5. Results and Discussion

The goal of this analysis is to assess the incremental benefits and costs due to the adoption of the Department’s proposed regulations. A fundamental indicator of a publicly acceptable rule is one in which public benefits exceed public costs. The difference between benefits and costs quantified over the planning horizon lifecycle and discounted to the present represent a fundamental indicator of project worth. OMB Circular A-4 stipulates that this difference, the net present value (NPV), is to be regarded as a principal measure of value produced by a benefit-cost analysis when, as here, benefits and costs are separated from each other over time (i.e., when some people benefit from accessible facilities long after their construction). Further, Executive Order 12866 states that agencies should attempt to maximize the net benefits of their rulemakings, subject to statutory requirements. An NPV greater than zero indicates that benefits exceed costs and that the regulation can be expected to increase the general level of economic welfare accordingly. An NPV of less than zero could mean that costs exceed benefits. To further evaluate this latter scenario, the existence and magnitude of unmeasured and qualitative benefits may be assessed in a threshold analysis.

This chapter is divided into several sections. The first section explores, in some depth, the results of the primary baseline scenario (i.e., 1991 Standards, RA = 50% and SH applies). Benefits and costs are aggregated (and expressed in terms of NPV) to show the total incremental impact of the proposed standards with respect to: (a) all requirements collectively; (b) each new and revised requirement; (c) each type of facility; and (d) public versus private facilities. Some of the results are presented with risk-based probabilities and others as expected (i.e., most likely) values. In addition, graphical information is provided that shows the distribution of benefits and costs in the baseline scenario. (Additional and more detailed requirement-by-requirement and facility-by-facility results at the expected value for the primary baseline scenario are also provided in the separate Supplemental Results volume that accompanies this analysis.) These different summaries of results are intended to enable stakeholders to examine the regulatory analysis from their particular perspective.

The second section discusses how the total NPV changes under key alternate scenarios. These alternate scenarios are: safe harbor versus no safe harbor; barrier removal that is assumed to be readily achievable at varying percentages [0%, 50%, and 100%]; and alternate IBC baselines [IBC 2000, IBC 2003, and IBC 2006]. Due to the large number of scenarios, references to single scenarios use these abbreviations for safe harbor (SH), readily achievable barrier removal (RA) and baselines (SH, NSH; RA0, RA50, RA100; and, B1991, B2000, B2003, B2006) respectively. Results for each of these alternate scenarios are only presented as risk-based probabilities.

The third section presents stress analyses that assess the relative impact of varying several key selected assumptions individually. Stress analyses are presented for three different parameters: premium on access time; premium on use time; and, price elasticity of demand for facility use. In addition, to further explore the relative impact of parameter variability on results, this section also includes an assessment of the key drivers behind the risk ranges for the three requirements with the largest negative NPVs [Side Reach (Req. # 37), Water Closet Clearance in Single User Toilet Rooms -- In Swinging Doors (Req. #32), and Passenger Loading Zones (Medical/Long-Term Care) (Req. # 26)], as well as the three requirements with the largest positive NPVs [Passenger Loading Zones (Req. # 19), Accessible Route to Exercise Machines and Equipment (Req. # 70), and Transient Lodging Guest Room Vanities (Req. # 45)].

Lastly, to supplement the quantitative results presented in preceding sections, the fourth section discusses the unquantified benefits of the proposed regulations and their implication for model results. Many of the significant benefits conferred on persons with disabilities, businesses, and society generally by these proposed civil rights standards that implement the ADA defy quantification. Such benefits include: decreased administrative costs for businesses, architects, and state and local governments due to harmonization of the proposed ADA standards with model codes; increased social equity for persons with disabilities through better access to, and use of, public facilities; enhanced social and physical development of children with disabilities through improved access to play areas and other recreational facilities; and greater use of accessibility features by persons without disabilities (such as a parent using an accessible passenger loading zone at an airport to facilitate easier transport of a stroller and wheeled baggage). Given that the overall NPV for the proposed regulation is significantly positive for all scenarios at their respective expected values, such benefits -- even if quantifiable -- would only serve to underscore the overall conclusion that the regulations would promote the general economic welfare. However, for any individual requirement (or facility) with a negative NPV under any particular scenario, consideration of these unquantified benefits could well alter the benefit-cost calculus.

The results presented in this section are dependent to a greater or lesser extent on assumptions about facilities, requirements, and user benefits by persons with disabilities that were necessitated by lack of publicly available data or other published sources. Each of these assumptions is discussed in detail in Chapter 4. Some of these assumptions by HDR and the Department were based on the advice of experts and independent research; others are based on HDR’s current understanding of the interaction between facilities, requirements, and users. Because of the nature of this analysis, some of these assumptions may have a significant impact on the final results. While these assumptions reflect HDR’s current understanding, they would undoubtedly benefit from further outside review.

5.1 Results Under Primary Baseline Scenario

5.1.1 Total Net Present Value

The scenario considered in this section is characterized by assuming: 1991 Standards baseline, RA = 50% and SH applies. Recall from the earlier discussion that the percentage of elements that are RA represent those that undertake barrier removal. Those elements that are not RA would become compliant following an alterations schedule that tracks from the date that building was constructed. For all revised requirements, BR would apply only when SH is not granted. As such, these results represent costs and benefits from all new construction, all altered elements, and BR of newly regulated elements. It is also worth noting that when SH is not granted, BR becomes the dominant form of compliance with its relatively large cost burden on facilities.

Table 6 and Figure 7 present total NPV for a baseline scenario: Safe Harbor (SH), BR is readily achievable for 50% of elements (RA50) and the baseline standard is 1991 (B1991). Results for both the 3% and 7% discount rates are shown. Each cost curve is a joint distribution of all uncertainties in the model based on a simulation of over 1,000 Monte Carlo simulations.

Under the assumptions used to construct this analysis, these results suggest that the proposed regulations have a net positive public benefit. The numbers on the chart represent the 10th, 50th and 90th percentiles of the distribution. The range between the 10th and 90th percentiles represents an 80% confidence interval. This interval can be interpreted as having 80% confidence that the true NPV would be within this range. The most likely NPV is the median (50th) percentile (in the middle of this range).

Figure 7 presents total NPV summing all discounted costs and benefits for all facilities and requirements at the 3% and 7% discount rates. The 7% discount rate indicates that the 80% confidence interval ranges from $4.7 B to $11.0 B, with a median of $7.6 B. At 3%, this range ($23.2 to $40.6 B) is much wider and more skewed towards positive NPVs. These results indicate that NPV is unlikely to be less than zero. Table 6 indicates the total expected benefits and costs from users and facilities, respectively. Differences between the Total expected NPV in Table 6 ($7.5 B at the 7% discount rate) and the median NPV in Figure 7 ($7.6 B) are caused by the skewness of the distribution of NPVs.

Figure 7: Total NPV - Baseline Scenario: SH/RA50/B1991; 3% and 7% Discount Rates

Figure 7: Total NPV - Baseline Scenario: SH/RA50/B1991; 3% and 7% Discount Rates

 

Table 6: Total Net Present Value in Baseline Scenario at Expected Value (billions $)

(Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for baseline)

Discount Rate Expected NPV Total Expected
PV(Benefits)
Total Expected
PV(Costs)
3% $31.1 $53.9 -$22.8
7% $7.5 $19.5 -$11.9
 

5.1.2 Distribution of Costs and Benefits

Figure 8 and Figure 9 show the distributions of benefits and costs for the baseline case (SH and 7% discount rate). Time savings for users comprises over 90% of total benefits. Cost savings for facilities associated with less stringent requirements for NC and ALT projects is comparatively small, at about 9%. On the cost side, because this scenario involves SH, most of compliance costs use the ALT cost series. NC applies to only new facilities and BR only occurs for 50% of elements that are subject to requirements for the first time. Among other costs, O&M is larger than lost productive space and replacement costs. Costs to users in terms of lost time are also a significant component of cost.

Figure 8: Distribution of Benefits between Users and Facilities (Cost Savings)

Figure 8: Distribution of Benefits between Users and Facilities (Cost Savings)

Figure 9: Distribution of Costs between Type of Cost, Type of Construction, Users[1]

Figure 9: Distribution of Costs between Type of Cost, Type of Construction, Users

5.1.3 Net Present Value by Requirements

Figure 10 shows the NPV for selected requirements including shower spray controls (a revised, more stringent requirement), assisted listening devices (technical) (a revised, more stringent requirement with use value benefits) and accessible routes to bowling lanes (a supplemental requirement with new user benefits).

Figure 10: NPV for Selected Requirements

Figure 10: NPV for Selected Requirements

The table below details the costs, benefits and net benefits (or costs) for each requirement. The NPV refers to the net benefits less the net costs (numbers in parentheses are negative, and those an overall cost to society). The Net Impact to Users reflects the value of the benefits to users; less stringent requirements resulting in negative benefits to users are in parentheses. The column listing the Top 3 drivers of benefits list the facilities which generate the largest benefits for that requirement. Net Impact to Facilities lists the cost to facilities of compliance with the requirement; numbers in parentheses represent a cost to the facilities, number without parentheses represent effect savings due to less stringent requirements. Top three Drivers of Costs list those facilities in which the greatest costs for the requirement are generated.

Table 7 (which follows at the end of Section 5.1.4) deconstructs aggregated results by requirement. The columns in this table include:

Requirements with the largest positive and negative NPVs are also interesting cases to examine in detail (See additional volume of Supplemental Results for details):

5.1.4 Net Present Value by Facilities

Figure 11 shows the NPV for selected facilities, including inns, hotels, and motels.

Figure 11: NPV for Selected Facilities

Figure 11: NPV for Selected Facilities

Table 8 summarizes the results for all facilities at the baseline scenario. Facilities with the largest positive and negative NPVs are discussed below (Details regarding benefits and costs for each requirement in each facility type can be found in the Supplemental Results volume):

The table below details the costs, benefits and net benefits (or costs) for each requirement. The NPV refers to the net benefits less the net costs (numbers in parentheses are negative, and those an overall cost to society). The Net Impact to Users reflects the value of the benefits to users; less stringent requirements resulting in negative benefits to users are in parentheses. The column listing the Top 3 drivers of benefits list the facilities which generate the largest benefits for that requirement. Net Impact to Facilities lists the cost to facilities of compliance with the requirement; numbers in parentheses represent a cost to the facilities, number without parentheses represent effect savings due to less stringent requirements. Top three Drivers of Costs list those facilities in which the greatest costs for the requirement are generated.

