense of the public. And so I think that that's kind of a dynamic there of why the longstanding practice matters.

Kristin Hayes: Well, you're definitely leading us into the next section of the book as well. I do want to come back a little bit later in our conversation to this question of the fact that cost-benefit analysis is very difficult and it does present real challenges and there probably are some pieces of the puzzle that will always need improving, but, for now, why don't we get into some specifics? And I will note that as I mentioned, the next section of the book is rather provocatively titled “Charade.” And in these chapters, you both call out a number of specific examples where you see the Trump administration in particular as having abandoned these best practices that you were talking about, Mike. And so can I ask each of you to just highlight one example that you describe in the book? Ricky, why don't I start with you?

Richard Revesz: Terrific. So that part of the book has six chapters. There's six, I think, very compelling examples. So the one I'll focus on for now is the use of co-benefits, which is the indirect benefits of regulation. It's well-established. I think any respectful economists who tell you that when cost-benefit analysis regulation is done, the benefits that should be considered are both the direct benefits of regulation—that is the benefits under the regulatory program that's justifying the rule—and also any indirect benefits that might come about.

So for example, the regulation of greenhouse gases will reduce greenhouse gases, and that's a direct benefit. But it might also lead to process changes that produce a reduction in particulate matter, which is a local pollutant, not a greenhouse gas. And those reductions in particulate matter are the indirect benefit of the regulation or the co-benefit and Circular A-4, which is the OMB circular that dates back to the Bush administration that gives agencies guidance on how to conduct cost-benefit analysis, is very clear that co-benefits must be taken into account.

And there's no debate in the economics community about that. The Trump administration has called co-benefits into question and in fact is trying to put together a set of regulatory measures that erases the co-benefits of regulation as a way to make the benefits seem smaller and make it more difficult to justify regulatory measures and make it easier to justify deregulatory measures. Again, it's not just that there's a debate about this. This is like the earth is flat kind of an approach, but having done that, it doesn't even have the intellectual decency to be consistent.

In some cases, actually, deregulation will be helped by taking co-benefits into account. And in those cases, the Trump administration embraces co-benefits with enormous vigor. And the example here are emission standards for cars, which are set by EPA and the companion CAFE standards, which are fuel economy standards set by the US Department of Transportation. The only way that the rollback of the Obama administration standards could even plausibly be justified is by paying attention to some alleged safety benefits, which the Trump administration embraces with vigor.

Well, the safety benefits are not the direct benefits of vehicle emissions standards for EPA. The direct benefits are reductions in greenhouse gases, and EPA doesn't even have a vehicle safety jurisdiction for the Department of Transportation for the CAFE standards. The direct benefits are the reductions in energy consumption. It comes under the statute that was set up after the energy crisis and we were trying to be less dependent on oil. The Department of Transportation does have a safety jurisdiction, but not under the CAFE program. So any safety benefits are co-benefits.

The Trump administration vigorously embraces co-benefits there, but when it wants to get rid of the finding that the regulation of the hazardous air pollutants from power plants is appropriate and necessary, it says that the co-benefits of particulate matter reductions should be ignored. So not only, on the whole, is the Trump administration's attack on co-benefits going against any plausible economic approach, but the Trump administration is being totally inconsistent and is basically saying, “We'll even embrace co-benefits or we'll reject co-benefits depending on what best serves our deregulatory agenda.” And it's for that reason that that part of the book has the chapter name, “Charade.”

Kristin Hayes: Right. Okay. Thanks. And Mike, is there an example that you would want to highlight as well?

Michael Livermore: Sure. I'll do something that is so over the top that it doesn't require any technical background to understand what's going on. So in the summer of 2019, the Food and Nutrition service, which is in the US Department of Agriculture, issued a rule that would change the eligibility for the Food Stamps program, basically, which was going to eliminate assistance for 3 million people. So that's the basic rule. There was an analysis of the rule and it became clear as the agency was contemplating the proposal, that one of the consequences is that half a million children would be excluded from the Free School Lunch program, because their parents would no longer be eligible for food stamps. The agency figured this out, learned it, and intentionally kept that information out of the final cost-benefit analysis.

The agency didn't put it in as a way of hiding essentially what one of the most important consequences of its decision was going to be. So this wasn't in the weeds; this wasn't a technical matter. It was just the agency flagrantly—

Kristin Hayes: Tipping the scales. Yeah.

Michael Livermore: Exactly. So that's one example.

