mation. There is substance to these doubts by thevery nature of the environmental economics re-search process in Europe. The formal requirementsto engage in CBA are not rigid, as with the Environ-ment Act’s mandate on CBA to the EnvironmentAgency, or the new Regulatory Appraisal processfor government Departments. As such, CBA hasdeveloped from a mix of studies prepared unilater-ally by academics for research interest, and byacademics and consultancies for individual agen-cies and government departments. While the numberof studies is surprisingly large, it is not large enoughto provide a statistical base for benefits transfer.Combined with the fact that the science of eco-nomic valuation has evolved and still is evolving,uncertainty is endemic in the estimates. This uncer-tainty presents government with several problems.First, if policy were directly related to benefit esti-mates, then it is conceivable that the policy could besubject to legal challenge. This prospect is dis-counted by some experts because policy is, ulti-mately, whatever politicians decide it is. Only judi-cial review relating to unreasonable behaviour couldchallenge it. None the less, there is some explana-tion here for the distancing of policy from CBAresults.Second, there is outright hostility within some partsof government to some aspects of CBA, whateverthe official guidance. Some of the traditional argu-ments against monetization are often emotive andirrational, but some coherence is afforded to theseviews from the belief that environmental assets aresomehow ‘different’ and should not be subject totrade-offs. Academic studies which claim that indi-viduals do not trade off environment and othergoods—so called ‘lexical preferences’—give somesupport to this view.Third, it is often argued that CBA is not ‘transpar-ent’. Highly varied and different costs and benefitsare ‘reduced’ to single numbers, giving the impres-sion of a ‘black box’ approach to policy. This is avalid criticism which could be surmounted by show-ing the sensitivities of the CBA outcome to variousfactors and by showing clearly which stakeholdersgain and which lose. Sensitivity analysis tends tocapture most of the former, but the latter is not afeature of most modern CBAs and should be. Thismay also help overcome the reasonable objectionthat most CBAs fail to identify the incidence of costsand benefits on different groups when, in mostcases, this could easily be done. Trying to build aconsensus among stakeholders about a policy changeclearly explains the divergence of many policyoutcomes from what would appear to be ‘rational’on CBA grounds. This also explains some of theemphasis on ‘process’ which, taken to the limit,implies that, so long as the main stakeholders areassembled round a table, whatever the outcome is,it is for the best. Arguably, however, CBA reachesstakeholders who tend to be excluded from proc-ess—not everyone has a well-organized lobby orvoice.Fourth, and perhaps a cynical interpretation, CBAtends to present results in a reasonably cut and driedmanner, subject to the uncertainty of the estimates.Benefits exceed or do not exceed costs. But deci-sion-makers may place as much importance onflexibility of decision. A CBA that, in effect, re-moves that flexibility will not be welcome. At itsworst, this view says that politicians will do what-ever they want, and that they do not want to betroubled by cost–benefit studies that might producethe opposite answer: CBA ‘crowds out’ flexibility.Fifth, as noted previously, CBA works best whenthe goal of policy is economic efficiency. Distribu-tional considerations can be accounted for, as notedabove, but their incorporation probably raises thelevel of discomfort that critics feel. Other goals,such as employment creation, protection of com-petitive position, and the desirability of the processof decision-making, tend to be omitted from CBAstudies. While calling for more use of CBA inEurope, Navrud and Pruckner (1997) argue that themore formalized use of CBA in the USA owes moreto the tradition there of emphasizing economicefficiency when compared to Europe. This may betrue but raises the issue of how best to accommo-date multiple objectives if that is the desired goal. Itis far from clear that other approaches fare anybetter than CBA. CBA is readily supplemented withan analysis of effects on competitiveness and em-ployment, and modern practitioners of the contin-gent valuation approach emphasize its role in secur-ing public participation. None the less, these broaderconcerns may explain the current interest in the UKin multi-criteria techniques which have been popular