Using Probabilistic Terrorism Risk Modeling For Regulatory Benefit Cost Analysis Application To The Western Hemisphere Travel Initiative Implemented In The Land Environment

The Intelligence Reform and Terrorism Prevention Act of 2004 requires that the Secretary of Homeland Security develop a plan for reliably evaluating the identity and citizenship of people entering the U.S. In response, the U.S. Customs and Border Protection "CBP" and U.S. Department of State are proposing a regulation specifying documentation requirements for people entering the U.S. via land borders from countries in the Western Hemisphere, referred to as the Western Hemisphere Travel Initiative "WHTI-L". The White House Office of Management and Budget directs agencies to use benefit-cost analyses to evaluate proposed regulations during the regulatory review process. However, data and methods for estimating the benefits of terrorism security regulations like the WHTI-L are inadequate to support benefit-cost analysis. This report introduces a framework for using probabilistic terrorism risk modeling in a break-even analysis of a regulatory action, demonstrates an application of the framework on the regulatory analysis of WHTI-L, and discusses how this type of analysis can be further integrated into the regulatory review process.