The DA is an opportunity cost --- political capital consumed trades off with other parts of agenda

3. Institutional path dependence. — Cost-benefit analysis also benefits from path dependence. The simple idea behind path dependence is that institutions tend to continue operating in the ways they have in the past.102 In the federal government context, one reason for path dependence is that it is costly for senior Executive Branch officials to change policies or procedures.103 Any given reform can consume time and political capital, which in turn can have high opportunity costs given the many policy objectives on any administration’s agenda. Another reason is that particular actors— both within and outside the Executive Branch—may seek to entrench the status quo. Political appointees necessarily rely on civil servants to implement their agendas.104 The extensive literature on the “internal separation of powers” emphasizes the ways in which civil servants within the Executive Branch can push back on agendas pursued by political appointees.105