Table 7: Costs and Benefits per Requirement in Baseline Scenario

Requirement NPV
(millions of $)
Net Impact
to Users
(millions of $)
Top 3 drivers of benefits Net Impact
to Facilities
(millions of $)
Top 3 drivers of costs
1-Public Entrances (22.08) (22.31) Shopping malls
Stadiums (public)
Stadiums
0.23 Shopping malls
Stadiums (public)
Stadiums
2-Maneuvering Clearance or Standby Power for Automatic Doors (0.38) 0.01 Nursing homes
Nursing homes (public)
Convention centers (public)
(0.40) Nursing homes
Nursing homes (public)
Convention centers (public)
3-Automatic Door Break-OutOpenings (3.25) 0.00 Motels
Hotels
Hospitals
(3.25) Hotels
Motels
Hospitals
4-Thresholds at Doorways 2.18 4.35 Motels
Hotels
Inns
(2.16) Public housing
Motels
Hotels
5-Door and Gate Surfaces (83.7) 2.73 Motels
Museums, historical sites & libraries (public)
Parks or zoos (public)
(86.42) Office buildings
Parks or zoos (public)
Office buildings (public)
9-Stairs (NC) 53.62 53.62 Motels
Museums, historical sites& libraries (public)
Undergraduate and postgraduate private schools
0.00  
10-Stairs (ALT/BR) (764.21) 18.26 Motels
Museums, historical sites & libraries (public)
Undergraduate and postgraduate private schools
(782.47) Office buildings
Offices of health care providers
Undergraduate, postgraduate public schools
11-Handrails Along Walkways 0.00 0.00   0.00  
12-Handrails 14.99 (24.83) Exercise facilities
Museums, historical sites& libraries (public)
Parking garages
39.82 Office buildings
Office buildings (public)
Undergraduate, postgraduate public schools
13-Accessible Routes from Site Arrival Points and Within Sites 9.89 (35.35) Parks or zoos (public)
Motels
Golf courses (private with public access)
45.23 Parks or zoos (public)
Motels
Terminal (private airports)
14-Standby Power for Platform Lifts (33.23) 0.00 Stadiums (public)
Stadiums
State and local judicial facilities (courthouses)
(33.23) State and local judicialfacilities (courthouses)
Stadiums (public)
Stadiums
15-Power-Operated Doors for Platform Lifts (24.74) 2.37 Stadiums (public)
Stadiums
State and local judicial facilities (courthouses)
(27.11) State and local judicial facilities (courthouses)
Stadiums (public)
Stadiums
16-Alterations to Existing Elevators (339.87) 2.53 Nursing homes
Undergraduate and postgraduate private schools
Hotels
(342.41) Office buildings
Office buildings (public)
State and local judicial facilities (courthouses)
19-Van Accessible Parking Spaces 52.6 59.87 Parks or zoos (public)
Amusement parks
Stadiums (public)
(7.27) Parks or zoos (public)
Terminal (private airports)
Undergraduate, postgraduate public schools
20-Valet Parking Garages (46.28) 175.22 Restaurants
Hotels
Theatre / Concert Hall
(221.5) Restaurants
Theatre / Concert Hall
Hotels
21-Mechanical Access Parking Garages 186.96 187.34 Parking garages
Parking garages (public)
(0.38) Parking garages
Parking garages (public)
22-Direct Access Entrances from Parking Structures 44.71 44.71 Shopping malls
Convention centers (public)
Convention centers
0.00  
23-Passenger Loading Zones 1,835.26 1,885.30 Restaurants
Shopping malls
Parks or zoos (public)
(50.03) Office buildings
Parks or zoos (public)
Restaurants
24-Parking Spaces 961.28 992.42 Restaurants
Museums, historical sites& libraries (public)
Parks or zoos (public)
(31.15) Office buildings
Restaurants
Parks or zoos (public)
25-Parking Spaces (Signs) (2.89) (3.27) Public housing 0.38 Public housing
26-Passenger Loading Zones(Medical / Long-Term Care) (489.01) (653.23) Nursing homes
Hospitals
Nursing homes (public)
164.22 Nursing homes
Hospitals
Nursing homes (public)
27-Ambulatory Accessible Toilet Compartments 442.06 497.81 Parks or zoos (public)
Undergraduate and postgraduate private schools
Exercise facilities
(55.76) Theatre / Concert Hall
Parks or zoos (public)
Shopping malls
28-Water closet clearance in single-user toilet rooms - out swinging door 189.66 2,364.31 Indoor Service Establishments
Undergraduate and postgraduate private schools
Parks or zoos (public)
(2,174.64) Indoor Service Establishments
Offices of health care providers
Nursing homes
29-Shower Spray Controls 144.3 207.18 Undergraduate and postgraduate private schools
Motels
Hotels
(62.88) Nursing homes
Undergraduate, postgraduate public schools
Parks or zoos (public)
30-Urinals (13.08) (13.08) Undergraduate and postgraduate private schools
Motels
Museums, historical sites & libraries (public)
0.00  
31-Multiple Single-User Toilet Rooms 135.34 (5.96) Offices of health care providers
Hospitals
Theatre / Concert Hall
141.3 Offices of health care providers
Theatre / Concert Hall
Hospitals
32-Water closet clearance in single-user toilet rooms - in swinging door (928.09) 46.28 Restaurants
Undergraduate and postgraduate private schools
Single level stores
(974.37) Single level stores
Restaurants
Elementary public schools
34-Patient Toilet Rooms (3.44) (5.4) Hospitals
Hospitals (public)
1.96 Hospitals
Hospitals (public)
35-Drinking Fountains (66.13) 0.37 Undergraduate and postgraduate private schools
Swimming pools / Aquatic centers
Swimming pools / Aquatic centers (public)
(66.5) Office buildings
Office buildings (public)
Swimming pools / Aquatic centers
37-Side Reach (970.6) 184.18 Indoor Service Establishments
Restaurants
Single level stores
(1,154.78) Indoor Service Establishments
Office buildings
Offices of health careproviders
38-Sales and Service Counters(NC) 31.42 (10.99) Restaurants
Museums, historical sites & libraries (public)
Indoor Service Establishments
42.41 Indoor Service Establishments
Single level stores
Parks or zoos (public)
39-Sales and Service Counters(Alt) (64) (239.6) Restaurants
Indoor Service Establishments
Single level stores
175.6 Indoor Service Establishments
Single level stores
Restaurants
40-Washing Machines and Clothes Dryers (technical) (6.43) 0.14 Undergraduate and postgraduate private schools
Public housing
Undergraduate, postgraduate public schools
(6.57) Public housing
Undergraduate, postgraduate public schools
Undergraduate and postgraduate private schools
41-Washing Machines and Clothes Dryers (Scoping) (1.93) 0.07 Undergraduate and postgraduate private schools
Public housing
Undergraduate, postgraduate public schools
(2.00) Public housing
Undergraduate, post graduate public schools
Undergraduate and postgraduate private schools
42-Self-Service Storage Access 17.08 19.78 Self service storage facilities (2.7) Self service storage facilities
45-Transient lodging Guest Room Vanities 1,071.48 1,093.72 Motels
Hotels
Inns
(22.24) Motels
Hotels
Inns
46-Operable Windows 169.56 204.66 Motels
Undergraduate and postgraduate private schools
Hotels
(35.11) Public housing
Undergraduate, post graduate public schools
Motels
47-Dwelling Units with Communication Features [1991] (13.00) 0.02 Public housing
(13.03) Public housing
48-Dwelling Units with Communication Features [UFAS] (3.47) 0.01 Public housing
(3.47) Public housing
49-Galley Kitchen Clearances 27.21 47.74 Undergraduate and postgraduate private schools
Public housing
Undergraduate, postgraduatepublic schools
(20.53) Undergraduate, postgraduate public schools
Public housing
Undergraduate and postgraduate private schools
50-Shower Compartments with Mobility Features 61.20 (12.38) Undergraduate and postgraduate private schools
Motels
Hotels
73.58 Nursing homes
Undergraduate, postgraduate public schools
Parks or zoos (public)
51-Location of Accessible Route to Stages (147.16) 0.16 Undergraduate and postgraduate private schools
Amusement parks
Secondary public schools
(147.32) Undergraduate, postgraduate public schools
Secondary public schools
Undergraduate and postgraduate private schools
52-Wheelchair Space Overlap in Assembly Areas (64.79) 498.06 Museums, historical sites & libraries (public)
Secondary public schools
Museums, historical sites & libraries
(562.85) Stadiums (public)
Motion Picture House
Theatre / Concert Hall
54-Handrails on Aisle Ramps in Assembly Areas (351.89) (400.95) Museums, historical sites& libraries (public)
Undergraduate and postgraduate private schools
Museums, historical sites& libraries
49.06 Parks or zoos (public)
Motion Picture House
Secondary public schools
55-Wheelchair Spaces in Assembly Areas 96.11 (5.82) Undergraduate and postgraduate private schools
Motion Picture House
Stadiums (public)
101.93 Stadiums (public)
Stadiums
Undergraduate, postgraduate public schools
56-Accessible Route to Tiered Dining Areas in Sports Facilities (NC) 5.6 (0.53) Stadiums (public)
Stadiums
6.13 Stadiums (public)
Stadiums
57-Accessible Route to Press Boxes 69.25 (1.48) Undergraduate and postgraduate private schools
Secondary public schools
Undergraduate, postgraduate public schools
70.74 Secondary public schools
Undergraduate and postgraduate private schools
Undergraduate, postgraduate public schools
58-Public TTYS (3.16) 0.02 Shopping malls
Convention centers (public)
Stadiums (public)
(3.17) State and local judicial facilities (courthouses)
Shopping malls
Terminal (private airports)
59-Public Telephone Volume Controls (7.78) 0.01 Nursing homes
Undergraduate and postgraduate private schools
Hotels
(7.8) State and local judicialfacilities (courthouses)
Hotels
Shopping malls
60-Two-Way Communication Systems at Entrances (5.45) 7.89 Motels
Public housing
(13.34) Public housing
Motels
61-ATMs and Fare Machines (14.42) 37.53 Indoor Service Establishments
Stadiums (public)
Stadiums
(51.95) Indoor Service Establishments
Stadiums (public)
Stadiums
62-Assistive Listening Systems(technical) (185.48) 1.24 Museums, historical sites & libraries (public)
Secondary public schools
Museums, historical sites & libraries
(186.72) Secondary public schools
Undergraduate, postgraduate public schools
Stadiums (public)
64-Detectable Warnings (scoping) 309.78 (71.87) Restaurants
Nursing homes
Museums, historical sites & libraries (public)
381.65 Indoor Service Establishments
Office buildings
Offices of health care providers
66-Assistive Listening Systems(scoping) 267.9 (7.03) Museums, historical sites & libraries (public)
Undergraduate and postgraduate private schools
Museums, historical sites & libraries
274.94 Stadiums (public)
Undergraduate, postgraduate public schools
Stadiums
68-Accessible Attorney Areas and Witness Stands (301.75) 0.01 State and local judicial facilities (courthouses) (301.76) State and local judicial facilities (courthouses)
70-Accessible Route to Exercise Machines and Equipment 1,100.40 1,115.75 Exercise facilities
Undergraduate and postgraduate private schools
Hotels
(15.35) Exercise facilities
Undergraduate and postgraduate private schools
Hotels
71-Accessible Machines and Equipment 841.53 1,181.17 Exercise facilities
Undergraduate and postgraduateprivate schools
Hotels
(339.64) Exercise facilities
Undergraduate and postgraduate private schools
Undergraduate, postgraduate public schools
73-Accessible Lockers 137.1 175.07 Exercise facilities
Undergraduate and postgraduate private schools
Swimming pools / Aquatic centers
(37.96) Exercise facilities
Swimming pools / Aquatic centers
Undergraduate and postgraduate private schools
74-Accessible Dressing Rooms, Fitting Rooms, or Locker Rooms 244.76 246.96 Undergraduate and postgraduate private schools
Secondary Private Schools
(2.2.0) Undergraduate and postgraduate private schools
Secondary Private Schools
75-Wheelchair Spaces in Team or Player Seating Areas (0.82) 0.01 Undergraduate and postgraduate private schools
Secondary Private Schools
(0.83) Undergraduate and postgraduate private schools
Secondary Private Schools
77-Accessible Route to Bowling Lanes 232.37 233.56 Bowling alleys (1.19) Bowling alleys
78-Shooting Facilities with Firing Positions 223.22 223.71 Shooting facilities (0.49) Shooting facilities
79-Accessible Means of Entry to Pools (NC/ALT) 104.51 393.53 Swimming pools / Aquatic centers
Undergraduate and postgraduate private schools
Motels
(289.03) Swimming pools / Aquatic centers
Motels
Hotels
80-Accessible Means of Entry to Wading Pools 179.04 867.78 Swimming pools / Aquatic centers
Swimming pools / Aquatic centers (public)
(688.74) Swimming pools / Aquatic centers
Swimming pools / Aquatic centers (public)
81-Accessible Means of Entry to Spas 598.52 779.37 Swimming pools / Aquatic centers
Undergraduate and postgraduate private schools
Nursing homes
(180.84) Nursing homes
Swimming pools / Aquatic centers
Hospitals
82-Accessible Route for Boating Facilities 2.48 10.28 Recreational boating facilities (public)
Recreational boating facilities
(7.79) Recreational boating facilities (public)
Recreational boating facilities
83-Accessible Boarding Piers(NC) 0.54 2.5 Recreational boating facilities (public)
Recreational boating facilities
(1.96) Recreational boating facilities (public)
Recreational boating facilities
85-Accessible Boat Slips (NC) (2.25) 9.42 Recreational boating facilities
Recreational boating facilities (public)
(11.68) Recreational boating facilities
Recreational boating facilities (public)
87-Accessible Route to Fishing Piers 31.98 32.3 Fishing piers and platforms
Fishing piers and platforms(public)
(0.32) Fishing piers and platforms
Fishing piers and platforms(public)
88-Accessible Fishing Piers and Platforms 57.51 66.43 Parks or zoos (public)
Fishing piers and platforms
Fishing piers and platforms(public)
(8.91) Parks or zoos (public)
Fishing piers and platforms
Parks or zoos
89-Accessible Route to Golf Courses 207.74 220.73 Golf courses (private with public access)
Golf courses (private only)
Golf courses (public)
(12.99) Golf courses (private with public access)
Golf courses (private only)
Golf courses (public)
90-Accessible Practice Grounds at Golf Courses (Alt/BR) (219.03) 162.36 Golf courses (private withpublic access)
Golf courses (private only)
Golf courses (public)
(381.39) Golf courses (private withpublic access)
Golf courses (private only)
Golf courses (public)
92-Accessible Practice Grounds at Driving Ranges 292.63 299.29 Golf courses (private withpublic access)
Golf courses (private only)
Golf courses (public)
(6.65) Golf courses (private withpublic access)
Golf courses (private only)
Golf courses (public)
93-Accessible Route to Minigolf Holes 241.42 257.93 Miniature golf courses
Miniature golf courses(public)
(16.52) Miniature golf courses
Miniature golf courses(public)
94-Accessible Minigolf Holes 179.9 243.92 Miniature golf courses
Miniature golf courses (public)
(64.02) Miniature golf courses
Miniature golf courses(public)
95-Accessible Route to Rides 441.25 503.57 Amusement parks
Amusement parks (public)
(62.31) Amusement parks
Amusement parks (public)
96-Wheelchair Space or Transfer Seat or Transfer Device 3.39 4.62 Amusement parks
Amusement parks (public)
(1.24) Amusement parks
Amusement parks (public)
97-Maneuvering Space in Load and Unload Area 12.25 15.33 Amusement parks
Amusement parks (public)
(3.08) Amusement parks
Amusement parks (public)
98-Signs at Amusement Parkrides 3.66 5.13 Amusement parks
Amusement parks (public)
(1.47) Amusement parks
Amusement parks (public)
99-Accessible Route to Play Components (BR) (13.54) 194.03 Elementary public schools
Parks or zoos (public)
Amusement parks
(207.58) Elementary public schools
Parks or zoos (public)
Elementary private schools
100-Accessible Play Components(BR) 259.11 294.94 Elementary public schools
Parks or zoos (public)
Amusement parks
(35.83) Elementary public schools
Parks or zoos (public)
Elementary private schools
101-Accessible Route to Play Components (ALT) 255.24 270.57 Restaurants
Shopping malls
Motels
(15.33) Restaurants
Parks or zoos (public)
Elementary public schools
102-Accessible Play Components(ALT) 398.56 402 Restaurants
Shopping malls
Motels
(3.43) Restaurants
Parks or zoos (public)
Nursery schools - Daycare
103-Accessible Route to Play Components (NC) (85.2) 84.07 Elementary public schools
Restaurants
Nursery schools - Daycare
(169.27) Elementary public schools
Nursery schools - Daycare
Elementary private schools
104-Accessible Play Components(NC) 111.29 126.17 Elementary public schools
Restaurants
Nursery schools - Daycare
(14.89) Elementary public schools
Nursery schools - Daycare
Elementary private schools
105-Open Captioning in Sports Stadium (0.53) 0.00 Stadiums (0.53) Stadiums (public)
Stadiums
106-Post Secondary School Multi-Story Dorm Facility (94.4) 0.48 Undergraduate, postgraduate public schools (94.87) Undergraduate, postgraduate public schools
109-Social Service Establishment (UFAS) 81.28 (24.34) Homeless Shelter
Homeless Shelter (public)
105.62 Homeless Shelter
Homeless Shelter (public)
110-Social Service Establishment (ADAAG) 51.18 54.56 Homeless Shelter
Homeless Shelter (public)
(3.38) Homeless Shelter
Homeless Shelter (public)
111-Accessible Saunas and Steam Rooms (ALT/BR) 344.39 553.05 Exercise facilities
Undergraduate andpostgraduate private schools
Swimming pools / Aquatic centers
(208.66) Exercise facilities
Undergraduate and postgraduate private schools
Swimming pools / Aquatic centers
112-Accessible Means of Entry to Pools (BR) 82.51 132.57 Undergraduate and postgraduate private schools
Swimming pools / Aquatic centers
Hotels
(50.07) Swimming pools / Aquaticcenters
Hotels
Undergraduate and postgraduate private schools

