6. Results and Discussion

The goal of this analysis is to assess the incremental benefits and costs due to the adoption of the Department's Final Rules. 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 (Section 6.1) 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 Final Rules 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 (Section 6.2) discusses how the total NPV changes under key alternate scenarios. These alternate scenarios are: safe barrier removal that is assumed to be readily achievable at varying percentages [0%, 50%, and 100%]; alternate IBC baselines [IBC 2000, IBC 2003, and IBC 2006]; and harbor versus no safe harbor. 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; 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 (Section 6.3) presents two sets of sensitivity-style analyses that assess the relative impact of varying several key selected assumptions individually. The first set of stress analyses evaluates how altering inputs for six parameters in the model would affect results for all requirements, facility groups, or overall NPV. To further explore the relative impact of parameter variability on results, this section also includes a second set of analyses that examines the key drivers behind the risk ranges for the three requirements with the largest negative NPVs [Water Closet Clearance in Single User Toilet Rooms – In Swinging Doors (Req. #32), Stairs (ALT/BR) (Req.#10) and Water Closet Clearance in Single User Toilet Rooms – Out Swinging Doors (Req. #28),], as well as the three requirements with the largest positive NPVs [Bathrooms in Accessible Guest Rooms (vanities and water closet clearances) (Req. #45), Passenger Loading Zones (Req. #23), and Accessible Exercise Machines and Equipment (Req. #71)].

Lastly, to supplement the quantitative results presented in preceding sections, the fourth section (Section 6.4) discusses the benefits not included in the main estimation of the Final Rules and their implication for model results. Many of the significant benefits conferred on persons with disabilities, businesses, and society generally by these revised 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 these revised 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 Final Rules 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 benefits not included in the main estimation 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.

6.1 Results Under Primary Baseline Scenario

6.1.1 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 if SH was not to be granted; BR would become the dominant form of compliance with its relatively large cost burden on facilities.[1]

Table 6 and Figure 8 present total NPV for the primary 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 3,000 Monte Carlo simulations.

Under the assumptions used to construct this analysis, these results suggest that the Final Rules 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 8 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 $6.2 B to $12.7 B, with a median of $9.3 B. At 3%, this range ($31.5 B to $50.7 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.

Figure 8: Total NPV – Primary Baseline Scenario: SH/RA50/B1991; 3% and 7% Discount Rates

Figure 8: Total NPV – Primary Baseline Scenario: SH/RA50/B1991; 3% and 7% Discount Rates

 

Table 6: Total Net Present Value in Primary 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% $40.4 $66.2 $25.8
7% $9.3 $22.0 $12.8

Figure 9 presents total NPV separately for private and public facilities respectively at the expected value under the primary baseline (i.e., assuming Safe Harbor (SH) applies, BR is readily achievable for 50% of elements (RA50), and the baseline standard is 1991 (B1991)). Results using both the 3% and 7% discount rates are shown. Each cost curve is a joint distribution of all uncertainties in the model based on results from over 3,000 Monte Carlo simulations. The NPV for private facilities is notably higher under a 3% discount rate, as compared to a 7% discount rate, but the NPV for such facilities under either discount rate nonetheless is still higher than the NPV for public facilities irrespective of the discount rate used due the larger number of facilities and users affected. The smallest NPV is at the expected value is for public facilities at the 7% discount rate ($0.6 B), but is still likely to be positive.

Figure 9: Total NPV – Primary Baseline Scenario: SH/RA50/B1991; 3% and 7% Discount Rates for Private and Public Facilities Separately

Figure 9: Total NPV – Primary Baseline Scenario: SH/RA50/B1991; 3% and 7% Discount Rates for Private and Public Facilities Separately

6.1.2 Distribution of Costs and Benefits

Figure 10 and Figure 11 show the distributions of benefits and costs for the baseline case (SH and 7% discount rate). Time savings for users comprises 93% of total benefits. Cost savings for facilities associated with less stringent requirements for NC and ALT projects is comparatively small, at about 7%. 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, those due to lost productive space are larger than O&M and replacement costs. Costs to users in terms of lost time due to less stringent requirements are also a significant component of cost.

Figure 10: Distribution of Benefits between Users and Facilities (Cost Savings) (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Figure 10: Distribution of Benefits between Users and Facilities (Cost Savings)

Figure 11: Distribution of Costs between Type of Cost, Type of Construction, Users[2] (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Figure 11: Distribution of Costs between Type of Cost, Type of Construction, Users

6.1.3 Net Present Values by Requirement

Figure 12 shows the NPV for three illustrative requirements with different cost and/or benefit profiles: Shower Spray Controls (Req. #29) (a revised, more stringent requirement); Assisted Listening Systems (technical) (Req. # 62) (a revised, more stringent requirement with use value benefits); and, Accessible Routes to Bowling Lanes (Req. # 77) (a supplemental requirement with new user benefits).

