"Cost-Benefit Analysis as a Commitment Device" The Vanderbilt Law School Environmental Law and Policy Annual Review, Vanderbilt's Energy, Environment and Land Use Program, Vanderbilt's Law and Economics Program, and Vanderbilt's Environmental Law Society hosted a panel discussion of Climenko Fellow Matthew Wansley's article "Cost-Benefit Analysis as a Commitment Device." Just as the expected costs and benefits of a rule determine its initial level of stringency, the observed costs and benefits of a rule should determine when and how it is updated. When an agency analyzes a proposed rule, it should explicitly anticipate adoption of a more stringent rule than the one it promulgates, then precommit to adopting the more stringent rule if a credible determination has been made that it has become cost-benefit justified. The commitment device would push the administrative state past retrospective analysis and directly addresses problems of rulemaking ossification and agency inaction.