 

The table below details the costs, benefits and net benefits (or costs) to each facility type. The NPV refers to the net benefits less the net costs (numbers in parentheses are negative, and those an overall cost to society). The Net Impact to Users reflects the value of the benefits to users; less stringent requirements resulting in negative benefits to users are in parentheses. The column listing the Top 3 drivers of benefits list the requirement which generate the largest benefits at that facility. Net Facility Impact lists the cost to facilities of compliance with the requirement; numbers in parentheses represent a cost to the facilities, number without parentheses represent effect savings due to less stringent requirements. The Top three drivers of Impacts to Facilities lists the requirements with the largest impact on facility costs.

Table 8: Total Costs and Benefits per Facility Group in Baseline Scenario

Facility NPV
(millions of $)
Total User
Impact
(millions of $)
Top 3 drivers of impact to users Total Facility
Impact
(millions of $)
Top 3 drivers of impact to facilities
Inns 353.58 361.37 Transient lodging Guest Room Vanities
Water closet clearance in single-user toilet rooms - out swinging door
Operable Windows
(7.80) Water closet clearance in single-user toilet rooms - out swinging door
Side Reach
Transient lodging Guest Room Vanities
Hotels 594.05 764.62 Transient lodging Guest Room Vanities
Water closet clearance in single-user toilet rooms - out swinging door
Accessible Route to Exercise Machines and Equipment
(170.57) Accessible Means of Entry to Pools (NC/ALT)
Water closet clearance in single-user toilet rooms - out swinging door
Stairs (ALT/BR)
Motels 718.23 854.43 Transient lodging Guest Room Vanities
Water closet clearance in single-user toilet rooms - out swinging door
Operable Windows
(136.20) Accessible Means of Entry to Pools (NC/ALT)
Water closet clearance in single-user toilet rooms - out swinging door
Transient lodging Guest Room Vanities
Restaurants 2,296.62 2,738.47 Passenger Loading Zones
Parking Spaces
Accessible Play Components (ALT)
(441.85) Water closet clearance in single-user toilet rooms - in swinging door
Valet Parking Garages
Side Reach
Motion Picture House (114.02) 26.73 Wheelchair Space Overlap in Assembly Areas
Passenger Loading Zones
Parking Spaces
(140.75) Wheelchair Space Overlap in Assembly Areas
Assistive Listening Systems (technical)
Ambulatory Accessible Toilet Compartments
Theatre / Concert Hall (170.21) 26.53 Wheelchair Space Overlap in Assembly Areas
Water closet clearance in single-user toilet rooms - out swinging door
Ambulatory Accessible Toilet Compartments
(196.74) Wheelchair Space Overlap in Assembly Areas
Valet Parking Garages
Assistive Listening Systems (technical)
Stadiums 4.96 19.28 Passenger Loading Zones
Wheelchair Space Overlap in Assembly Areas
Accessible Saunas and Steam Rooms (ALT/BR)
(14.32) Wheelchair Space Overlap in Assembly Areas
Assistive Listening Systems (technical)
Water closet clearance in single-user toilet rooms - out swinging door
Auditoriums (3.61) 9.82 Passenger Loading Zones
Wheelchair Space Overlap in Assembly Areas
Ambulatory Accessible Toilet Compartments
(13.43) Wheelchair Space Overlap in Assembly Areas
Location of Accessible Route to Stages
Ambulatory Accessible Toilet Compartments
Convention centers 14.49 14.56 Passenger Loading Zones
Ambulatory Accessible Toilet Compartments
ATMs and Fare Machines
(0.07) Assistive Listening Systems (technical)
Location of Accessible Route to Stages
Water closet clearance in single-user toilet rooms - in swinging door
Single level stores (391.45) (2.90) Sales and Service Counters (Alt)
Sales and Service Counters (NC)
Urinals
(388.55) Water closet clearance in single-user toilet rooms - in swinging door
Side Reach
Door and Gate Surfaces
Shopping malls 307.28 341.00 Passenger Loading Zones
Ambulatory Accessible Toilet Compartments
Direct Access Entrances from Parking Structures
(33.72) Stairs (ALT/BR)
Ambulatory Accessible Toilet Compartments
Water closet clearance in single-user toilet rooms - in swinging door
Indoor Service Establishments (1,109.49) 524.84 Water closet clearance in single-user toilet rooms - out swinging door
Side Reach
ATMs and Fare Machines
(1,634.33) Water closet clearance in single-user toilet rooms - out swinging door
Side Reach
ATMs and Fare Machines
Offices of health care providers (222.72) 116.86 Water closet clearance in single-user toilet rooms - out swinging door
Side Reach
Stairs (NC)
(339.58) Water closet clearance in single-user toilet rooms - out swinging door
Stairs (ALT/BR)
Side Reach
Hospitals (29.56) (10.27) Passenger Loading Zones (Medical / Long-Term Care)
Patient Toilet Rooms
Multiple Single-User Toilet Rooms
(19.29) Accessible Means of Entry to Spas
Water closet clearance in single-user toilet rooms - out swinging door
Water closet clearance in single-user toilet rooms - in swinging door
Nursing homes (303.38) (188.68) Passenger Loading Zones (Medical / Long-Term Care)
Detectable Warnings (scoping)
Accessible Routes from Site Arrival Points and Within Sites
(114.70) Water closet clearance in single-user toilet rooms - out swinging door
Accessible Means of Entry to Spas
Side Reach
Terminal (private airports) 1.58 0.06 Direct Access Entrances from Parking Structures
Passenger Loading Zones
Water closet clearance in single-user toilet rooms - out swinging door
1.53 Accessible Routes from Site Arrival Points and Within Sites
Detectable Warnings (scoping)
Sales and Service Counters (NC)
Depots 0.06 0.05 Passenger Loading Zones
Water closet clearance in single-user toilet rooms - in swinging door
Door and Gate Surfaces
0.01 Detectable Warnings (scoping)
Handrails
Sales and Service Counters (NC)
Museums, historical sites & libraries 44.88 51.85 Wheelchair Space Overlap in Assembly Areas
Passenger Loading Zones
Parking Spaces
(6.97) Water closet clearance in single-user toilet rooms - in swinging door
Wheelchair Space Overlap in Assembly Areas
Assistive Listening Systems (technical)
Parks or zoos 45.50 48.27 Water closet clearance in single-user toilet rooms - out swinging door
Passenger Loading Zones
Accessible Play Components (BR)
(2.77) Accessible Route to Play Components (BR)
Water closet clearance in single-user toilet rooms - in swinging door
Accessible Fishing Piers and Platforms
Amusement parks 773.40 844.76 Accessible Route to Rides
Water closet clearance in single-user toilet rooms - out swinging door
Ambulatory Accessible Toilet Compartments
(71.36) Accessible Route to Rides
Maneuvering Space in Load and Unload Area
Location of Accessible Route to Stages
Nursery schools - Daycare (23.15) 84.15 Water closet clearance in single-user toilet rooms - out swinging door
Accessible Play Components (NC)
Accessible Route to Play Components (NC)
(107.30) Accessible Route to Play Components (NC)
Water closet clearance in single-user toilet rooms - out swinging door
Side Reach
Elementary private schools (33.10) 80.61 Accessible Play Components (BR)
Accessible Route to Play Components (BR)
Water closet clearance in single-user toilet rooms - out swinging door
(113.71) Accessible Route to Play Components (BR)
Accessible Route to Play Components (NC)
Water closet clearance in single-user toilet rooms - in swinging door
Secondary Private Schools (10.68) 9.72 Wheelchair Space Overlap in Assembly Areas
Water closet clearance in single-user toilet rooms - out swinging door
Ambulatory Accessible Toilet Compartments
(20.40) Location of Accessible Route to Stages
Accessible Lockers
Assistive Listening Systems (technical)
Undergraduate and postgraduate private schools 1,482.99 1,624.15 Accessible Dressing Rooms, Fitting Rooms, or Locker Rooms
Accessible Machines and Equipment
Accessible Route to Exercise Machines and Equipment
(141.16) Accessible Means of Entry to Pools (NC/ALT)
Location of Accessible Route to Stages
Accessible Machines and Equipment
Ski facilities 53.21 53.30 Water closet clearance in single-user toilet rooms - out swinging door
Passenger Loading Zones
Door and Gate Surfaces
(0.09) Water closet clearance in single-user toilet rooms - out swinging door
Door and Gate Surfaces
Passenger Loading Zones
Homeless Shelter 152.47 66.96 Social Service Establishment (ADAAG)
Water closet clearance in single-user toilet rooms - out swinging door
Shower Spray Controls
85.51 Social Service Establishment (UFAS)
Shower Compartments with Mobility Features
Detectable Warnings (scoping)
Food banks 13.25 14.36 Water closet clearance in single-user toilet rooms - out swinging door
Parking Spaces
Side Reach
(1.11) Water closet clearance in single-user toilet rooms - out swinging door
Side Reach
Parking Spaces
Social service establishments (31.04) 0.14 Side Reach
Water closet clearance in single-user toilet rooms - in swinging door
Door and Gate Surfaces
(31.18) Water closet clearance in single-user toilet rooms - in swinging door
Side Reach
Door and Gate Surfaces
Exercise facilities 1,790.96 2,315.14 Accessible Machines and Equipment
Accessible Route to Exercise Machines and Equipment
Accessible Saunas and Steam Rooms (ALT/BR)
(524.18) Accessible Machines and Equipment
Accessible Saunas and Steam Rooms (ALT/BR)
Accessible Lockers
Swimming pools / Aquatic centers 766.02 1,586.53 Accessible Means of Entry to Wading Pools
Accessible Means of Entry to Spas
Accessible Means of Entry to Pools (NC/ALT)
(820.51) Accessible Means of Entry to Wading Pools
Accessible Means of Entry to Pools (NC/ALT)
Accessible Means of Entry to Spas
Bowling alleys 234.83 236.40 Accessible Route to Bowling Lanes