Kristin Hayes: Yeah. Well, let's turn to the final and more hopeful section of the book then, because you've obviously called out some places where these departures from practice have had some pretty significant consequences. But in the third section, you write that it offers some of your thoughts on how cost-benefit analysis might be saved. And so what would you suggest are some of the most important actions to take, to build or to rebuild trust in cost-benefit analysis? And then maybe on the flip side of that, are there any criticisms of cost-benefit analysis that have equally accumulated over the years, that you do think the incoming administration should consider, or parts that you'd call out for revision that might help rebuild that trust? So, Ricky, let me turn that one to you.

Richard Revesz: Terrific. It's an exciting time to talk about this topic because in two months, a new administration will take office and we'll be in a position to actually significantly change the practices around cost-benefit analysis. And I think the challenge for the new administration falls into three categories. So the first is undoing all of the damage of the Trump administration. And that won't be easy, because it probably won't be like just turning off the switch and saying, “All this bad stuff goes out the window. And then we'll start afresh.”

The Trump administration has said that it would finalize a rule on how cost-benefit analysis must be conducted for clean air rules, and any regulation has to be undone because of notice-and-comment rulemaking, which is a difficult process and time-consuming. So there is a lot of underbrush that needs to get cleared. It needs to get cleared quickly because otherwise it will make it more difficult for regulations to actually be put in place.

The second component is modernization. This, I mean, the lack of modernization is not a particularly the fault of the Trump administration. So the first component is; the second component is not. A lot of the building blocks of cost-benefit analysis have not been reviewed for a long time. I mean, the leading document giving agencies guidance on how to conduct cost-benefit analysis, I already mentioned, is OMB’s Circular A-4. It dates back to 2003 and the Bush administration, it's a good document, but it's soon going to turn 18. It won't be a child anymore.

Kristin Hayes: It can vote.

Richard Revesz: It can vote. And so various companies have not been updated. For example, discount rates of 3% and 7% have to be used to analyze the consequences of future benefits and costs. I think there is a view in the economics community that those numbers are high. There's also significant economics scholarship on why lower numbers and perhaps declining numbers should be used in inter-generational settings and in settings where the benefits happen way into the future in the face of climate change.

Kristin Hayes: Right, like climate change. Yeah.

Richard Revesz: Right. And so those things need to get reviewed and need to be updated, and need to be modernized. And Circular A-4, or kind of a new version of it, needs to rely on the best scholarship available in 2021 and not the best scholarship available in 2003. A lot of work has been done. RFF has done a lot of that work and it should be reflected in how cost-benefit analysis is conducted.

The third component, and this is very important, is that distributional consequences have always been considered a relevant criterion for evaluating regulation; it should be looked at alongside cost-benefit analysis. And the cost-benefit analysis executive order, or the Clinton executive order, and some additional orders from the Obama administration make that very clear, but we've never been successful at looking at distributional analysis. And in particular, I mean the impacts of regulation on disadvantaged, vulnerable, and marginalized groups.

We don't have the techniques for doing that. Circular A-4, for example, says nothing about distribution, but given the commitments and platform of the Biden-Harris administration, their statements in the campaign, and given the particular time that we're living in our society, it's clear that attention to distributional issues will be a priority, and cost-benefit analysis will have to adapt these methodologies to make that inquiry possible. “Adapt” isn't quite the right word. I mean, it's going to have to go from zero to 60 very quickly to be able to provide the analytical underpinnings to satisfy a very important political commitment.

Kristin Hayes: This makes me want to ask you guys kind of a spontaneous question, too. As you noted, Ricky, RFF is very much steeped in this work and has a number of economists on staff who think about these analytical methods. You both are lawyers and you talk the language of economics with a fluency that is quite impressive. Ricky, could you say a little bit more about the intersection of law and economics here and how those two disciplines intersect in this particular area?

Richard Revesz: Definitely. Well, for better or worse in the United States, lawyers play a disproportionate role in the formulation of public policy. I'm just describing a situation. I'm neither defending or attacking, I'm just describing.

Kristin Hayes: Okay.

Richard Revesz: And so I think the challenge is to be steeped in the best economics, at least as consumers. I mean, I've actually published in economics journals. I've actually even coauthored a couple of articles with Ken Arrow, the Nobel prize winner, as well as other prominent economists. And I have some graduate training in economics, although I do not have a PhD, but the question is how to make the best economics accessible to decisionmakers—basically both agencies and then the courts—where these things get litigated. Policy Integrity, the group that Mike and I founded together and that Mike first directed and I direct now, participates a lot in these proceedings.

