Thursday, June 8, 2023

Cost Benefit Comments

The Biden Administration is proposing major changes to cost-benefit analysis used in all regulations. The preamble here, and the full text here. It is open for public comments until June 20

Economists don't often comment on proposed regulations. We should do so more often. Agencies take such comments seriously. And they can have an afterlife. I have seen comments cited in litigation and by judicial decisions. Even if you doubt the Biden Administration's desire to hear you on cost-benefit analysis, a comment is a marker that the inevitable eventual Supreme Court case might well consider. Comments tend only to come from interested parties and lawyers. Regular economists really should comment more often. I don't do it enough either. 

You can see existing comments:  Search for Circular A-4 updates to get to, then select “browse all comments.” (Thanks to a good friend who sent this tip.) 

Take a look at comments from an MIT team led by Deborah Lucas here and by Josh Rauh. These are great models of comments. You don't have to review everything.   Make one good point. 

Cost benefit analysis is useful even if imprecise. Lots of bright ideas in Washington (and Sacramento!) would struggle to document any net benefits at all. Yes, these exercises can lie, cheat, and steal, but having to come up with a quantitative lie can lay bare just how hare-brained many regulations are. 

Both Josh and the MIT response focus on the draft proposal's use of ultra-low discount rates, ranging from historic TIPS yields to arguments for zero or negative "social" discount rates. Josh emphasizes a beautiful compromise: always show the annual stream of costs and benefits. Then it's easy enough to apply different discount rates. No Black Boxes. 

Discount rates seem like a technical issue. But they matter a lot for climate policies, or for policies with substantial cost but putatively permanent benefits, because of the long horizons. For example, climate change is alleged to create costs of 5% of GDP in 100 years. So, let's assume a 0% discount rate -- treat the future just like the present. How much is it worth spending this year to eliminate additional climate change in 2100? Spend means real spending, real reductions in everyone's standard of living, not just funny money billions on twitter. 

If you answered "5% of GDP" (roughly $3,500 per person) that's wrong, for two crucial reasons. First, the economy grows over time. At a modest 2% real growth, US GDP will be 7.4 times as large in 100 years as it is today, or 640% greater. (e^2=7.4). Thus, 5% of GDP in 100 years, discounted at 0%,  is 7.4 x 5% or 37% of today's GDP, or $17,500 per person today. Second, the gain is forever -- 5% of 2123 GDP, but 5% of 2124 GDP, and so on. Discounted at a zero rate, 5% of 2123 forever after that is worth... an infinite amount today. But GDP keeps growing after 2123. If you discount at anything less than the growth rate of GDP -- 2% in my example -- 5% of (growing) GDP forever is worth an infinite amount!  So what if $250 billion subsidizing huge battery long range electric cars made by union labor in the USA from hypothetical US made lithium mines might, all in, save a thimbleful of carbon per car (is it even positive?), if the benefits are infinite, go for it. 

If you discount by a low, but somewhat more reasonable number like 7%, then a dollar in 100 years is worth 0.09 cents today (100 x e^-7). Now you know where to put your thumb on the climate scales! 

You might be wondering, if our great grandchildren are going to be so fantastically better off than we are, let them deal with it. Or you may be wondering that maybe there are other things we could do with money today that might speed up this magical growth process and do 5% better. For an infinite amount of money, is there nothing we can do to raise the growth rate from 2% to 2.05%? 

The latter opportunity cost question is, I think, a good way to think of discount rates. The average real return on stocks is something like 5%, at least. The average pre-tax marginal product of capital is higher; pick you number but it's in the range of 10% not 1%. The right "discount rate" is the rate of return on alternative uses of money. Josh and the MIT team are exactly right to point out that using the rate of return on risk free government bonds is a completely mistaken way to discount the very risky costs of climate damage -- that 5% is a very poorly known number -- and the even riskier benefits of the government's shifting climate policy passions. But I think phrasing the experiment in terms of opportunity costs rather than proper discounting of risky streams makes it more salient, despite the decades I have spent (and an entire book!) on the latter approach. Businesses can take $1 today and turn it in to, on average, $1.07 next year. Why take away that money for a project that yields $1.00 or $1.01 next year? 

The former question has a deeper consequence. Why should we suffer to help people, even our grandchildren, who will be on average 7.4 times better off than we are? How much would you ask your great grandparents to sacrifice to make you 5% better off than you are today? 