Side Reach
Door and Gate Surfaces
(1.57) Accessible Route to Bowling Lanes
Side Reach
Door and Gate Surfaces
Golf courses (private with public access) 296.68 567.80 Accessible Practice Grounds at Driving Ranges
Accessible Route to Golf Courses
Accessible Practice Grounds at Golf Courses (Alt/BR)
(271.12) Accessible Practice Grounds at Golf Courses (Alt/BR)
Accessible Route to Golf Courses
Water closet clearance in single-user toilet rooms - in swinging door
Golf courses (private only) 87.83 222.87 Accessible Practice Grounds at Driving Ranges
Accessible Route to Golf Courses
Accessible Practice Grounds at Golf Courses (Alt/BR)
(135.04) Accessible Practice Grounds at Golf Courses (Alt/BR)
Water closet clearance in single-user toilet rooms - in swinging door
Accessible Route to Golf Courses
Miniature golf courses 401.84 485.14 Accessible Route to Minigolf Holes
Accessible Minigolf Holes
Side Reach
(83.30) Accessible Minigolf Holes
Accessible Route to Minigolf Holes
Water closet clearance in single-user toilet rooms - in swinging door
Recreational boating facilities (3.93) 11.38 Accessible Boat Slips (NC)
Accessible Route for Boating Facilities
Accessible Boarding Piers (NC)
(15.31) Accessible Boat Slips (NC)
Accessible Route for Boating Facilities
Water closet clearance in single-user toilet rooms - in swinging door
Fishing piers and platforms 45.23 48.44 Accessible Route to Fishing Piers
Accessible Fishing Piers and Platforms
(3.21) Accessible Fishing Piers and Platforms
Accessible Route to Fishing Piers
Shooting facilities 221.29 220.99 Shooting Facilities with Firing Positions
Door and Gate Surfaces
0.30 Accessible Routes from Site Arrival Points and Within Sites
Detectable Warnings (scoping)
Office buildings (1,036.79) 3.80 Passenger Loading Zones
Parking Spaces
Stairs (NC)
(1,040.59) Stairs (ALT/BR)
Alterations to Existing Elevators
Side Reach
Elementary public schools 53.97 332.79 Accessible Play Components (BR)
Water closet clearance in single-user toilet rooms - out swinging door
Accessible Route to Play Components (BR)
(278.82) Accessible Route to Play Components (BR)
Water closet clearance in single-user toilet rooms - in swinging door
Accessible Route to Play Components (NC)
Secondary public schools 161.26 296.93 Wheelchair Space Overlap in Assembly Areas
Water closet clearance in single-user toilet rooms - out swinging door
Ambulatory Accessible Toilet Compartments
(135.67) Assistive Listening Systems (technical)
Location of Accessible Route to Stages
Water closet clearance in single-user toilet rooms - in swinging door
Undergraduate, postgraduate public schools (228.83) 17.33 Water closet clearance in single-user toilet rooms - out swinging door
Accessible Machines and Equipment
Ambulatory Accessible Toilet Compartments
(246.16) Post Secondary School Multi-Story Dorm Facility
Location of Accessible Route to Stages
Stairs (ALT/BR)
Public housing (0.47) 168.54 Water closet clearance in single-user toilet rooms - out swinging door
Accessible Play Components (BR)
Accessible Route to Play Components (BR)
(169.01) Stairs (ALT/BR)
Accessible Route to Play Components (BR)
Operable Windows
State and local judicial facilities (courthouses) (516.95) 0.85 Water closet clearance in single-user toilet rooms - out swinging door
Passenger Loading Zones
Parking Spaces
(517.80) Accessible Attorney Areas and Witness Stands
Water closet clearance in single-user toilet rooms - out swinging door
Standby Power for Platform Lifts
State and local detention facilities (jails) (3.11) 0.02 Shower Spray Controls
Passenger Loading Zones
Parking Spaces
(3.14) Shower Spray Controls
Side Reach
Door and Gate Surfaces
State and local correctional facilities (prisons) (0.83) 3.60 Accessible Machines and Equipment
Shower Spray Controls
Passenger Loading Zones
(4.42) Stairs (ALT/BR)
Accessible Machines and Equipment
Shower Spray Controls
Parking garages 182.97 187.80 Mechanical Access Parking Garages
Stairs (NC)
Stairs (ALT/BR)
(4.83) Stairs (ALT/BR)
Mechanical Access Parking Garages
Self service storage facilities 15.11 19.50 Self-Service Storage Access
Stairs (NC)
Side Reach
(4.39) Self-Service Storage Access
Stairs (ALT/BR)
Alterations to Existing Elevators
Theatre / Concert Halls (public) (0.13) 0.03 Water closet clearance in single-user toilet rooms - out swinging door
Wheelchair Space Overlap in Assembly Areas
Ambulatory Accessible Toilet Compartments
(0.16) Wheelchair Space Overlap in Assembly Areas
Valet Parking Garages
Assistive Listening Systems (technical)
Stadiums (public) 12.42 50.37 Passenger Loading Zones
Wheelchair Space Overlap in Assembly Areas
ATMs and Fare Machines
(37.95) Wheelchair Space Overlap in Assembly Areas
Assistive Listening Systems (technical)
Water closet clearance in single-user toilet rooms - out swinging door
Auditoriums (public) 0.05 1.01 Passenger Loading Zones
Wheelchair Space Overlap in Assembly Areas
Ambulatory Accessible Toilet Compartments
(0.97) Wheelchair Space Overlap in Assembly Areas
Location of Accessible Route to Stages
Ambulatory Accessible Toilet Compartments
Convention centers (public) 21.73 21.84 Passenger Loading Zones
Ambulatory Accessible Toilet Compartments
ATMs and Fare Machines
(0.11) Assistive Listening Systems (technical)
Location of Accessible Route to Stages
Water closet clearance in single-user toilet rooms - in swinging door
Hospitals (public) (4.68) (4.02) Passenger Loading Zones (Medical / Long-Term Care)
Patient Toilet Rooms
Multiple Single-User Toilet Rooms
(0.66) Water closet clearance in single-user toilet rooms - out swinging door
Water closet clearance in single-user toilet rooms - in swinging door
Accessible Means of Entry to Spas
Nursing homes (public) (31.63) (26.93) Passenger Loading Zones (Medical / Long-Term Care)
Detectable Warnings (scoping)
Accessible Routes from Site Arrival Points and Within Sites
(4.70) Water closet clearance in single-user toilet rooms - out swinging door
Side Reach
Accessible Means of Entry to Spas
Museums, historical sites & libraries (public) 91.31 105.48 Wheelchair Space Overlap in Assembly Areas
Passenger Loading Zones
Parking Spaces
(14.17) Water closet clearance in single-user toilet rooms - in swinging door
Wheelchair Space Overlap in Assembly Areas
Assistive Listening Systems (technical)
Parks or zoos (public) 465.75 617.36 Water closet clearance in single-user toilet rooms - out swinging door
Passenger Loading Zones
Ambulatory Accessible Toilet Compartments
(151.61) Water closet clearance in single-user toilet rooms - in swinging door
Accessible Route to Play Components (BR)
Side Reach
Homeless Shelter (public) 22.78 10.01 Social Service Establishment (ADAAG)
Water closet clearance in single-user toilet rooms - out swinging door
Shower Spray Controls
12.78 Social Service Establishment (UFAS)
Shower Compartments with Mobility Features
Detectable Warnings (scoping)
Exercise facilities (public) 13.92 20.41 Accessible Machines and Equipment
Ambulatory Accessible Toilet Compartments
Accessible Lockers
(6.49) Accessible Machines and Equipment
Wheelchair Space Overlap in Assembly Areas
Side Reach
Social service establishments (public) (13.28) 0.06 Side Reach
Water closet clearance in single-user toilet rooms - in swinging door
Door and Gate Surfaces
(13.34) Water closet clearance in single-user toilet rooms - in swinging door
Side Reach
Door and Gate Surfaces
Swimming pools / Aquatic centers (public) 62.44 115.30 Accessible Means of Entry to Wading Pools
Accessible Means of Entry to Spas
Accessible Means of Entry to Pools (NC/ALT)
(52.87) Accessible Means of Entry to Wading Pools
Accessible Means of Entry to Pools (NC/ALT)
Accessible Means of Entry to Spas
Miniature golf courses (public) 15.03 16.88 Accessible Route to Minigolf Holes
Accessible Minigolf Holes
Side Reach
(1.84) Accessible Minigolf Holes
Water closet clearance in single-user toilet rooms - in swinging door
Accessible Route to Minigolf Holes
Recreational boating facilities (public) 0.94 10.62 Accessible Route for Boating Facilities
Accessible Boat Slips (NC)
Accessible Boarding Piers (NC)
(9.68) Accessible Route for Boating Facilities
Water closet clearance in single-user toilet rooms - in swinging door
Accessible Boat Slips (NC)
Fishing piers and platforms (public) 15.60 16.02 Accessible Route to Fishing Piers
Accessible Fishing Piers and Platforms
(0.42) Accessible Fishing Piers and Platforms
Accessible Route to Fishing Piers
Office buildings (public) (93.02) 12.54 Passenger Loading Zones
Parking Spaces
Stairs (NC)
(105.56) Stairs (ALT/BR)
Alterations to Existing Elevators
Side Reach
Parking garages (public) 1.64 1.68 Mechanical Access Parking Garages
Stairs (NC)
Stairs (ALT/BR)
(0.04) Stairs (ALT/BR)
Mechanical Access Parking Garages
Golf courses (public) 45.94 60.86 Water closet clearance in single-user toilet rooms - out swinging door
Accessible Route to Golf Courses
Accessible Practice Grounds at Driving Ranges
(14.92) Accessible Practice Grounds at Golf Courses (Alt/BR)
Water closet clearance in single-user toilet rooms - in swinging door
Side Reach
Restaurants (public) 0.07 0.09 Passenger Loading Zones
Parking Spaces
Accessible Play Components (ALT)
(0.02) Water closet clearance in single-user toilet rooms - in swinging door
Valet Parking Garages
Side Reach
Amusement parks (public) 33.65 34.20 Accessible Route to Rides
Water closet clearance in single-user toilet rooms - out swinging door
Ambulatory Accessible Toilet Compartments
(0.54) Accessible Route to Rides
Location of Accessible Route to Stages
Wheelchair Space or Transfer Seat or Transfer Device