For example, we played a very important role in getting a federal court of appeals in 2016 to hold that the Obama administration’s global social cost of carbon approach was a reasonable approach, against the approach by the US Chamber of Commerce that argued that only domestic numbers should be used. And just a few months ago, an amicus brief that we wrote was very influential in the decision by a US district court in California that held that the Trump administration’s domestic only number was arbitrary and capricious, and then struck it down.

So the challenge is how to make this the best economic principles. And I think most economists, certainly most RFF economists, would think that the way to value the damages of climate change is by looking at global damages and not some kind of subset of those damages, but how to make those arguments in a way that could be accepted by a court. And that's actually not something that economists are trained to do. So it requires a kind of quality that groups like Policy Integrity have, where we have lawyers and economists working side by side, figuring out both how to bring the best economics to the rectory table and then how to make it accessible and persuasive in arguments before the relevant decision makers.

Michael Livermore: So I agree with that. Exactly. Right. The one thing I would add is that on top of identifying the best economics, doing this important work of translation and bringing it into the regulatory process, there is something useful about law and kind of the legal methodology and that style of thinking. It independently brings something useful here that couldn't just be substituted by say someone with an Economics PhD who kind of learned how to communicate effectively. Which is that for a lot of these questions, there's a mix of normative and empirical issues in play. Climate change is an obvious example, but basically any policy question is a mix of empirical and normative questions.

And I think one of the values of a legal perspective is to clarify and identify where there are pure empirical questions and where there are normative questions, and think in sophisticated ways about those normative questions. With the field of economics, welfare economics has something to say about many normative questions, but it's not the final word. And so bringing to bear lots of different normative perspectives and creating space for those, I think as another interaction with the social sciences and the physical sciences is something that lawyers who have a broad interdisciplinary orientation can do.

Kristin Hayes: Fantastic. Thank you both for kind of talking me through that, because that is something that I've been curious about. Certainly this seems like an area where the interdisciplinary work is important and you both did a very good job of kind of articulating why. So Mike, let me ask you one final question about the book itself before we wrap up. And I want to ask this question sort of centered in RFF's commitment to nonpartisanship.

So the book as you've noted calls out actions of certain administrations by name, but I would argue that what you've tried to create here is actually an apolitical book that makes the case for good cost-benefit analysis by addressing concerns on both sides of the aisle. Is that a fair assessment? Is that an overly optimistic assessment? How would you put this in a kind of a broad bipartisan or nonpartisan context?

Michael Livermore: Yeah, I think it's a fair assessment. That certainly was our goal. I think that one of the signs, to the extent that we've been successful, is that folks of different partisan affiliations or even kind of broad ideological orientations, will find something useful there. We can disagree about a lot of things, and there's legitimate things to disagree about on regulatory policy and public policy more generally, but folks across the spectrum generally agree that evidence, analysis, and expertise are valuable things that ought to have a place in our decisionmaking. And that's really the argument of the book. And so it's one that we hope can find an audience quite broadly.

Kristin Hayes: Well, fantastic. And I really do want to thank you both for coming on the podcast to talk about this new book. I will note it was released on November 11th. I'm sure there are opportunities to purchase it should folks be interested, but let me close with again thanking you for joining me and then with our regular feature, Top of the Stack. So let me turn to you and ask if you have recommendations on more good content of any variety. And again, either related to this subject, or maybe just something else you want to share with our listeners. So Mike, let me start with you. What's on the top of your proverbial stack?

Michael Livermore: Well, I'll tell you one of my favorite pieces of culture these days is a podcast by a physicist at CalTech. His name is Sean Carroll and the podcast is called the Mindscape podcast.

Michael Livermore: It's really fantastic. He's super, super smart and brings in the broadest possible group of people that you can imagine. So, one episode, he's talking with a guest about black holes or quantum entanglement. And then in another episode, he has Wynton Marsalis talking about jazz and time. And in another episode, he brings in social scientists or neuroscientists or philosophers to talk about free will. It's really fun and very broad. And I definitely suspect that many of your listeners would find some value there as well.

Kristin Hayes: Great. Okay. Ricky, what about you?

Richard Revesz: A podcast: Nice White Parents. It examines racial inequities in public schools and underscores how even well-meaning people can exacerbate those inequities. It's actually very connected to some of the distributional issues that we've talked about in this podcast tonight. Very highly recommended.

Kristin Hayes: That's great. All right, well shout outs for the podcasts all around. That's great. Well, gentlemen, thank you again for joining me. It's been a pleasure talking to you. I would encourage folks to check out the Top of the Stack recommendations and of course, if they're interested in the book itself. So thank you both.

Michael Livermore: Thanks very much.

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