Figure 12: NPV for Three Selected Requirements (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Figure 12: NPV for Three Selected Requirements

Table 7 (which follows at the end of Section 6.1.4) deconstructs aggregated results by requirement. The columns in this table include:

  • NPV.
  • Net impact to users (as the total monetized change in access time).
  • Top 3 facilities that increase the magnitude of user benefits. For less stringent requirements, these facilities have the largest negative benefits, i.e. costs, to users. The opposite is true for more stringent requirements.
  • Net impact to facilities (as the sum of increased and reduced costs across all elements).
  • Top 3 facilities which have the highest magnitude of requirement costs (with the same implication on type of requirement as benefits).

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

  • 45. Bathrooms in Accessible Guest Rooms (vanities and water closet clearances): the high positive NPV ($1.79 B) for this requirement is due to high users benefits ($1.95 B) and low costs to facilities ($159 M). Benefits from this requirement are substantial because of the time savings, plus an increase in use value – the quality of the experience in bathroom at a facility in which the comfort of the bathroom is a key determinant of the facility's demand – at hotels, inns, and motels. Being able to use the bathroom comfortably, safely, or independently due to greater accessibility enhances the experience relating to the primary purpose of staying at the hotel (defined as shelter, a bed and use of a bathroom).
  • 70. Accessible Routes to Exercise Machines and 71. Accessible Exercise Machines and Equipment: New access to exercise facilities also drives high NPVs ($968 M and $1.4 B, respectively). Benefits from these requirements are substantial because of the time savings, as well as the enhanced quality of use. Because these requirements now ensure independent access to the facilities' primary use, a large increase in new users is expected. Costs to facilities for the Accessible Route to Exercise Machines requirement are fairly low ($20.3 M), but costs to facilities for the Accessible Exercise Machines and Equipment requirement are higher ($492 M), and benefits follow a similar pattern ($988M for Accessible Routes to Exercise Machines, and $1.9 B for Accessible Exercise Machines and Equipment).
  • 23. Passenger Loading Zones: Similar to the NPV for the requirement for Bathrooms in Accessible Guest Rooms (including vanities and water closet clearances), the high positive NPV ($1.29 B) for this requirement is due to high users benefits ($1.34 B) and low costs to facilities ($49 M). The large benefits are driven primarily by a large number of users of restaurants overall and a fair number of users at malls. In each case, the time savings are due to waiting for access to the loading zone, which could be occupied by persons with or without disabilities. Since costs for facilities are relatively insignificant, the NPV is driven by benefits. The most probable likelihood that a loading zone is present at these facilities (10%) and the most probable likelihood that a visitor with disabilities would be waiting (5%) scale down the costs and benefits.
  • 100, 102, 104. Accessible Play Components:[3] The NPV for the Accessible Play Components requirements collectively (i.e., new construction, alterations, and barrier removal), totals $657 M. This is due to large users benefits ($720 M) and moderate costs to facilities. The benefits and costs for public schools are moderate due to existing program access requirements which already have made a large number of existing school playgrounds accessible.
  • 32. Water Closet Clearance in Single-user Toilet Rooms with In-swinging doors: The large negative NPV (-$975 M) for this requirement is due to relatively small monetized benefits to users ($42 M) but large costs to facilities ($1 B). Over 90% of the total cost comes from capital construction costs for alterations; unit costs under new construction are less than a tenth of unit costs under alterations ($200 versus $3,100, respectively at the median level).
  • 9, 10. Stairs:[4] Stairs under new construction (Req. # 9) has a small positive NPV of $52.5M, but it is minimal when paired with the large negative NPV (-$808 M) for stairs under alterations (Req. # 10). The benefits for this requirement under alterations are moderate in size ($20 M) when compared to other requirements but the costs to facilities are high ($828 M) due to high unit costs ($7,500 per flight at the median level).
  • 28. Water Closet Clearance in Single-user Toilet Rooms with Out-Swinging Doors: This requirement posts the largest cost to facilities ($2.5 B). And while benefits are also high ($1.6 B) they are less than costs, leading to a relatively negative NPV (-$898 M)
  • 37. Side Reach: The large negative NPV (-$555 M) is driven by the ubiquitous nature of this element and a relatively small monetized benefit per use compared with capital cost. Total benefits to users are $715 M while the cost to facilities is $1.3 B. The facility group with the largest side reach costs is Indoor Service Establishments, which is also the facility type with the largest number of establishments (more than 3 million).

6.1.4 Net Present Values by Facility

Figure 13 shows the NPV for shows the NPV for three illustrative selected facility groups: Inns; Hotels; and, Motels to illustrate how the NPV can vary even for similar facilities.

