Adam M. Samaha


How does government value people's time? Often the valuation is implicit, even mysterious. But in patches of the federal administrative state, paperwork burdens are quantified in hours and often monetized. When agencies do monetize, they look to how the labor market values the time of the people faced with paperwork. The result is that some people's time is valued over ten times more than other people's time. In contrast, when agencies monetize the value of statistical life for cost-benefit analysis, they look to how people faced with a risk of death subjectively value its reduction. In practice, agencies assign the same value to every statistical life saved by a given policy.

This Article establishes these patterns of agency behavior and suggests that there is no satisfying justification for them. Welfarist and egalitarian principles, along with the logic of statistical life valuation, lean against the use of market wages to monetize a person's time doing government paperwork. The impact of this practice might be limited, given the modest ambition of today's paperwork reduction efforts. But time-related burdens—and benefits—are key consequences of government decisions in countless contexts. If we want to scale up a thoughtful process for valuing people's time in the future, we will need new foundations.

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