Comment by jakeydus
5 days ago
That's what I thought too, but from the ruling in the article, it seemed like the justification came from calculating the cost to implement (emphasis on 'compliance costs'.
> But an administrative law judge later found that the rule's impact surpassed the threshold, observing that compliance costs would exceed $100 million "unless each business used fewer than twenty-three hours of professional services at the lowest end of the spectrum of estimated hourly rates," the 8th Circuit ruling said.
Well, the two are related. By definition, the economic impact must be at least as much as the cost to implement. So estimating the cost to implement sets a lower bound on the total economic impact.