Figure 13: NPV for Three Selected Facility Groups (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Figure 13: NPV for Three Selected Facility Groups

Table 8 summarizes the results for all facilities at the primary 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):

  • Exercise Facilities: Very high user impacts ($2.5 B) combined with facility costs of $684 M lead to a high NPV of $1.8 B. Benefits are generated from both access time and use time for Accessible Exercise Machines and Equipment. In addition, the relatively low costs for Accessible Saunas and Steam Rooms further elevate the facilities' overall NPV.
  • Undergraduate and Post-Graduate Private Schools: The large NPV of $1.5 B is due to substantial benefits of $1.6 B while costs total $152 M. These large benefits are due to moderately high benefits for several requirements, including Water Closet Clearance in Single-User Toilet Rooms with Out-Swinging Doors, Accessible Routes to Exercise Machines, Accessible Exercise Machines and Equipment, and Accessible Dressing Rooms, Fitting Rooms, or Locker Rooms.
  • Motels: The large NPV for this facility of $1.4 B is due to relatively low costs of $431 M compared to substantial benefits of $1.8 B. These large benefits are driven primarily by benefits from the requirements for Bathrooms in Accessible Guest Rooms (including vanities and water closet clearances), supplemented by Accessible Routes to Exercise Machines and Accessible Exercise Machines and Equipment.
  • Indoor Service Establishments: The large negative NPV (-$1.8 B) for this facility is driven partly by the very large number of establishments in this category (over 3 million; next largest category is single-level store with under a million establishments). Amongst the requirements, the costs for alterations for Water Closet Clearance in Single-User Toilet Rooms with Out-Swinging Doors accounts is one of the requirements with the most significantly negative NPV, and is coupled in the this facility group with substantial costs due to lost usable space.
  • Office Buildings: The Office Buildings facility group collectively posted a large negative NPV of -$1 B. This large number is due partly to the large number of existing office buildings (nearly three quarters of a million existing buildings). The requirement with the largest impact on office buildings' NPV is Stairs (Alt/BR) followed by alteration costs for the Side Reach requirement, both of which are among those requirements with significantly negative NPVs.
  • Single Level Stores: This facility group has a fairly large negative NPV (-$355 M) partly due to high costs for alterations for Water Closet Clearance in Single-User Toilet Rooms with Out-Swinging Doors (one of the requirements with the most significantly negative NPV) coupled with substantial costs due to lost usable space.

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 costs are overall costs 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 3 Drivers of Costs list those facilities in which the greatest costs for the requirement are generated.

Table 7: Costs and Benefits per Requirement in Primary Baseline Scenario (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