 

5.1.5 Net Present Value for Public versus Private Facilities

Figure 12 shows the NPV for public and privately owned elementary and postgraduate schools. The results show a large discrepancy between public and private undergraduate and postgraduate schools. This result reflects how public facilities are not subject to the readily achievable barrier removal requirement. In this comparison, the supplemental requirements for exercise equipment are not costed for undergraduate and postgraduate public schools.

Figure 12: NPV for Selected Facilities with Public and Private

Figure 12: NPV for Selected Facilities with Public and Private

Table 9 presents the NPV for all private and all public facilities analyzed. While the total NPV is positive for both sets of groups, the NPV for private facilities ($7.4 B) is significantly higher than that for public facilities ($126 M). This is primarily due to the fact that there are significantly more private than public establishments.

The private facilities with the largest (positive or negative) NPV are Restaurants ($2.3 B), Exercise Facilities ($1.8 B), Undergraduate and Postgraduate Private Schools ($1.5 B) and Indoor Service Establishments (-$1.1 B). The public facility with the greatest benefits is Parks and zoos, with a positive NPV of $0.5 B. The public facility with the largest negative NPV is State and local Judicial Facilities (-$0.5 B).

Table 9: Net Present Value for Public and Private Facilities

Facility Group Private Facility Code NPV Private
Facilities  ($ mil)
Impact to
Private
Facilities
Public Facility Code NPV Public
Facility ($ mil)
Impact to
Public
Facilities
Inns A 353.58 (7.80) No public counterpart    
Hotels B 594.05 (170.57) No public counterpart    
Motels C 718.23 (136.20) No public counterpart    
Restaurants D 2296.62 (441.85) BP 0.07 (0.02)
Motion Picture House E (114.02) (140.75) No public counterpart    
Theatre / Concert Hall F (170.21) (196.74) AW (0.13) (0.16)
Stadiums G 4.96 (14.32) AX 12.42 (37.95)
Auditoriums H (3.61) (13.43) AY 0.05 (0.97)
Convention centers I 14.49 (0.07) AZ 21.73 (0.11)
Single level stores J (391.45) (388.55) No public counterpart    
Shopping malls K 307.28 (33.72) No public counterpart    
Indoor Service Establishments L (1109.49) (1634.33) No public counterpart    
Offices of health care providers M (222.72) (339.58) No public counterpart    
Hospitals N (29.56) (19.29) BB (4.68) (0.66)
Nursing homes O (303.38) (114.70) BC (31.63) (4.70)
Terminal (private airports) P 1.58 1.53 No public counterpart    
Depots Q 0.06 0.01 No public counterpart    
Museums, historical sites & libraries R 44.88 (6.97) BD 91.31 (14.17)
Parks or zoos S 45.50 (2.77) BE 465.75 (151.61)
Amusement parks T 773.40 (71.36) BQ 33.65 (0.54)
Nursery schools - Daycare U (23.15) (107.30) No public counterpart    
Elementary schools V (33.10) (113.71) AN 53.97 (278.82)
Secondary Schools W (10.68) (20.40) AO 161.26 (135.67)
Undergraduate and postgraduate schools X 1482.99 (141.16) AP (228.83) (246.16)
Ski facilities Y 53.21 (0.09) No public counterpart    
Homeless Shelter Z 152.47 85.51 BF 22.78 12.78
Food banks AA 13.25 85.51 No public counterpart    
Social service establishments AB (31.04) (31.18) BH (13.28) (13.34)
Exercise facilities AC 1790.96 (524.18) BG 13.92 (6.49)
Aquatic centers / swimming pools AD 766.02 (820.51) BI 62.44 (52.87)
Bowling alleys AE 234.83 (1.57) No public counterpart    
Golf courses (private with public access) AF 296.68 (271.12) No public counterpart    
Golf courses AG 87.83 (135.04) BO 45.94 (14.92)
Miniature golf courses AH 401.84 (83.30) BJ 15.03 (1.84)
Recreational boating facilities AI (3.93) (15.31) BK 0.94 (9.68)
Fishing piers and platforms AJ 45.23 (3.21) BL 15.60 (0.42)
Shooting facilities AK 221.29 0.30 No public counterpart    
Office buildings AM (1036.79) (1040.59) BM (93.02) (105.56)
Public housing No public counterpart     AQ (0.47) (169.01)
State and local judicial facilities (courthouses) No public counterpart     AR (516.95) (517.80)
State and local detention facilities (jails) No public counterpart     AS (3.11) (3.14)
State and local correctional facilities (prisons) No public counterpart     AT (0.83) (4.42)
Parking garages AU 182.97 (4.83) BN 1.64 (0.04)
Self service storage facilities AV 15.11 (4.39) No public counterpart    

 

5.2 Results Under Additional Scenarios

This section discusses a few of the scenarios that are analyzed in this report. The scenarios are discussed in comparison with one or more other scenarios given a common basis. For review, the scenarios modeled in this analysis include: safe harbor (SH) and no safe harbor (NSH) for existing facilities compliant under the 1991 Standards; barrier removal that would be readily achievable in either 0%, 50%, or 100% of situations (RA0, RA50, and RA100); and alternate baselines using either the 1991 Standards or recent IBC editions (B1991, and B2000, B2003, and B2006)[4].

Results under safe harbor (SH) versus no safe harbor (NSH) are discussed assuming that 50% of barrier removal is readily achievable (RA50) and with the 1991 Standards as the baseline (B1991). In addition, results for RA0, and RA100 also assume SH and B1991. Alternative baselines for B1991, and the various IBC editions (B2000, B2003, and B2006) all assume SH and RA100.

5.2.1Safe Harbor and No Safe Harbor Scenarios

The following graphs (Figure 13, Figure 14, and Figure 15) show the NPV results for other scenarios. Figure 13 compares SH and NSH policies (both assuming RA50 and 1991 Standards). The difference in NPV is significant. Without SH, benefits are most likely to exceed costs by about $3.3 B whereas with SH, benefits exceed costs by over $7.6 B. Part of the explanation for this discrepancy is that under NSH, BR costs are applied to more stringent requirements and the level of benefits for many element’s barrier removal are lower than costs. The larger costs are then magnified because of the larger numbers of facilities that would be required to undertake BR before the next rule-making occurs.

Figure 13: NPV Comparison -- Safe Harbor Policy: SH/RA50/ B1991 , NSH/RA50/ B1991

Figure 13</A>: NPV Comparison -- Safe Harbor Policy: SH/RA50/ B1991 , NSH/RA50/ B1991

5.2.2 Readily Achievable Scenarios

Figure 14 provides an assessment of how NPV changes with different readily achievable assumptions. There is little variation among the three RA scenarios (RA0, RA50, and RA100): One of the reasons that the results of the RA scenarios do not vary significantly under safe harbor is that there are three offsetting effects working simultaneously. The first effect that pushes costs up is a higher barrier removal cost due to a higher number of elements subject to new requirements undergoing barrier removal. The second effect reduces costs because a higher RA% implies fewer alterations on elements subject to new requirements. Finally, the third effect increases the benefits as the RA% increases, because the rate of completion of elements related to new requirements is higher, and so are the benefits derived from them (benefits can be shown to increase at a decreasing rate). The combination of these three effects keeps the RA curves close to one another.

Figure 14: NPV Comparison -- Alternate Readily Achievable %: SH/ RA0, RA50, RA100/ B1991

Figure 14: NPV Comparison -- Alternate Readily Achievable %: SH/ RA0, RA50, RA100/ B1991

5.2.3International Building Code (IBC) Scenarios

Figure 15 represents differences in NPV for different baselines, including the various IBC editions (B2000, B2003, and B2006). These probability curves indicate that the effect of changing the set of requirements that apply. The results indicate that B2000 (IBC 2000) has the highest NPV and B2006 (IBC 2006) has the lowest and B1991 is less than B2003 (IBC 2003). These results are due to changes in the make-up of the set of requirements that are included in each alternative baseline.

The alternative baselines for the different IBC fluctuate as various requirements, some with positive NPVs and some with negative NPVs, are included under the various IBC years. The NPV using the 2000 IBC as a baseline is highest of the four, and well above that for the 1991 Standards as twelve elements are no longer costed. This difference is primarily driven by the fact that the Side Reach requirement is already under the 2000 IBC and its NPV is not included. Using the 2003 IBC as a baseline, the NPV is still higher than under the 1991 Standards as a baseline, but lower than the 2000 IBC. This is largely due to the fact that Passenger Loading Zones are covered under the 2003 IBC and are thus no longer included, though it is counterbalanced by the fact that Accessible Attorney Areas and Witness Stands) and Location of Accessible Routes to are also no longer included. The total NPV using the 2006 IBC is lowest of all the scenarios (though not by much), as Transient Lodging Guest Room Vanities and Water Closet Clearances with Out-Swinging Doors are no longer included under this scenario.