Here the low discount rate clashes interestingly with another part of the proposal: equity and transfers. 

From the preamble p. 12: 

A standard assumption in economics, informed by empirical evidence (as discussed below), is that an additional $100 given to a low-income individual increases the welfare of that individual more than an additional $100 given to a wealthy individual. Traditional benefit-cost analysis, which applies unitary weights to measures of willingness to pay, does not usually take into account how distributional effects may affect aggregate welfare because of differences in individuals’ marginal utility of income. Related to the topic of distributional analysis is the question of whether agencies should be permitted or encouraged to develop estimates of net benefits using weights that take account of these differences.26 The proposed revisions to Circular A-4 suggest that agencies may wish to consider weights for each income group affected by a regulation that equal the median income of the group divided by median U.S. income, raised to the power of the elasticity of marginal utility times negative one.

Now wait a darn-tootin' minute. The "standard" doctrine in economics is that you cannot make intra-personal utility comparisons. Utility is ordinal, not cardinal. Here cardinal-utility utilitarianism with equal Pareto-weights is about to be carved into federal stone. (To decide social benefit of taking from A and giving to B, you construct a social welfare function \(u(c_A) + \lambda u(c_B)\). This needs you to use the same \(u()\) for A and B, and agree on a Pareto-weight \(\lambda\) implicitly one here.) 

Imagine a simple regulation: take a dollar from Joe ($100,000 income) and give it to Kathy ($50,000 income). By this standard such a straightforward transfer passes a cost-benefit test.  

But this does not get applied over time. Taking a dollar from you and me, and at a discount rate of 0% giving it to our great grandchildren who will be 7.4 times better off should set off massive inequity alarm bells. Nope. 

Indeed, you can deduce a discount rate from the inequality goal. Pure undiscounted intergenerational equity requires a discount rate proportional to the economic growth rate. 

(With power utility, an intervention that costs A $1 to give B $\(e^{rt}\) just passes a cost-benefit test if \[c_A^{-\gamma} = e^{rt} (c_B)^{-\gamma}.\]  If B is \(e^{gt}\) times as well off as A, \(c_B=e^{gt} \times c_A\) then we need  \(r=\gamma g\). \( \gamma\) is usually a number a bit bigger than one.  The preamble's discussion of \(\gamma\) values is pretty good, settling on a number between one and two. However, they haven't really heard of the finance literature: 

Evidence on risk aversion can be used to estimate the elasticity of marginal utility. In a constant-elasticity utility specification, the coefficient of relative risk aversion is the elasticity of marginal utility. There are numerous different estimates of the coefficient of relative risk aversion (CRRA), using data from a variety of different markets, including labor supply markets,29 the stock market,30 and insurance markets.31 Relevant estimates vary widely, though assumed values of the CRRA between 1 and 2 are common.32

30 Robert S. Pindyck, “Risk Aversion and Determinants of Stock Market Behavior,” The Review of Economics and Statistics 70, no. 2 (1988): 183-90 uses stock market data and estimates the CRRA to be “in the range of 3 to 4"

Since then, of course, the whole equity premium literature sprang up with coefficients 10 to 50. Shh. That would justify insane levels of equity. 

The draft also encourages all sorts of unquantifiable non-economic "benefits," but I'll leave that for another day. 

Read and comment. 

BTW, despite my negative tone and picking on these elements, much of the draft is quite good. Here is a particularly nice piece, from p. 26 of the full text 

j. A Note Regarding Certain Types of Economic Regulation

In light of both economic theory and actual experience, it is particularly difficult to demonstrate positive net benefits for any of the following types of regulations:

 price controls in well-functioning competitive markets;

 production or sales quotas in well-functioning competitive markets;

 mandatory uniform quality standards for goods or services, if the potential problem can be adequately dealt with through voluntary standards or by disclosing information of the hazard to buyers or users; or

 controls on entry into employment or production, except (a) where needed to protect health and safety (e.g., Federal Aviation Administration tests for commercial pilots) or (b) to manage the use of common property resources (e.g., fisheries, airwaves, Federal lands, and offshore areas).