ID   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     (8.14)     (8.15)   Stadiums (public) Stadiums Shopping Malls   0.02   Shopping Malls Stadiums (public) Stadiums
2   Maneuvering Clearance or Standby Power for Automatic Doors     (0.32)     0.01   Nursing Homes Convention Centers (public) Convention Centers   (0.33)   Nursing Homes Nursing Homes (public) Convention Centers (public)
3   Automatic Door Break-Out Openings     (7.96)     0.00   Motels Hotels Hospitals   (7.96)   Hotels Motels Hospitals
4   Thresholds at Doorways     0.08     1.15   Public Housing Motels Hotels   (1.08)   Public Housing Hotels Motels
5   Door and Gate Surfaces     (23.14)     3.66   Museums, Historical Sites & Libraries (public) Parks or zoos (public) Exercise Facilities   (26.81)   Parks or zoos (public) Undergraduate, postgraduate public schools Elementary Public Schools
9   Stairs (NC)     52.50     52.50   Museums, Historical Sites & Libraries (public) Museums, Historical Sites & Libraries Undergraduate and Postgraduate Private Schools   0.00        
10   Stairs (ALT/BR)     (808.41)     20.02   Motels Hotels Museums, Historical Sites & Libraries (public)   (828.43)   Office Buildings Offices of Health Care Providers Hotels
12   Handrails     (23.66)     (33.55)   Exercise Facilities Museums, Historical Sites & Libraries (public) Parking Garages   9.88   Public Housing Undergraduate, postgraduate public schools Parks or zoos (public)
13   Accessible Routes from Site Arrival Points and Within Sites     (0.95)     (48.50)   Parks or zoos (public) Golf Courses (private with public access) Amusement Parks   47.55   Parks or zoos (public) Self Service Storage Facilities Terminal (private airports)
14   Standby Power for Platform Lifts     (8.45)     0.00   Stadiums (public) Stadiums State and Local Judicial Facilities (courthouses)   (8.45)   State and Local Judicial Facilities (courthouses) Stadiums (public) Stadiums
15   Power-Operated Doors for Platform Lifts     (5.72)     2.39   Stadiums (public) Stadiums State and Local Judicial Facilities (courthouses)   (8.11)   State and Local Judicial Facilities (courthouses) Stadiums (public) Stadiums
16   Alterations to Existing Elevators     (338.98)     2.26   Hotels Nursing Homes Undergraduate and Postgraduate Private Schools   (341.24)   Office Buildings Office Buildings (public) Hotels
19   Van Accessible Parking Spaces     58.85     67.01   Parks or zoos (public) Amusement Parks Stadiums (public)   (8.17)   Parks or zoos (public) Terminal (private airports) Amusement Parks
20   Valet Parking Garages     82.51     109.84   Restaurants Hotels Theatre / Concert Hall   (27.34)   Restaurants Theatre / Concert Hall Hotels
21   Mechanical Access Parking Garages     206.52     206.95   Parking Garages Parking Garages (public)     (0.43)   Parking Garages Parking Garages (public)  
22   Direct Access Entrances from Parking Structures     7.82     7.82   Convention Centers (public) Shopping Malls Convention Centers   0.00        
23   Passenger Loading Zones     1,292.42     1,341.17   Restaurants Shopping Malls Parks or zoos (public)   (48.75)   Parks or zoos (public) Office Buildings Restaurants
24   Parking Spaces     604.04     631.46   Restaurants Museums, Historical Sites & Libraries (public) Museums, Historical Sites & Libraries   (27.42)   Office Buildings Restaurants Parks or zoos (public)
25   Parking Spaces (Signs)     (2.57)     (2.97)   Public Housing       0.40   Public Housing    
26   Passenger Loading Zones (Medical / Long-Term Care)     (280.45)     (413.82)   Nursing Homes Hospitals Nursing Homes (public)   133.37   Nursing Homes Hospitals Nursing Homes (public)
27   Ambulatory Accessible Toilet Compartments     414.78     484.65   Parks or zoos (public) Exercise Facilities Undergraduate and Postgraduate Private Schools   (69.87)   Theatre / Concert Hall Shopping Malls Parks or zoos (public)
28   Water closet clearance in single-user toilet rooms - out swinging door     (898.43)     1,625.70   Indoor Service Establishments Parks or zoos (public) Undergraduate and Postgraduate Private Schools   (2,524.13)   Indoor Service Establishments Offices of Health Care Providers Nursing Homes
29   Shower Spray Controls     136.79     193.36   Undergraduate and Postgraduate Private Schools Motels Hotels   (56.57)   Nursing Homes Undergraduate, postgraduate public schools Parks or zoos (public)
30   Urinals     (11.03)     (11.03)   Undergraduate and Postgraduate Private Schools Museums, Historical Sites & Libraries (public) Museums, Historical Sites & Libraries   0.00        
31   Multiple Single-User Toilet Rooms     94.14     (3.57)   Offices of Health Care Providers Hospitals Theatre / Concert Hall   97.72   Offices of Health Care Providers Theatre / Concert Hall Hospitals
32   Water closet clearance in single-user toilet rooms - in swinging door     (974.75)     42.14   Undergraduate and Postgraduate Private Schools Restaurants Single Level Stores   (1,016.89)   Single Level Stores Restaurants Elementary Public Schools
