Here is Lisa Heinzerling’s and Frank Ackerman’s critique of cost-benefit analysis, Pricing the Pricelesss: Cost-Benefit Analysis of Environmental Protection (they also discuss Larry Summers’ toxic waste memo). They write,
In recent years the use of “cost-benefit” analysis to set environmental standards has attracted a large and high-profile group of supporters. According to its advocates, cost-benefit analysis offers a way of achieving superior environmental results at a lower overall cost to society than other available approaches.
This view is mistaken. Cost-benefit analysis is a deeply flawed method that repeatedly leads to biased and misleading results. Far from providing a panacea, cost-benefit analysis offers no clear advantages in making regulatory policy decisions and often produces inferior results, in terms of both environmental protection and overall social welfare, compared to other approaches.
The paper is here (pdf).