EXECUTIVE OFFICE OF THE PRESIDENT OFFICE OF MANAGEMENT AND BUDGET : WASHINGTON , D. C . 20503 September 20, 201 2 MEMORANDUM FOR CHIEF FINANC; OFFICERS AND AGENCY BUDGET DIRECTORS ~ FROM: V L SUBJECT: r Danny werfP/.l Controller Interpretation of OMB Circul ar A-94 In 1992, the Office of Management and Budget (OMB) issued a revision to OMB Circular A-94, "Guidelines and Discount Rates for Benefit-Cost Analysis of Federal Programs," to supply guidance on the conduct of benefit-cost analysis and life-cycle cost analysis of Federal investments and other po licies. In conducting a review of the Circular we have learned about certain issues regarding its proper interpretation, which this memorandum is intended to clarify. In particular. this memorandum addresses (1) the interpretation of constant do llar or constant costs in treatment of inflation, and (2) the appropriate choice of a horizon for life-cycle cost analysis. 1. Constant-Dollar Analysis in Treatment of Inflation. Economic analysis, including both benefit-cost analysis and life-cycle cost analysis, is frequently conducted using constant-dollar estimates of benefits and costs, where benefits and costs are measured in terms of constant purchasing power not grown by an overall inflation rate. Constant-dollar analysis is especially appropriate for long- lived projects where the costs or benefits may stretch out for decades. In Section 7, Circular A-94 states : " Future inflation is highly uncertain. Analys ts should avoid having to make an assumption abo ut the general rate of inflation whenever possible." Economists distinguish between general inflation and changes in individual prices or cos ts. Although the Circular recommends against making a general inflation assumption, constant-dollar analysis permits analysts to project changes in relative prices. In Section 7, the Circular points out: "Such estimates may refl ect ex pected future changes in relative prices, however, where there is a reaso nable basis for estimating such changes." In the case of materials, the Circular permits analysts to assume different patterns of future costs , when there is evidence to support such an assumption. Agencies should decide, based on their own professional j udgment, if there is a reliable basis to assume changes in relative prices and when such assumptions wo uld improve their analysis. Regardl ess of any ass umptions abo ut relative prices and costs, all alternatives being compared should be discounted with the same discount rate following the guidelines in Section 8 of Circular A-94 . 2. Time Horizon For Life-Cycle Analysis Circular A-94 does not specify the length of time over which analysis is to be conducted. In defining life-cycle costs, the Circular states in Appendix A that life-cycle costs consist of: "The overall estimated cost for a patticular program alternative over the time period conesponding to the life of the program, including direct and indirect initial costs plus any periodic or continuing costs of operation and maintenance. " The time horizon for life-cycle analysis is project specific, but should normally be long enough to encompass the likely lifespan of the most durable alternative being compared. The Circular allows agencies to set their own guidelines for the length of analysis to produce the most useful and meaningful comparisons between alternative uses of resources in their programs. With respect to materials , it may be appropriate for the agency to consider the relative durability of materials in assessing lifecycle costs by extending the time frame for analysis. For example, if the durability of one form of a material would extend the useful life of a constructed asset as compared to an alternative material , the agency could, consistent with Circular A-94, extend the time frame used for analysis in comparing all of the relevant alternatives . The agency should use its best j udgment in terms of whether there is adequately reli able information available on the durability of materials and its associated impact on lifecycle costs when choosing the appropriate time frame for analysis. For questions regarding interpretation of Circular A-94 or the clarifications contained in this memorandum, please contact Michael Falkenheim (mfalkenheim@omb.eop.gov), OMB Deputy Associate Director for Economic Policy. 2