Figure 15: NPV Comparison -- Alternate Baselines: SH/RA100/ B1991, B2000, B2003, B2006

Figure 15: NPV Comparison -- Alternate Baselines: SH/RA100/ B1991, B2000, B2003, B2006

As discussed previously in Section 2.4.3, it was not feasible to construct alternate IBC baselines for each requirement and facility nationwide that took into account actual IBC adoption by state and local jurisdictions. Nonetheless, to further assist stakeholders in assessing the impact of the proposed regulations, several more limited assessments were conducted that compared four illustrative proposed requirements against requirement-specific alternate IBC/ANSI baselines based on current IBC adoption by states and local jurisdictions nationwide. The results of these analyses demonstrate that consideration of requirement-specific alternate IBC/ANSI baselines on a requirement-by-requirement basis would likely lead to markedly lower incremental costs (and benefits) for many requirements.

Table 10 presents total comparative costs, benefits, and NPV for two illustrative proposed requirements when using either the primary baseline (1991 Standards) or a requirement-specific alternate IBC baseline. The two illustrative requirements -- barrier removal and alteration requirements for existing stairs (RIA Req. #10) and alterations requirements for existing elevators (RIA Req. # 16) -- were selected because they both appear in the "main" chapters of the IBC for which adoption is near universal. It is estimated that 95.63% of facilities nationwide are currently covered by IBC provisions that mirror these two proposed requirements for existing stairs and elevators. Thus, for purposes of these alternate IBC baselines, the expected values for costs and benefits were scaled by this same percentage. Using this methodology, the likely costs for these two requirements falls from $1.1 billion using the 1991 Standards as a baseline to $49 million using requirement-specific alternate IBC baselines.

Table 10: Costs, Benefits and NPV Comparison using Primary (1991 Standards) Baseline and Requirement-Specific Alternate IBC Baseline -- Req. # 10 and 16

1991 Standards Baseline ($ millions)
Requirement Impact to Users (Benefits) Impact to Facilities (Costs) * NPV
10-Stairs (ALT/BR) 18.3 (782.5) (764.2)
16-Alterations to Existing Elevators 2.5 (342.4) (339.9)
Sum 20.8 (1,124.9) (1,104.1)

Alternate IBC Baseline ($ millions)
Requirement Impact to Users (Benefits) Impact to Facilities (Costs) * NPV
10-Stairs (ALT/BR) 0.8 (34.1) (33.3)
16-Alterations to Existing Elevators 0.1 (14.9) (14.8)
Sum 0.9 (49.0) (48.1)
* Negative numbers in these columns are a cost to facilities.

Table 11 presents total costs, benefits, and NPV for two other illustrative proposed requirements using the same comparative baselines. This second set of illustrative proposed requirements -- water closet clearance requirements in single-user toilet rooms with in-swinging doors (RIA Req. # 32) and side reach requirements (RIA Req. # 37) -- were selected because they both appear in Chapter 11 of the IBC (through incorporation by reference of ANSI A117.1) which has been less widely adopted than some other IBC chapters. Nonetheless, it is still estimated that 31.03% of facilities nationwide are currently covered by IBC/ANSI A117.1 provisions that mirror these two proposed requirements for water closet clearances and side reach. Likely costs and benefits were thus scaled in a manner similar to that described above. Using this methodology, the likely costs for this second set of illustrative proposed requirements falls from $2.1 billion using the 1991 Standards as a baseline to $1.5 billion using requirement-specific alternate IBC/ANSI baselines.

Table 11: Costs, Benefits and NPV Comparison Using Primary (1991 Standards) Baseline and Requirement-Specific Alternate IBC/ANSI Baselines -- Req # 32 and 37

1991 Standards Baseline ($ millions)
Requirement Impact to Users (Benefits) Impact to Facilities (Costs) * NPV
32-Water closet clearance in single-user toilet rooms - in swinging door 46.3 (974.4) (928.1)
37-Side Reach 184.2 (1,154.8) (970.6)
Sum 230.5 (2,129.2) (1,898.7)

Alternate IBC/ANSI A117.1 Baseline ($ millions)
Requirement Impact to Users (Benefits) Impact to Facilities (Costs) * NPV
32-Water closet clearance in single-user toilet rooms - in swinging door 31.9 (672.0) (640.1)
37-Side Reach 127.0 (796.4) (669.4)
Sum 158.9 (1,468.4) (1,309.5)
* Negative numbers in these columns are a cost to facilities.

 

5.3 Relative Impact of Selected Assumptions

As noted in sections 3.4 and 4.3, this regulatory impact analysis incorporates risk analysis to understand the potential impact on results of the uncertainty surrounding assumptions and some data estimates. The results presented in preceding sections illustrate how parameters of uncertainties translate into variability of NPVs.

An additional assessment of impact of parameter values explores the change in benefits from alternate assumptions. The change in benefits is assessed at expected value. This approach of assessing impact is not a sensitivity analysis in which viable values are assessed, justified in economic literature. Instead, this approach is a stress analysis to asses the impact in results from a hypothetical change in one parameter. The approach is conducted for three variables: the premium on access time, the premium on use time, and the price elasticity of demand for facility visits.

The access time premium is defined in the model to range from 0.75 to 1.25 percent of the value of time. (The median of the range is 1.) This stress analysis assesses the impact on reducing the premium to 0.5. In other words, the access time change is valued at 50% of the base VOT.

The results below are for the complete list of requirements. Some requirements have no data since, in the baseline scenario, they were not costed (see Table 4). Reducing the premium used for access time by half (i.e. using an access premium of .5 instead of 1) reduces the benefits to users by that factor. Lowering the premium by one half reduces total net benefits to users from $16.3 billion to $10.7 billion, or 34%.[5]

Table 12: Impact on Results of Reduced to Access Time Premium

Requirement (millions of dollars) Baseline Scenario
Premium=1
Impact to Users
(Benefits and Costs)
Impact of Reduced
Premium On Net
Benefits to Users
Premium=.5
Impact to Users
(Benefits and Costs)
Public Entrances         (22.3)              (11.1)
Maneuvering Clearance or Standby Power for Automatic Doors             0.0                  0.0
Automatic Door Break-Out Openings             0.0                  0.0
Thresholds at Doorways             4.3                  2.1
Door and Gate Surfaces             2.7                  1.6
Location of Accessible Routes               -                      -  
Common Use Circulation Paths in Employee Work Areas               -                      -  
Accessible Means of Egress               -                      -  
Stairs (NC)           53.6                26.6
Stairs (ALT/BR)           18.3                  9.1
Handrails Along Walkways               -                      -  
Handrails         (24.8)              (14.2)
Accessible Routes from Site Arrival Points and Within Sites         (35.3)              (24.5)
Standby Power for Platform Lifts             0.0                  0.0
Power-Operated Doors for Platform Lifts             2.4                  1.2
Alterations to Existing Elevators             2.5                  1.3
Platform Lifts in Hotel Guest Rooms and Dwelling Units               -                      -  
“LULA” and Private Residence Elevators               -                      -  
Van Accessible Parking Spaces           59.9                35.9
Valet Parking Garages         175.2                87.4
Mechanical Access Parking Garages         187.3                91.8
Direct Access Entrances from Parking Structures           44.7                22.3
Passenger Loading Zones      1,885.3              968.7
Parking Spaces         992.4              500.4
Parking Spaces (Signs)           (3.3)                (1.6)
Passenger Loading Zones (Medical / Long-Term Care)       (653.2)            (326.8)
Ambulatory Accessible Toilet Compartments         497.9              322.8
Water closet clearance in single-user toilet rooms - out swinging door      2,364.4           1,398.0
Shower Spray Controls         207.2              152.1
Urinals           (13.1)                  (9.3)
Multiple Single-User Toilet Rooms           (6.0)                (3.0)
Water closet clearance in single-user toilet rooms - in swinging door           46.3                28.5
Water Closet Location and Rear Grab Bar               -                      -  
Patient Toilet Rooms           (5.4)                (2.7)
Drinking Fountains             0.4                  0.2
Sinks               -                      -  
Side Reach         184.2                99.8
Sales and Service Counters (NC)         (11.0)                (5.6)
Sales and Service Counters (Alt)       (239.6)            (120.1)
Washing Machines and Clothes Dryers (technical)             0.1                  0.1
Washing Machines and Clothes Dryers (Scoping)             0.1                  0.0
Self-Service Storage Access           19.8                  9.9
Limited Access Spaces and Machinery Spaces               -                      -  
Operable Parts               -                      -  
Transient lodging Guest Room Vanities      1,093.7              623.3
Operable Windows         204.7              102.2
Dwelling Units with Communication Features [1991]             0.0                  0.0
Dwelling Units with Communication Features [UFAS]             0.0                  0.0
Galley Kitchen Clearances           47.7                38.0
Shower Compartments with Mobility Features             (12.4)                  (11.0)
Location of Accessible Route to Stages             0.2                  0.1
Wheelchair Space Overlap in Assembly Areas         498.1              474.3
Lawn Seating in Assembly Areas               -                      -  
Handrails on Aisle Ramps in Assembly Areas       (400.9)            (200.8)
Wheelchair Spaces in Assembly Areas           (5.8)                (2.9)
Accessible Route to Tiered Dining Areas in Sports Facilities (NC)           (0.5)                (0.3)
Accessible Route to Press Boxes           (1.5)                (0.7)
Public TTYS             0.0                  0.0
Public Telephone Volume Controls             0.0                  0.0
Two-Way Communication Systems at Entrances             7.9                  3.9
ATMs and Fare Machines           37.5                18.8
Assistive Listening Systems (technical)             1.2                  1.2
Visible Alarms in Alterations to Existing Facilities               -                      -  
Detectable Warnings (scoping)         (71.9)              (35.9)
Detectable Warnings (technical)               -                      -  
Assistive Listening Systems (scoping)           (7.0)                (3.5)
Accessible Courtroom Stations               -                      -  
Accessible Attorney Areas and Witness Stands             0.0                  0.0
Raised Courtroom Stations Not for Members of the Public               -                      -  
Accessible Route to Exercise Machines and Equipment      1,115.9              809.6
Accessible Machines and Equipment      1,181.3              866.1
Accessible Saunas and Steam Rooms (NC)               -                      -  
Accessible Lockers         175.1              127.0
Accessible Dressing Rooms, Fitting Rooms, or Locker Rooms         247.1              122.8
Wheelchair Spaces in Team or Player Seating Areas             0.0                  0.0
Accessible Route in Court Sport Facilities               -                      -  
Accessible Route to Bowling Lanes         233.6              221.9
Shooting Facilities with Firing Positions         223.7              218.1
Accessible Means of Entry to Pools (NC/ALT)         393.6              241.3
Accessible Means of Entry to Wading Pools         867.8              584.3
Accessible Means of Entry to Spas         779.5              470.2
Accessible Route for Boating Facilities           10.3                  8.4
Accessible Boarding Piers (NC)             2.5                  2.0
Accessible Boarding Piers (ALT/BR)               -                      -  
Accessible Boat Slips (NC)             9.4                  7.7
Accessible Boat Slips (Alt/BR)               -                      -  
Accessible Route to Fishing Piers           32.3                31.4
Accessible Fishing Piers and Platforms           66.4                55.5
Accessible Route to Golf Courses         220.7              198.8
Accessible Practice Grounds at Golf Courses (Alt/BR)         162.4              146.2
Accessible Practice Grounds at Golf Courses (NC)               -                      -  
Accessible Practice Grounds at Driving Ranges         299.3              269.5
Accessible Route to Minigolf Holes         257.9              211.6
Accessible Minigolf Holes         243.9              200.6
Accessible Route to Rides         503.6              417.6
Wheelchair Space or Transfer Seat or Transfer Device             4.6                  3.5
Maneuvering Space in Load and Unload Area           15.3                11.5
Signs at Amusement Park rides             5.1                  3.9
Accessible Route to Play Components (BR)         194.0              116.0
Accessible Play Components (BR)         294.9              179.2
Accessible Route to Play Components (ALT)         270.6              136.2
Accessible Play Components (ALT)         402.0              202.6
Accessible Route to Play Components (NC)           84.1                46.1
Accessible Play Components (NC)         126.2                69.8
Open Captioning in Sports Stadium             0.0                  0.0
Post Secondary School Multi-Story Dorm Facility 0.5 0.2
Mobility Accessible Prison Cell               -                      -  
Communication Accessible Prison Cell               -                      -  
Social Service Establishment (UFAS)         (24.3)              (12.1)
Social Service Establishment (ADAAG)           54.6                27.2
Accessible Saunas and Steam Rooms (ALT/BR)         553.1              404.8
Accessible Means of Entry to Pools (BR)         132.6                73.5
Total for Entire Rule 16,264.7 10,720.2

 

The use time premium is defined in the benefits model to range from 0.2 to 0.5 the base VOT (with the median use time premium at 0.35 the base VOT). This stress analysis examines the impact on reducing the median use time to 0.175. The results are shown below for the requirements with use value only. Reducing the premium used for use time by a half (i.e. using a use time premium of .175 instead of .35) lowers total net benefits to users[6] from $16.3 billion to $16.0 billion, or 2%.