Well, FAA tests and rules for commercial pilots is not actually quite so obvious and really needs a cost benefit test. "Commercial pilot" does not mean "airline pilot," it means can you do anything in an airplane and get money for it. But leave that for another day, these principles if applied could clean out a lot of mischief. Well, I guess many on the progressive left or nascent national-conservative right would deny there is such a thing as a "well-functioning competitive market." 


I should have added: It's insane to make a once and for all cost benefit analysis, especially for projects with 100 year horizons. All regs should be re evaluated every 5 to 10 years, and use experience to update costs and benefits. 




  1. -- I think that's the link you were looking for, and you'll recognize at least some other commenters (who chose to easily identify themselves in submissions). I am also reading the deadline as June 20th, but I might be off, as the docket is not that well-updated.

    And +1 on importance of public comments and on the importance of the A-4 circular in particular!

  2. Economy cannot grow by 2% forever, because physics. Why are you so sure we won't hit that wall by 2123?

    1. How is physics relevant here? Are you posting from a couple galaxies over?

    2. Don't think of economic growth in terms of 'more', think of it in terms of 'better'. Our vehicles can become safer and more efficient, our electronics computers faster, our batteries more energy dense, etc without any of the above requiring more raw materials to produce or energy to operate -- indeed improvement (growth) happens even while requiring ever fewer raw materials and energy inputs.

    3. Physics is relevant because whether you call it growth or whether you call it betterment - it can't go on forever. Sooner or later it will stop because the world is finite and is made of finite particles. You can assume that we're far from that, but that's just an assumption without any evidence.

    4. This is not true. GDP (and, more importantly consumer surplus) is measured by value, not by atoms. The things we value and pay for are becoming less and less resource intensive all the time. Exchanging high value services for other high value services can make us all happier and healthier without resource limits.

    5. They are not becoming less resource intensive because magic. It happens because technology improves (coughphysicscough), but that cannot go on forever. It will stop. Perhaps it stops in 2000123 or perhaps it's 2123 - I don't know - and it's wishful thinking to claim to know the answer to that.

  3. You write that US GDP will be 7.4 times as large in 100 years as it is today, or 740% greater. 7.4 times greater means greater by 640%, not by 740%. (I am not a native speaker, so I might have misunderstood your formulation.)

    1. "7.4 times as large in 100 years" means "greater by 640%". B/A = exp(2) = 7.389, say 7.4 (rounded to 2 significant figures), then (B - A)/A = 7.389 - 1 = 6.389, say 6.4 (rounded to 2 significant figures).

  4. When I was on staff at The Heritage Foundation 3 decades ago, they wanted to invest a large donor-sum into a data center with large macro models. In the D.C. political debates, opponents were touting models and data "to prove the superiority" of proposed policy advocacy. Heritage wanted to fight the other side.

    I was a lonely voice protesting that interpersonal comparisons of cardinal utility was nonsense. They started their (sexy) macro data project anyway, and I retired from that job. Which reminds me of your recent posting on "group think."

    Maybe, in truth, noise from one side can be blunted by noise from the other side. But a shouting match is hardly a way to select a better path. Nonsense is nonsense.

    Thank you for this analysis today. It shows I was not being foolish.

  5. As an employee benefits practitioner (and novice practitioner of behavioral economics applications in employee benefits), I am often perplexed by the cost benefit analysis the agencies deploy as justification for rules and regulations per Executive Order 12866.

    A good example was the fee disclosure regulations for retirement savings plans that took effect in 2012 - which were not prompted by any new legislation from Congress.

    The Department of Labor estimated participant time savings from reduced time searching for fee information. '... Pursuant to Executive Order 12866,
    ... the net present value of benefits is $12.3 billion, affecting 72 million
    participants in 483,000 participant directed individual account plans
    containing assets valued at nearly $3.0 trillion. Over ten-years (2012–
    2021), the present value of benefits will be $14.9 billion and the present value of the costs will be approximately $2.7 billion. A significant benefit of this regulation is that it will reduce the amount of time participants spend
    collecting fee and expense information and organizing the information in a
    format that allows key information to be compared; this time savings is estimated to total nearly 54 million hours valued at nearly $2 billion in 2010 (2010 dollars).'

    However, the DOL never actually confirmed just how much time people were spending in 2010 searching for fee information. As a practitioner, I can confirm it - few knew they were paying fees, and even fewer were searching for fee information. Worse, most plans don't offer a choice of investments for every one of the 9 domestic equity style boxes, let alone fixed income choices, international, etc.