34   Patient Toilet Rooms     (2.13)     (3.87)   Hospitals Hospitals (public)     1.73   Hospitals Hospitals (public)  
35   Drinking Fountains     (66.49)     0.39   Undergraduate and Postgraduate Private Schools Swimming pools / Aquatic Centers Swimming pools / Aquatic Centers (public)   (66.88)   Office Buildings Office Buildings (public) Swimming pools / Aquatic Centers
37   Side Reach     (554.99)     715.52   Indoor Service Establishments Restaurants Single Level Stores   (1,270.51)   Indoor Service Establishments Office Buildings Single Level Stores
38   Sales and Service Counters (NC)     4.73     (9.57)   Restaurants Museums, Historical Sites & Libraries (public) Museums, Historical Sites & Libraries   14.30   Parks or zoos (public) Indoor Service Establishments Terminal (private airports)
39   Sales and Service Counters (Alt)     85.10     (170.86)   Restaurants Indoor Service Establishments Single Level Stores   255.96   Indoor Service Establishments Single Level Stores Restaurants
40   Washing Machines and Clothes Dryers (technical)     (6.26)     0.13       (6.39)   Public Housing Undergraduate, postgraduate public schools Undergraduate and Postgraduate Private Schools
41   Washing Machines and Clothes Dryers (Scoping)     (1.88)     0.07       (1.95)   Public Housing Undergraduate, postgraduate public schools Undergraduate and Postgraduate Private Schools
42   Self-Service Storage Facility Spaces     25.63     29.69   Self Service Storage Facilities       (4.06)   Self Service Storage Facilities    
45   Bathrooms with vanities and water closet clearance out-swinging doors     1,788.45     1,947.03   Motels Hotels Inns   (158.58)   Hotels Motels Inns
46   Operable Windows     240.03     292.69   Motels Hotels Inns   (52.66)   Public Housing Hotels Motels
47   Dwelling Units with Communication Features [1991]     (13.86)     0.02   Public Housing       (13.88)   Public Housing    
48   Dwelling Units with Communication Features [UFAS]     (3.70)     0.01   Public Housing       (3.70)   Public Housing    
49   Galley Kitchen Clearances     23.81     43.19   Undergraduate and Postgraduate Private Schools Public Housing Undergraduate, postgraduate public schools   (19.38)   Undergraduate, postgraduate public schools Public Housing Undergraduate and Postgraduate Private Schools
50   Shower Compartments with Mobility Features     59.81     (12.79)   Undergraduate and Postgraduate Private Schools Motels Hotels   72.59   Nursing Homes Undergraduate, postgraduate public schools Parks or zoos (public)
51   Location of Accessible Route to Stages     (152.02)     0.14   Undergraduate and Postgraduate Private Schools Amusement Parks Secondary Public Schools   (152.16)   Undergraduate, postgraduate public schools Secondary Public Schools Undergraduate and Postgraduate Private Schools
52   Wheelchair Space Overlap in Assembly Areas     (318.10)     437.36   Museums, Historical Sites & Libraries (public) Secondary Public Schools Museums, Historical Sites & Libraries   (755.46)   Stadiums (public) Motion Picture House Theatre / Concert Hall
54   Handrails on Aisle Ramps in Assembly Areas     (366.72)     (418.39)   Museums, Historical Sites & Libraries (public) Museums, Historical Sites & Libraries Undergraduate and Postgraduate Private Schools   51.66   Parks or zoos (public) Motion Picture House Secondary Public Schools
55   Wheelchair Spaces in Assembly Areas     107.15     (10.63)   Undergraduate and Postgraduate Private Schools Motion Picture House Stadiums (public)   117.78   Stadiums (public) Stadiums Undergraduate, postgraduate public schools
56   Accessible Route to Tiered Dining Areas in Sports Facilities (NC)     6.34     (1.07)   Stadiums (public) Stadiums     7.41   Stadiums (public) Stadiums  
57   Accessible Route to Press Boxes     61.94     (1.39)   Undergraduate and Postgraduate Private Schools Secondary Public Schools Undergraduate, postgraduate public schools   63.33   Secondary Public Schools Undergraduate and Postgraduate Private Schools Undergraduate, postgraduate public schools
58   Public TTYS     (1.69)     0.02   Shopping Malls Convention Centers (public) Stadiums (public)   (1.70)   Terminal (private airports) Shopping Malls State and Local Judicial Facilities (courthouses)
59   Public Telephone Volume Controls     (6.10)     0.01   Hotels Nursing Homes Undergraduate and Postgraduate Private Schools   (6.11)   Hotels State and Local Judicial Facilities (courthouses) Shopping Malls
60   Two-Way Communication Systems at Entrances     (9.15)     10.21   Motels Public Housing     (19.36)   Motels Public Housing  
61   ATMs and Fare Machines     (30.48)     27.77   Indoor Service Establishments Stadiums (public) Stadiums   (58.25)   Indoor Service Establishments Stadiums (public) Hotels
62   Assistive Listening Systems (technical)     (25.77)     2.28   Museums, Historical Sites & Libraries (public) Secondary Public Schools Museums, Historical Sites & Libraries   (28.05)   Secondary Public Schools Undergraduate, postgraduate public schools Stadiums (public)
