N001998

Friday, January 18, 2002 2:21 PM
comment on Iterim Rules


18 January 2002

Kenneth L. Zwick, Director
Office of Management Programs
Civil Division
U.S. Department of Justice
Main Building, Room 3140
950 Pennsylvania Avenue
Washington, DC 20530

                      RE: Presumed Economic and Non-Economic Loss Tables

Dear Mr. Zwick:

                      I am writing to make two comments regarding the Presumed Economic and Non-Economic Loss Tables and the Interim Final Rules.

                      1.     Discount Rate

                      In calculating economic damages, a victim?s future earnings are reduced by the income taxes that would have been payable on such earnings. When the after-tax earnings are converted into a present value figure, the interest rate used is 5.13 percent. The Presumed Economic and Non-Economic Loss Tables explain that this rate is ?equivalent, given the other components of the calculation, to a long-term, risk free interest rate.? See Step Four of the Calculation of Economic Loss. There are three problems with this rate.

                      First, the rate of 5.13 percent is clearly not available on safe tax-free instruments; it is a taxable rate. Thus, the present value of the damages is calculated using a victim?s after-tax earnings and a fully taxable discount interest rate. Because the replacement income stream generated by a taxable instrument will be subject to income tax to the extent of interest included, the victim?s family will not receive after-tax income equivalent to the after tax earnings of the victim.

                      Second, the calculation of the victim?s future earnings presumes that the victim would continue to work ?for a number of years equal to the average expected work life as defined by the U.S. Department of Labor, Bureau of Labor Statistics, ?Worklife Estimates.?? See Step Three of the Calculation of Economic Loss. But the expected work life may be considerably shorter than the ?long term? presumed when setting the discount rate. The expected work life of a 65-year old man would probably be much shorter than the 30-year maturity of a long-term bond.

                      Third, a typical long-term bond pays out only interest until the bond?s maturity, at which time the principal amount is returned On the other hand, the victim?s earnings would have been received in a series of substantially equal payments. Thus, the effective term of the victim?s earnings is shorter than the effective term of a bond that matures at the end of the victim?s expected work life.

                      The discount rate should be adjusted to the rate available on short-term, tax-free investments, especially for those victims whose work life expectation is relatively short.

                      2.     Non-Economic Damages

                      Non-economic damages are presumed to be equal to $250,000 plus $50,000 for each of the victim?s spouse and dependents. Thus, the family of a financially dependent child merits the additional $50,000; the family of a child who was not financially dependent on the victim does not merit the additional amount. This is an astounding distinction when calculating non-economic damages. The dependent child deserves every consideration, certainly in excess of the parsimonious figures in the Presumed Economic and Non-Economic Tables. But more to the point here, why economic dependency is a factor in setting non-economic damages? It should not be.

                      I am not an orphaned child, but I was orphaned on September 11. I loved my father no less after I stopped needing his financial support, and he loved me the same way. The Tables? clear suggestion to the contrary is odious.

                      Sincerely,

                      Individual Comment
                      San Diego, CA

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