    Just as important, the regulatory guidance never confirmed that the singuler hyper focus on fees ignored the more important data on investment option performance, net net of fees. Similarly, the regulations failed to confirm the #1 reason why fees vary from plan to plan - the size of the plan, assets under management, etc. So, there is no comparabive data other than index funds. For example, if you offer employer stock, the regulations suggest you can use the S&P 500 as the comparator investment.

    So, whoever submits a comment letter, please consider including the following recommendation:

    With respect to all rules, regulations and Federal Programs adopted in the past and those adopted in the future:
    (1) All such rules, regulations or Federal Program should receive an updated cost/benefit analysis, to include metrics to prospectively collect data (or, where available, use CBO scoring of the legislation), and
    (2) Once five years of data for cost/benefit metrics have been accumulated, each agency rule/regulation, or Benefit-Cost Analysis of a Federal Program, should be reviewed (completing the updated analysis in the 12 months following) to prove or disprove the accuracy of the cost/benefit estimate.

    This would require the agencies to identify the metrics and to capture necessary data. The Congressional Budget Office would have to provide the economic analysis it used in pricing the legislation.

    Where a rule, regulation or Federal Program underperforms and does not achieve the estimated cost/benefit, the rule/regulation/Federal Program should sunset no later than the end of the 12 month period described above leaving Congress/agencies to decide next steps.

    Simply, many regulations are ineffective and should be changed, updated or discontinued. With respect to fee disclosure, see:

    Thank you for your consideration.

  6. As usual, the grumpy economist is exactly correct. Given the incentives for government errors (corruption) a discount rate of at least 10% should be used. Particularly on the subject of “climate change” (née global warming) the government is highly politicized. The simple fact is that over the last ~70 years there is no statistically significant relationship between atmospheric carbon dioxide and global temperature. And, as China and so many others won’t do anything to limit their CO2, it’s crazy for the U.S. to spend anything on this issue.

  7. "Discount rates seem like a technical issue. But they matter a lot for climate policies, or for policies with substantial cost but putatively permanent benefits, because of the long horizons. For example, climate change is alleged to create costs of 5% of GDP in 100 years. So, let's assume a 0% discount rate -- treat the future just like the present. How much is it worth spending this year to eliminate additional climate change in 2100?"

    Society has a time preference that is positive. Let the time preference rate be given by the parameter r > 0, where r is equal to -ln((β)). β > 0 is the discount factor used in the NK-DSGE model's Phillips Curve equation, and the discount factor used to determine the discounted present value of the infinite sum of the periodic utility functions of private consumption expenditures of the representative household. The first-order condition (Euler equation) for the optimization of the discounted present value of the sum of the utility functions of private consumption is the foundational basis of the NK-DSGE model’s Intertemporal Substitution (“IS”) equation.

    Suppose that the government proposes to expend K dollars in public capital expenditures today by reducing private consumption expenditures by (1 - θ)·K dollars and private investment expenditures by θ·K dollars, to avoid the certain event of a reduction of national income by a perpetual φ·Y dollars per year commencing n years from today arising from the negative economic & societal effects of 'climate change'. [n.b., (1 - θ) is the private marginal propensity to consume.] If the government does not expend K dollars for the public capital expenditures, the social value of K dollars of private consumption and investment expenditures has a present value of Ψ·K dollars ( Ψ > 1). [n.b., $1 today has the same purchasing power as $1 in n years' time.]

    Then, if Ψ·K > (φ·Y/r)/(1 + r)ⁿ, the government should not expend the K dollars on public capital expenditures to avoid the reduction of national income by a perpetual φ·Y dollars per year commencing n years from today. In this case, the present social value of the certain loss of future income in n years’ time is less than the present social value of the private consumption and investment expenditures of K dollars today.

    But, if Ψ·K < (φ·Y/r)/(1 + r)ⁿ, then the investment should go forward because then the reduction in private consumption and investment expenditures today is warranted by the present social value of avoiding the certain event of a reduction of national income by a perpetual φ·Y dollars per year commencing n years from today.