Table 13: Impact on Results of Reduced to Use Time Premium

Requirement (millions of dollars) Impact to Users
Baseline
Use Value = .35
Impact to Users
Alternate Use
Value = .175
Ambulatory Accessible Toilet Compartments 497.86 489.93
Water closet clearance in single-user toilet rooms - out swinging door 2,364.39 2,308.18
Shower Spray Controls 207.18 160.14
Urinals -13.09 -10.48
Multiple Single-User Toilet Rooms -5.96 -5.96
Water closet clearance in single-user toilet rooms - in swinging door 46.28 42.70
Transient lodging Guest Room Vanities 1,093.72 1,013.12
Shower Compartments with Mobility Features -12.38 -8.13
Wheelchair Space Overlap in Assembly Areas 498.06 396.24
Assistive Listening Systems(technical) 1.24 0.94
Accessible Machines and Equipment 1,181.32 1,167.83
Accessible Fishing Piers and Platforms 66.43 64.19
Accessible Minigolf Holes 243.92 243.06
Accessible Play Components (BR) 294.94 292.83
Accessible Play Components (ALT) 402.00 401.85
Accessible Play Components (NC) 126.17 125.75
Total for Entire Rule 16,264.7 15,940.5

 

The last stress analysis assesses the impact of reducing the price elasticity of demand for each facility. This analysis shows the overall minor impact the slope of the demand curve (which is derived, in part, from the elasticity) has on the change in consumer surplus. Reducing the elasticities by a half (meaning that each reducing in price leads to a smaller change in demand) reduces net benefits to users from $16.3 billion to $13.2 billion. The elasticity impacts only new uses of a facility and the new users of a newly independent accessible facility (e.g. aquatic centers / swimming pools). The facilities with a significant change in user benefits when the elasticity is reduced are the facilities with expected new users, brought about by the supplemental requirements.

Table 14: Impact on Results of Reduced Demand Elasticity At All Facilities

Facility Group Facility Index Results Using Literature Elasticities Impact to Users Results Using Literature Elasticities NPV Results Using Elasticity Estimates Reduced by Half Impact to Users Results Using Elasticity Estimates Reduced by Half NPV Difference In Benefits
$
Difference In Benefits
%
Inns A 361.37 353.58 359.58 351.78 (1.8) -0.5%
Hotels B 764.62 594.05 761.52 590.95 (3.1) -0.4%
Motels C 854.43 718.23 845.26 709.06 (9.2) -1.1%
Restaurants D 2,738.47 2,296.62 2,732.40 2,290.55 (6.1) -0.2%
Motion Picture House E 26.73 (114.02) 26.66 (114.09) (0.1) -0.3%
Theatre / Concert Hall F 26.53 (170.21) 26.51 (170.23) (0.0) -0.1%
Stadiums G 19.28 4.96 19.26 4.94 (0.0) -0.1%
Auditoriums H 9.82 (3.61) 9.81 (3.62) (0.0) -0.1%
Convention centers I 14.56 14.49 14.53 14.45 (0.0) -0.2%
Single level stores J (2.90) (391.45) (2.90) (391.45) 0.0 0.0%
Shopping malls K 341.00 307.28 340.47 306.75 (0.5) -0.2%
Indoor Service Establishments L 524.84 (1,109.49) 524.80 (1,109.52) (0.0) 0.0%
Offices of health care providers M 116.86 (222.72) 116.86 (222.72) 0.0 0.0%
Hospitals N (10.27) (29.56) (10.27) (29.56) 0.0 0.0%
Nursing homes O (188.68) (303.38) (188.79) (303.49) (0.1) 0.1%
Terminal (private airports) P 0.06 1.58 0.06 1.58 0.0 0.0%
Depots Q 0.05 0.06 0.05 0.06 0.0 0.0%
Museums, historical sites & libraries R 51.85 44.88 51.59 44.63 (0.3) -0.5%
Parks or zoos S 48.27 45.50 36.57 33.80 (11.7) -32.0%
Amusement parks T 844.76 773.40 537.02 770.43 (307.7) -57.3%
Nursery schools - Daycare U 84.15 (23.15) 84.08 (23.22) (0.1) -0.1%
Elementary private schools V 80.61 (33.10) 80.46 (33.25) (0.2) -0.2%
Secondary Private Schools W 9.72 (10.68) 9.72 (10.69) 0.0 0.0%
Undergraduate and postgraduate private schools X 1,624.15 1,482.99 1,615.61 1,474.45 (8.5) -0.5%
Ski facilities Y 53.30 53.21 28.21 53.21 (25.1) -88.9%
Homeless Shelter Z 66.96 152.47 66.83 152.34 (0.1) -0.2%
Food banks AA 14.36 13.25 14.34 13.23 (0.0) -0.1%
Social service establishments AB 0.14 (31.04) 0.14 (31.04) 0.0 0.0%
Exercise facilities AC 2,315.14 1,790.96 1,368.39 844.22 (946.8) -69.2%
Aquatic centers / swimming pools AD 1,586.53 766.02 967.77 695.29 (618.8) -63.9%
Bowling alleys AE 236.40 234.83 124.53 122.96 (111.9) -89.8%
Golf courses (private with public access) AF 567.80 296.68 319.40 294.77 (248.4) -77.8%
Golf courses (private only) AG 222.87 87.83 125.60 48.42 (97.3) -77.4%
Miniature golf courses AH 485.14 401.84 276.71 310.89 (208.4) -75.3%
Recreational boating facilities AI 11.38 (3.93) 7.41 (7.90) (4.0) -53.6%
Fishing piers and platforms AJ 48.44 45.23 25.17 34.01 (23.3) -92.5%
Shooting facilities AK 220.99 221.29 112.69 215.12 (108.3) -96.1%
Office buildings AM 3.80 (1,036.79) 3.79 (1,036.80) (0.0) -0.3%
Elementary public schools AN 332.79 53.97 332.44 53.62 (0.4) -0.1%
Secondary public schools AO 296.93 161.26 296.83 161.16 (0.1) 0.0%
Undergraduate, postgraduate public schools AP 17.33 (228.83) 17.19 (228.97) (0.1) -0.8%
Public housing AQ 168.54 (0.47) 162.05 (6.95) (6.5) -4.0%
State and local judicial facilities (courthouses) AR 0.85 (516.95) 0.85 (516.95) 0.0 0.0%
State and local detention facilities (jails) AS 0.02 (3.11) 0.02 (3.11) 0.0 0.0%
State and local correctional facilities (prisons) AT 3.60 (0.83) 3.60 (0.83) 0.0 0.0%
Parking garages AU 187.80 182.97 184.02 179.19 (3.8) -2.1%
Self service storage facilities AV 19.50 15.11 19.42 15.03 (0.1) -0.4%
Theatre / Concert Halls (public) AW 0.03 (0.13) 0.03 (0.13) 0.0 0.0%
Stadiums (public) AX 50.37 12.42 50.33 12.38 (0.0) -0.1%
Auditoriums (public) AY 1.01 0.05 1.01 0.05 0.0 0.0%
Convention centers (public) AZ 21.84 21.73 21.79 21.68 (0.1) -0.2%
Hospitals (public) BB (4.02) (4.68) (4.02) (4.68) 0.0 0.0%
Nursing homes (public) BC (26.93) (31.63) (26.95) (31.65) (0.0) 0.1%
Museums, historical sites & libraries (public) BD 105.48 91.31 104.96 90.79 (0.5) -0.5%
Parks or zoos (public) BE 617.36 465.75 453.67 302.06 (163.7) -36.1%
Homeless Shelter (public) BF 10.01 22.78 9.99 22.76 (0.0) -0.2%
Exercise facilities (public) BG 20.41 13.92 11.98 5.49 (8.4) -70.4%
Social service establishments (public) BH 0.06 (13.28) 0.06 (13.28) 0.0 0.0%
Aquatic centers / swimming pools (public) BI 115.30 62.44 69.16 58.69 (46.1) -66.7%
Miniature golf courses (public) BJ 16.88 15.03 9.62 11.87 (7.3) -75.5%
Recreational boating facilities (public) BK 10.62 0.94 6.92 (2.76) (3.7) -53.5%
Fishing piers and platforms (public) BL 16.02 15.60 8.33 11.89 (7.7) -92.3%
Office buildings (public) BM 12.54 (93.02) 12.49 (93.08) (0.0) -0.4%
Parking garages (public) BN 1.68 1.64 1.65 1.61 (0.0) -1.8%
Golf courses (public) BO 60.86 45.94 34.20 45.74 (26.7) -78.0%
Restaurants (public) BP 0.09 0.07 0.09 0.07 0.0 0.0%
Amusement parks (public) BQ 34.20 33.65 17.97 17.61 (16.2) -90.3%
Total   16,264.7 7,541.8 13,231.5 5,999.6 (3,033.2) -22.9%

The three requirements with the largest positive NPVs and the three requirements with the largest negative NPVs can be characterized as key drivers of the overall costs and benefits to the Rule. The following figures present the driving factors behind the risk range for the NPV estimates for each of these requirements. Each graph indicates the level of risk attributable to each variable. Those factors that explain the largest portion of the risk are the ones that will have the largest impact on the overall NPV.

Top Negative Requirements (NPV $ millions)

The Side Reach requirement has one of the largest negative NPVs (-$970.6 million at the median) among the nearly one hundred requirements in the proposed Rule. Figure 16 illustrates the relative impact of various assumptions on the side reach NPV. The unit cost estimates for alterations are a significant driver for this requirement, and substantially greater than the impact from other assumptions. Unit costs for side reach under alterations can vary greatly, from $0 to $1,500 and with a median estimate of $150.

Figure 16: Distribution of Sensitivities for Requirement 37: Side Reach. NPV = -$970.6

Figure 16: Distribution of Sensitivities for Requirement 37: Side Reach. NPV = -$970.6

Figure 17 illustrates the relative impact of various assumptions on the Water closet clearance in single user toilet rooms -- in swinging doors NPV. The range of estimates (incorporated to account for uncertainty regarding the actual figure) on the likelihood of occurrence are the most significant drivers for the range of results for the requirement’s NPV. The range of alterations costs has the next most significant impact on the NPV range. The frequency of occurrence at single-level stores is the third most important driver of the NPV range, since there are a large number of single-level stores.