64   Detectable Warnings (scoping)     318.01     (53.05)   Restaurants Museums, Historical Sites & Libraries (public) Undergraduate and Postgraduate Private Schools   371.07   Indoor Service Establishments Office Buildings Single Level Stores
66   Assistive Listening Systems (scoping)     273.95     (7.29)   Museums, Historical Sites & Libraries (public) Museums, Historical Sites & Libraries Undergraduate and Postgraduate Private Schools   281.23   Stadiums (public) Undergraduate, postgraduate public schools Stadiums
68   Accessible Attorney Areas and Witness Stands     (106.31)     0.02   State and Local Judicial Facilities (courthouses)       (106.33)   State and Local Judicial Facilities (courthouses)    
70   Accessible Route to Exercise Machines and Equipment     967.70     988.00   Exercise Facilities Undergraduate and Postgraduate Private Schools Motels   (20.30)   Exercise Facilities Motels Hotels
71   Accessible Exercise Machines and Equipment     1,411.82     1,903.97   Exercise Facilities Motels Undergraduate and Postgraduate Private Schools   (492.15)   Exercise Facilities Motels Undergraduate and Postgraduate Private Schools
72   Accessible Saunas and Steam Rooms (NC)     192.18     192.18   Exercise Facilities Undergraduate and Postgraduate Private Schools Swimming pools / Aquatic Centers   0.00        
73   Accessible Lockers     160.38     217.41   Exercise Facilities Undergraduate and Postgraduate Private Schools Swimming pools / Aquatic Centers   (57.03)   Exercise Facilities Secondary Public Schools Swimming pools / Aquatic Centers
74   Accessible Dressing Rooms, Fitting Rooms, or Locker Rooms     169.92     172.01   Undergraduate and Postgraduate Private Schools Secondary Private Schools     (2.08)   Undergraduate and Postgraduate Private Schools Secondary Private Schools  
75   Wheelchair Spaces in Team or Player Seating Areas     (0.77)     0.01   Undergraduate and Postgraduate Private Schools Secondary Private Schools     (0.78)   Undergraduate and Postgraduate Private Schools Secondary Private Schools  
77   Accessible Route to Bowling Lanes     132.90     133.92   Bowling Alleys       (1.02)   Bowling Alleys    
78   Shooting Facilities with Firing Positions     260.13     261.02   Shooting Facilities       (0.89)   Shooting Facilities    
79   Primary Accessible Means of Entry to Pools (NC/ALT)     383.62     1,166.36   Swimming pools / Aquatic Centers Motels Hotels   (782.74)   Motels Swimming pools / Aquatic Centers Hotels
80   Accessible Means of Entry to Wading Pools     221.10     1,276.52   Swimming pools / Aquatic Centers Swimming pools / Aquatic Centers (public)     (1,055.42)   Swimming pools / Aquatic Centers Swimming pools / Aquatic Centers (public)  
81   Accessible Means of Entry to Spas     782.49     1,012.16   Swimming pools / Aquatic Centers Undergraduate and Postgraduate Private Schools Nursing Homes   (229.67)   Nursing Homes Swimming pools / Aquatic Centers Hotels
82   Accessible Route for Boating Facilities     6.64     19.16   Recreational Boating Facilities (public) Recreational Boating Facilities     (12.51)   Recreational Boating Facilities (public) Recreational Boating Facilities  
83   Accessible Boarding Piers (NC)     1.10     3.34   Recreational Boating Facilities (public) Recreational Boating Facilities     (2.23)   Recreational Boating Facilities (public) Recreational Boating Facilities  
85   Accessible Boat Slips (NC)     (0.66)     12.42   Recreational Boating Facilities Recreational Boating Facilities (public)     (13.08)   Recreational Boating Facilities Recreational Boating Facilities (public)  
87   Accessible Route to Fishing Piers     35.62     36.04   Fishing Piers and Platforms Fishing Piers and Platforms (public)     (0.42)   Fishing Piers and Platforms Fishing Piers and Platforms (public)  
88   Accessible Fishing Piers and Platforms     81.61     94.61   Parks or zoos (public) Fishing Piers and Platforms Fishing Piers and Platforms (public)   (13.00)   Parks or zoos (public) Fishing Piers and Platforms Fishing Piers and Platforms (public)
89   Accessible Route to Golf Courses     292.35     306.58   Golf Courses (private with public access) Golf Courses (private only) Golf Courses (public)   (14.23)   Golf Courses (private with public access) Golf Courses (private only) Golf Courses (public)
90   Accessible Teeing Grounds, Putting Greens, and Weather Stations (Alt/BR)     196.16     216.50   Golf Courses (private with public access) Golf Courses (private only) Golf Courses (public)   (20.34)   Golf Courses (private with public access) Golf Courses (private only) Golf Courses (public)
92   Accessible Practice Grounds at Driving Ranges     391.52     399.09   Golf Courses (private with public access) Golf Courses (private only) Golf Courses (public)   (7.57)   Golf Courses (private with public access) Golf Courses (private only) Golf Courses (public)