    This is the criterion laid down by Edward J. Mishan in his book Cost-Benefit Analysis (1976, New York: Praeger Publishers). It follows from two precepts: (1) society has a time preference expressed as a rate, r, that equates private consumption in the current period to private consumption in a future period n years’ ahead through the discount factor β = exp(-r) raised to the power of n; (2) the criterion for accepting a public agency’s proposal to reduce private consumption and investment expenditures by K dollars in the present in order to produce a stream of future of benefits {Bᵢ} (i = 1, 2, ..., t, ..., n) by K dollars of capital expenditure today should be that the present social value of the discounted stream of future benefits {Bᵢ} at the social time preference rate, r, exceeds the discounted present social value of K dollars of private consumption and investment expenditures, i.e., Ψ·K dollars.

    The social opportunity cost of capital is given by p = [(1 - θ)·r + ρ·θ]/r, where ρ is the rate of return on private capital expenditures.

    One can expand this basic approach, and bring into it ‘realism’ via complexities such as stochastic ‘shocks’, time variant rates of return, &c. One can substitute uncertainty for certainty, then reduce it to a certainty-equivalent problem to be solved with a risk-neutral measure, &c.

    1. The real challenge in doing a cost- benefit analysis is identifying all the cost and all the benefits.
      Fossil fuel has provided cheap reliable energy for decades allowing unimagined improvements in the quality of life world wide. Test none of these benefits are included in the the cost-benefit annaliys. CO2 alleged costs are all allocated to fossil fuel.
      Electric vehicles are alleged to be Zero emissions, yet none of the CO2 emitted during the production of the electric these vehicle use is considered. Then the cost of extracting the rare earth and other metals necessary to manufacture these batteries and at some point we’ll have used batteries to recycle.
      The same asymmetrical treatment is applied to clean energy produced by wind turbines and solar panels. These are clean energies until you include the cost of manufacturing and disposing of the solar panels and turbines.
      An old friend once told me “nothing difficult is ever easy” We need to stop trying to make easy analysis of complex problems.
      Government cost-benefit analysis is a prime example of looking for an easy solution to a difficult problem

    2. For a discussion on discount rates related to climate change abatement investments see:
      L. Barrage and Wm. Nordhaus, May 15, 2023, "Background Note on Rates of Returns and Discounting". Not published.

      The background note (for informational purposes for modelers, not intended for publication) discusses the difficulty of determining the appropriate rate of discount for climate abatement related investments vs. non-climate related capital investments (i.e., investments in bolted-down capital and, similarly, related real options on physical investment projects). Historical rates of return on securities investments and real asset investments are presented. The Ramsey approach to estimating the appropriate discount rate is discussed. The application to the IAM climate model application DICE is discussed and the pros and cons of the one-stage and the alternative two-stage CAPM determination of the discount rates are listed.

  8. We should not underestimate this statement:

    "Yes, these exercises can lie, cheat, and steal, but having to come up with a quantitative lie can lay bare just how hare-brained many regulations are."

    It is on point and sums up the need for comments on proposals. Thank you for the work done here.

  9. "The Biden Administration is proposing major changes to cost-benefit analysis used in all regulations." My question. Who should do these analyses? Each individual knows far more, than anyone else, about their subjective preferences and more about their opportunities and opportunity costs than any one else. Each individual possesses stronger incentives than anyone else to pursue their greatest total net benefit. The better alternative for cost-benefit analysis is the individual. The reasons: The amount of information and knowledge central planners have is less ample than individuals have. Central planners have a strong incentive to substitute their own preferences for those of individuals. To do cost-benefit analyses with better accuracy, as many as possible should be done by individuals in free markets. If the planners in the administration have open minds, they would heed Hayek's advice to social scientists; recognize their “insuperable limits to his knowledge.”

  10. Former CBOer here. It's far from obvious that the appropriate discount rate for climate related benefits should mimic the 7% estimate of an economy-wide cost of capital if what you are trying to mitigate is the risk of catastrophic losses. Catastrophic insurance is a low or negative beta asset and this comes straight out of Arrow-Debreu state pricing. Try valuing the loss payments on a loan guarantee using a positive beta discount rate and revel in the unintuitive outcomes. I think Gollier explores this in one of his papers and comes up with low discount rate estimates. There's a big difference between e^-1, e^-3, and e^-7 in terms of how much investment in mitigation and non-emitting energy sources that allows.

    1. How catastrophic are the expected climate change losses? The median ipcc forecast puts climate change related impact at 5% of world GDP? Are these catastrophic enough to qualify?

