Abstract: Many people have argued for cost-benefit analysis on economic grounds. In their view, a primary goal of regulation is to promote economic efficiency, and cost-benefit analysis is admirably well suited to that goal. Arguments of this kind have been met with sharp criticism from those who reject the efficiency criterion or who believe that in practice, cost-benefit analysis is likely to produce a kind of regulatory paralysis (“paralysis by analysis”) or to represent a bow in the direction of well-organized private groups.