Regulators Should Value Nonhuman Animals

Some regulations do not only reduce human deaths, injuries, and illnesses; they also protect nonhuman animals. Regulatory Impact Analyses, required by prevailing executive orders, usually do not disclose or explore benefits or costs with respect to nonhuman animals, even when those benefits or costs are significant. This is an inexcusable gap. If a regulation prevents dogs, horses, or cats from being killed or hurt, the benefits should be specified and quantified. This proposition holds even if those benefits are in some sense incidental to the main goal of the regulation. At the same time, turning the relevant benefits into monetary equivalents raises serious challenges, akin to those raised by the valuation of statistical children.