93   Accessible Route to Mini Golf Holes     535.06     553.74   Miniature golf courses Miniature golf courses (public)     (18.68)   Miniature golf courses Miniature golf courses (public)  
94   Accessible Mini Golf Holes     449.95     523.24   Miniature golf courses Miniature golf courses (public)     (73.30)   Miniature golf courses Miniature golf courses (public)  
95   Accessible Route to Amusement Rides     440.74     523.01   Amusement Parks Amusement Parks (public)     (82.27)   Amusement Parks Amusement Parks (public)  
96   Wheelchair Space, Transfer Seat or Transfer Device for Amusement Ride     5.55     7.14   Amusement Parks Amusement Parks (public)     (1.59)   Amusement Parks Amusement Parks (public)  
97   Maneuvering Space in Load and Unload Area of Amusement Ride     14.74     18.60   Amusement Parks Amusement Parks (public)     (3.86)   Amusement Parks Amusement Parks (public)  
98   Signs at Amusement Rides     4.20     6.22   Amusement Parks Amusement Parks (public)     (2.03)   Amusement Parks Amusement Parks (public)  
99   Accessible Route to Play Components (BR)     14.00     244.82   Restaurants Elementary Public Schools Parks or zoos (public)   (230.82)   Elementary Public Schools Parks or zoos (public) Elementary Private Schools
100   Accessible Play Components (BR)     323.58     367.13   Restaurants Elementary Public Schools Parks or zoos (public)   (43.55)   Parks or zoos (public) Elementary Public Schools Elementary Private Schools
101   Accessible Route to Play Components (ALT)     133.29     161.72   Restaurants Motels Shopping Malls   (28.43)   Restaurants Parks or zoos (public) Elementary Public Schools
102   Accessible Play Components (ALT)     234.68     241.02   Restaurants Motels Shopping Malls   (6.33)   Restaurants Parks or zoos (public) Nursery schools - Daycare
103   Accessible Route to Play Components (NC)     (77.11)     74.42   Elementary Public Schools Nursery schools - Daycare Parks or zoos (public)   (151.53)   Nursery schools - Daycare Elementary Public Schools Elementary Private Schools
104   Accessible Play Components (NC)     98.80     112.13   Elementary Public Schools Nursery schools - Daycare Parks or zoos (public)   (13.33)   Nursery schools - Daycare Elementary Public Schools Elementary Private Schools
106   Post Secondary School Multi-Story Dorm Facility     (64.04)     0.42   Undergraduate, postgraduate public schools       (64.46)   Undergraduate, postgraduate public schools    
107   Mobility Accessible Prison Cell     44.08     (11.72)   State and Local Correctional Facilities (prisons)       55.80   State and Local Correctional Facilities (prisons)    
108   Communication Accessible Prison Cell     (5.83)     0.33   State and Local Correctional Facilities (prisons)       (6.17)   State and Local Correctional Facilities (prisons)    
109   Social Service Establishments – Elevator Access (NC)     6.70     0.00           6.70   Homeless Shelter Homeless Shelter (public)  
110   Social Service Establishments – Clear Floor Space around Beds     105.74     110.90   Homeless Shelter Homeless Shelter (public)     (5.17)   Homeless Shelter Homeless Shelter (public)  
111   Accessible Saunas and Steam Rooms (ALT/BR)     179.61     421.75   Exercise Facilities Undergraduate and Postgraduate Private Schools Swimming pools / Aquatic Centers   (242.14)   Exercise Facilities Swimming pools / Aquatic Centers Undergraduate and Postgraduate Private Schools
112   Primary Accessible Means of Entry to Pools (BR)     39.32     130.49       (91.16)   Swimming pools / Aquatic Centers Motels Hotels
113   Housing at Places of Education – Kitchen Turning Space     49.66     53.06   Undergraduate and Postgraduate Private Schools Undergraduate, postgraduate public schools     (3.40)   Undergraduate and Postgraduate Private Schools Undergraduate, postgraduate public schools  
114   Housing at Places of Education – Kitchen Work Surfaces     (0.17)     4.90   Undergraduate and Postgraduate Private Schools Undergraduate, postgraduate public schools     (5.06)   Undergraduate, postgraduate public schools Undergraduate and Postgraduate Private Schools  
115   Secondary Accessible Means of Entry into Pools (NC/ALT)     132.88     161.89   Undergraduate and Postgraduate Private Schools Swimming pools / Aquatic Centers Undergraduate, postgraduate public schools   (29.01)   Swimming pools / Aquatic Centers Undergraduate and Postgraduate Private Schools Undergraduate, postgraduate public schools
116   Secondary Accessible Means of Entry into Pools (BR)     12.00     26.22   Undergraduate and Postgraduate Private Schools Swimming pools / Aquatic Centers Swimming pools / Aquatic Centers (public)   (14.22)   Swimming pools / Aquatic Centers Undergraduate and Postgraduate Private Schools Swimming pools / Aquatic Centers (public)
117   Social Service Establishments – Roll-in Shower     (0.09)     0.03   Social Service Establishments (public) Homeless Shelter (public)     (0.11)   Social Service Establishments (public) Homeless Shelter (public)  