  11. As to the damage function, a review of "What the Earth Knows", Rob't. B. Laughlin (June 2010), The American Scholar, will put it in perspective. R. B. Laughlin is a professor of physics at Stanford University and a co-recipient of the 1998 Nobel Prize for Physics. Navigate to:

  12. Many valid points, but I'd like to clarify that what is being "taken" to day is the dead-weight loss of the measure. For example the cost of a tx n net emissions of CO@ is not the revenue collected, but the disutility of shifting consumption patterns form more to les CO2 emissions intensive good and services.
    I difficulty with the approach being suggested is that the discount is being asked to do three things when it can do only one: indicate the scarcity value of capital, the time preference of consumption today and in the future, and interpersonal utility of poorer people today and richer people in the future.

  13. If you wrote a book on the topic, I'm sure the notation comes as second nature, but please define terms so that someone coming to it for the first time can more easily read through the equations and the post.

  14. When Climate is viewed as a doomsday scenario with the planet disappearing as a result of not acting soon enough, all economic analysis is thrown out the window! Emotions and political pandering is what we see today, and not the obviously needed analysis that putting some numbers to a story requires to really have a framework to understand the real impact of any policy action.
    If one is to apply numbers to the story, and use a zero interest rate or current long term Treasury Bond rate(10 yr, 30 yr) for discount purposes , the assumption is that the US creditworthiness as viewed today will remain intact; that seems quite uncertain given the extent of US indebtedness.
    And a 2% real growth is also a challenge based on current economic policies and a gov that does not seem to be growth minded, but redistribution oriented.
    So, if the narrative is dominated by the near term( 50-75 years) catastrophe crowd then any kind of analysis will be meaningless.

  15. Here's what you seem to be missing. Given declining marginal utility to wealth, the optimal distribution of wealth will be an equal distribution. (minimize vairance of wealth in the cross-section) Pure socialism. It's OK to admit that.

    Capitalism is about giving people incentive to help each other. And you can't have incentive without the promise of different outcomes. And, obviously, you can't have the promise and expectation of different outcomes unless you actually allow them to happen.

    Thus, we have a trade off between dividing the pie, and baking the pie. We don't have to deny the realities of distribution of wealth to reject policies that focus on distribution rather than building the pie.

    We can suggest that national_utility_from_wealth = sum(utility(portion_of_wealth*total_national_wealth)). This national utility will be maximized when a % change in total_national_wealth will be offset by a % change in the average_utility_from_wealth.

    I'll suggest the following heuristic: balance median household wealth with average household wealth. If a 1% increase average wealth (=pie 1% bigger) will lead to more than 1% decrease in meadian wealth (distributed so 1% decrease in average utility from wealth), we have a problem. If a 1% increase in median wealth means more than 1% decrease in average wealth, we have a problem. Thus, if capitalist policies increase motivation or national wealth at a decreasing rate, follow them until the distribution function detracts from utility greater than the motivation function adds to it.

    Pure capitalism is just the idea that the distribution function would never detract from utlity more than the motivation function adds to it. Pure socialism is just the opposite.

  16. CBAs are methodologically frought but conceptually sound. At least your asking the correct questions, even if you can't answer them very accurately. The alternative still in use everywhere is IO models and "economic impact analysis", which couldn't give the correct answer even if all the inputs and outputs were precise.

  17. John, thank you for your eloquent advocacy for wealth redistribution. As you say, "Why should we suffer to help people, even our grandchildren, who will be on average 7.4 times better off than we are?" Taking money from those with fantastically high living standards, and redistributing it to those with far lower living standards, just seems like the right thing to do.

    1. I appreciate snark as much as the next blogger, but to be clear the point made in the blog is only one of logical consistency. If the Administration is writing equity across people and groups into current regulations it's a bit strange for them to wish disequity between now and our prosperous great grandchildren. I'm not a fan of forced redistribution in either case, and happy to work hard to improve economic growth and the institutions of our society, thereby helping those far-off descendants despite their (hopefully) great prosperity.


Comments are welcome. Keep it short, polite, and on topic.

Thanks to a few abusers I am now moderating comments. I welcome thoughtful disagreement. I will block comments with insulting or abusive language. I'm also blocking totally inane comments. Try to make some sense. I am much more likely to allow critical comments if you have the honesty and courage to use your real name.