Figure 17: Distribution of Sensitivities for Requirement 32: Water closet clearance in single user toilet rooms -- in swinging doors. NPV = -928.1

Figure 17: Distribution of Sensitivities for Requirement 32: Water closet clearance in single user toilet rooms -- in swinging doors. NPV = -928.1

Figure 18 illustrates the relative impact of various assumptions on the Passenger Loading Zones (Medical / Long-Term Care) NPV. The range of estimates (incorporated to account for uncertainty regarding the actual figure) on access time saved is the most significant drivers for the range of results for the requirement’s NPV, followed closely by the frequency of use of the element.

Figure 18: Distribution of Sensitivities for Requirement 26: Passenger Loading Zones (Medical / Long-Term Care). NPV = -489.0

Figure 18: Distribution of Sensitivities for Requirement 26: Passenger Loading Zones (Medical / Long-Term Care). NPV = -489.0

Top Positive Requirements (NPV $ millions)

Figure 19 illustrates the relative impact of various assumptions on the Passenger Loading Zones NPV. The range of estimates (incorporated to account for uncertainty regarding the actual figure) on likelihood that a user would experience benefits is the most significant driver on the requirement’s NPV range, followed by the range of estimates around the likelihood that the element occurs and around the frequency of using the element.

Figure 19: Distribution of Sensitivities for Requirement 23: Passenger Loading Zones. NPV = 1,835.3

Figure 19: Distribution of Sensitivities for Requirement 23: Passenger Loading Zones. NPV = 1,835.3

Figure 20 illustrates the relative impact of various assumptions for the Accessible Route to Exercise Machines and Equipment NPV. The range of estimates on likelihood that a user would experience benefits is the most significant driver on the requirement’s NPV range, followed by range of estimates for the frequency of using the element and around the access time savings.

Figure 20: Distribution of Sensitivities for Requirement 70: Accessible Route to Exercise Machines and Equipment. NPV = 1,100.4

Figure 20: Distribution of Sensitivities for Requirement 70: Accessible Route to Exercise Machines and Equipment. NPV = 1,100.4

Figure 21 illustrates the relative impact of various assumptions on the Transient lodging Guest Room Vanities NPV. The range of estimates on access time savings is the most significant driver on the requirement’s NPV range, followed by the range of estimates around the frequency of its use at motels, at hotels, and at inns.

Figure 21: Distribution of Sensitivities for Requirement 45: Transient lodging Guest Room Vanities. NPV = 1,071.5

Figure 21: Distribution of Sensitivities for Requirement 45: Transient lodging Guest Room Vanities. NPV = 1,071.5

The range of estimates modeled for several factors appear repeatedly as key drivers behind many of the requirements with the largest positive and negative NPV:

Likelihood that an element occurs,

Likelihood of benefiting from a requirement,

Frequency of use, and

Access time.

The two likelihood factors have standard rules to apply ranges around the point estimate in most cases (see Appendix 3F, 3G, and 4M). The frequency of use and access time estimates were developed based upon responses from the RAP Benefits Panel. These differ from the unit costs estimates ranges, which were developed separately at high, medium, and low for each requirement (and at new construction, alterations, and barrier removal).

Unquantified Benefits -- Option and Existence Values

In addition to the monetized benefits presented above, there are numerous other benefits that are likely to result from the proposed standards. Many of these benefits cannot be quantified, let alone monetized.[7] These benefits include: harmonized guidelines; increased business opportunities; increased social development; improved health benefits; higher social equity levels; user benefits for people without disabilities; and benefits to employees. Other qualitative benefits that are important, but unaccounted for, in the user benefits include option (or insurance) value and existence value. The option value is the value that people with and without disabilities derive from the opportunity to obtain the benefit of accessible facilities. The existence value is the value that people both with and without disabilities derive from the guarantees of equal protection and non-discrimination that are accorded through the provision of accessible facilities.

Other Unquantifiable Benefits

Substantial effort was taken in the development of the guidelines upon which the proposed standards will be based to ensure that they would be consistent with model codes such as the IBC 2003. This harmonization of other model codes with the ADA Standards will yield substantial benefits to businesses, architects, and State and local governments, in addition to the benefits generated for people with disabilities. The proposed standards represent essentially one set of requirements which eliminates confusion and unintentional failure to meet standards. It also reduces administrative costs associated with determining the exact requirements. The proposed standards will also make it easier for State and local codes to be certified as meeting or exceeding Federal standards.

Evidence supports the notion of children both with and without disabilities benefiting from interaction with one another.[8] Therefore, there will undoubtedly be social development benefits generated by an increase in accessible play areas. However, these are nearly impossible to quantify for several reasons. One, there is no guarantee that accessibility will generate play opportunities between children with and without disabilities. Two, there may be substantial overlap between other opportunities for these two groups to interact, such as schools and religious facilities. Three, it is not even certain what the unit of measurement for social development should be.

Increased access to play areas (for children) and recreational facilities such as gyms (for adults) can also provide improved health benefits.[9] Although, again, there may be an overlap with other opportunities for exercise,[10] this makes the actual impact of the new requirements difficult to quantify.

In addition, the proposed standards will substantially increase social equity, particularly for newly scoped facilities like play areas, recreational facilities, and judicial, detention and correctional facilities. Methods of measuring existence value attempt to measure some portion of this benefit, but only that portion of increased equity that is valued by non-users.

Finally, there is clearly a use benefit that individuals without disabilities get from certain accessibility features. Curb cuts in sidewalks make life easier for those using wheeled suitcases and backpacks or pushing a baby stroller. For people with a lot of baggage or a need to change clothes, the larger bathroom stalls can be a highly valued commodity. It is not just persons with disabilities who derive use value from accessibility features.

Employees with disabilities will also benefit from the proposed standards. Employees of the establishments in compliance with the proposed standards will experience greater accessibility when doing their work. The benefits an employee experiences in an accessible workplace are realized through the same changes in access time that are experienced by non-employee users. Employees perceive the time change as enabling more work to be done with greater ease. Increased efficiency is valuable to employees looking for advancement and valuable to employers who benefit from more productive workers. However, measuring benefits to employees with disabilities is difficult, in large part because there is little to no data on the number of employees with disabilities per facility group or establishment type, which would be necessary to generate the benefits per employee per facility.

From all this it can be determined that, in some cases, benefits may be underestimated. However, it is also possible to overestimate benefits. For example, consider a city block that already contains two facilities with play areas. Under the proposed standards, a new facility with a play area must make itself accessible even at an increased construction cost. The cost will be the same as for any other play area undergoing construction, but the benefit is likely to be lower given that play area demand for that area is likely already being well filled. This is impossible to take into account in a model that is designed to abstract away from these sorts of details. However, the possibility that benefits will actually fall short of median levels is taken into account using risk analysis.

Non-User Benefits: Insurance Value

Just because an individual is a non-user of accessible elements today, does not mean that he or she will remain so tomorrow. In any given year, there is some probability of an individual developing a disability (either temporary or permanent) that will necessitate use of these features. Therefore, even individuals who have no direct use for accessibility features today get a direct benefit from the knowledge of their existence should they need them in the future. This is like an insurance policy against any future disability -- hence the term insurance value or insurance benefit.

Non-User Benefits: Existence Value

As the name suggests, existence value is the benefit that individuals get from the mere existence of a good, service or resource -- in this case, accessibility. Unlike user value and insurance value, existence value does not require an individual to ever use the resource or even plan on using the resource in the future. There can be numerous reasons why individuals might value accessibility even if they do not require it now and do not ever anticipate needing it in the future. These include: bequest motives, benevolence toward relatives and/or friends who require accessibility features,[11] and general feelings of empathy and responsibility toward individuals with disabilities.

Bequest values -- the wish to leave accessible features to future generations -- do not seem appropriate in the present context. For something like a natural resource that has an infinite lifecycle (barring natural disaster or society’s failure to preserve it), bequest values make sense. For structural changes made to facilities that may last up to forty years, but which might change again in more or less time, bequests make less sense. Even in buildings that comply fully with the proposed standards, it is unclear whether they will stand long enough to accumulate substantial bequest valuations.

Empathy and/or feelings of responsibility are closely related to another unquantified benefit -- social equity. Clearly this is a real phenomenon, as so many individuals without disabilities have worked toward the adoption of both the current and the proposed standards. However, it is difficult to measure and even more difficult to separate from other existence value benefits, like altruism which risks double-counting.[12]

Existence values run into an additional problem, in that even with appropriate surveys, users tend to carry over their use values into their evaluation of existence values. This makes the existence valuations of users and nonusers inconsistent with one another.[13] What remains are estimates of willingness-to-pay. One method which can be employed is to evaluate how much nonusers of one resource are willing to pay to use another similar resource. This option does not appear to be available in the case of accessibility features, however. As with altruism, the literature relies on surveys to estimate the actual willingness-to-pay values.

Relation to Model Results

Given that the range of possible NPV values for the entire rule is unlikely to be less than zero (see Section 5.1), the foregoing discussion of unquantified benefits has greatest potential impact on those particular requirements with negative NPVs. If requirements and their impacts can be considered separately, those with negative monetized NPVs will warrant closer evaluation. For these requirements, the actual total overall value to society includes the non-monetized benefits discussed above, and the true NPV for each is some value greater than the figure presented here.




[1] The costs to users are the increases in time that would result from less stringent requirements.

[2] New construction was modeled separately from alterations and barrier removal due to differences in other underlying assumptions.

[3] New construction, alterations, and barrier removal were all modeled separately in order to adequately take into account the impact of program access for public facilities and the exemptions provided to small playgrounds.

[4] See section 4.2.1 for a discussion of safe harbor and section 2.4.3 for a discussion of the relationship between the 1991 Standards and recent IBC editions.

[5] This $16.3 billion is not the same as the estimate for Total Expected Benefits in Table 5, because the latter includes any benefits to facilities from any less stringent requirements and does not net out the costs to users from less stringent requirements.

[6] Ibid.

[7] Many of these benefits were discussed in the Access Board’s various regulatory assessments.

[8] The United States Architectural and Transportation Barriers Compliance Board, Final Accessibility Guidelines For Play Areas: Economic Assessment (October 2000), contains references supporting this. A copy is located at: http://www.access-board.gov/play/assess.htm.

[9] The United States Architectural And Transportation Barriers Compliance Board, Assessment of Benefits and Costs of Final Accessibility Guidelines for Recreation Facilities (September 2002), contains references supporting this. A copy is located at: http://www.access-board.gov/recreation/reg-assessment.htm.

[10] Although clearly there will be fewer alternatives absent the proposed standards.

[11] This is different from altruism, because altruism assumes no direct connection between the altruist and the recipient of the benefit. Altruism is a concept closely related to existence value, although it can be present among users and non-users alike. The Office of Budget and Management (OMB) rejects the notion of general altruism because it impacts costs and benefits equally (See OMB Circular A-4). In other words, the concern for the welfare of others would be present for users as well as industries. Since there is no reason to expect selective altruism in the ADA context, this type of altruism can be ignored in the analysis of existence value. Much of the material on altruism comes from McConnell, "Does Altruism Undermine Existence Value?" Journal of Environmental Economics and Management 32 (1997): 22-37.

[12] See, for example, Lazo, McClelland, and Schulze. "Economic Theory and Psychology of Non-Use Values." Land Economics 73, No. 3 (August, 1997): 358-371.

[13] Silberman, Gerlowski, and Williams. "Estimating Existence Value for Users and Nonusers of New Jersey Beaches." Land Economics 68, no. 2 (May, 1992): 225-236.

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last updated December 9, 2010