 

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 costs are overall costs 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 requirements 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 3 Drivers of Impacts to Facilities column lists the requirements with the largest impact on facility costs.

Table 8: Total Costs and Benefits per Facility Group in Primary Baseline Scenario (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

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   499.53     519.19   Bathrooms with vanities and water closet clearance out-swinging doors Operable Windows Side Reach   (19.65)   Bathrooms with vanities and water closet clearance out-swinging doors Side Reach Operable Windows
Hotels   753.47     1,232.08   Bathrooms with vanities and water closet clearance out-swinging doors Accessible Exercise Machines and Equipment Primary Accessible Means of Entry to Pools (NC/ALT)   (478.61)   Primary Accessible Means of Entry to Pools (NC/ALT) Bathrooms with vanities and water closet clearance out-swinging doors Stairs (ALT/BR)
Motels   1,403.08     1,834.48   Bathrooms with vanities and water closet clearance out-swinging doors Accessible Exercise Machines and Equipment Primary Accessible Means of Entry to Pools (NC/ALT)   (431.40)   Primary Accessible Means of Entry to Pools (NC/ALT) Bathrooms with vanities and water closet clearance out-swinging doors Side Reach
Restaurants   1,413.77     1,742.54   Passenger Loading Zones Parking Spaces Accessible Play Components (ALT)   (328.77)   Water closet clearance in single-user toilet rooms - in swinging door Side Reach Accessible Route to Play Components (BR)
Motion Picture House   (169.43)     8.84   Wheelchair Space Overlap in Assembly Areas Passenger Loading Zones Parking Spaces   (178.26)   Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments Water closet clearance in single-user toilet rooms - in swinging door
Theatre / Concert Hall   (145.52)     25.37   Water closet clearance in single-user toilet rooms - out swinging door Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments   (170.90)   Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments Location of Accessible Route to Stages
Stadiums   (10.90)     18.85   Passenger Loading Zones Wheelchair Space Overlap in Assembly Areas Van Accessible Parking Spaces   (29.75)   Wheelchair Space Overlap in Assembly Areas Water closet clearance in single-user toilet rooms - out swinging door Accessible Saunas and Steam Rooms (ALT/BR)
Auditoriums   (9.63)     15.83   Passenger Loading Zones Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments   (25.46)   Wheelchair Space Overlap in Assembly Areas Location of Accessible Route to Stages Ambulatory Accessible Toilet Compartments
Convention Centers   20.11     19.26   Passenger Loading Zones Ambulatory Accessible Toilet Compartments Direct Access Entrances from Parking Structures   0.85   Assistive Listening Systems (scoping) Detectable Warnings (scoping) Handrails
Single Level Stores   (354.54)     61.78   Side Reach Water closet clearance in single-user toilet rooms - in swinging door Door and Gate Surfaces   (416.32)   Water closet clearance in single-user toilet rooms - in swinging door Side Reach Door and Gate Surfaces
Shopping Malls   280.14     328.01   Passenger Loading Zones Ambulatory Accessible Toilet Compartments Accessible Play Components (ALT)   (47.87)   Stairs (ALT/BR) Ambulatory Accessible Toilet Compartments Water closet clearance in single-user toilet rooms - in swinging door
Indoor Service Establishments   (1,758.39)     410.84   Water closet clearance in single-user toilet rooms - out swinging door Side Reach ATMs and Fare Machines   (2,169.22)   Water closet clearance in single-user toilet rooms - out swinging door Side Reach ATMs and Fare Machines
Offices of Health Care Providers   (228.77)     76.99   Water closet clearance in single-user toilet rooms - out swinging door Side Reach Stairs (NC)   (305.76)   Water closet clearance in single-user toilet rooms - out swinging door Stairs (ALT/BR) Side Reach
Hospitals   (26.42)     (1.70)   Passenger Loading Zones (Medical / Long-Term Care) Patient Toilet Rooms Multiple Single-User Toilet Rooms   (24.72)   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     (192.94)     (61.48)   Passenger Loading Zones (Medical / Long-Term Care) Detectable Warnings (scoping) Accessible Routes from Site Arrival Points and Within Sites   (131.46)   Water closet clearance in single-user toilet rooms - out swinging door Accessible Means of Entry to Spas Side Reach
Terminal (private airports)   1.84     0.10   Direct Access Entrances from Parking Structures Passenger Loading Zones Water closet clearance in single-user toilet rooms - out swinging door   1.74   Accessible Routes from Site Arrival Points and Within Sites Detectable Warnings (scoping) Sales and Service Counters (NC)
Depots   0.10     0.08   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   68.81     74.82   Wheelchair Space Overlap in Assembly Areas Passenger Loading Zones Side Reach   (6.01)   Water closet clearance in single-user toilet rooms - in swinging door Wheelchair Space Overlap in Assembly Areas Stairs (ALT/BR)
Parks or zoos   42.28     45.73   Water closet clearance in single-user toilet rooms - out swinging door Passenger Loading Zones Ambulatory Accessible Toilet Compartments   (3.45)   Accessible Route to Play Components (BR) Water closet clearance in single-user toilet rooms - in swinging door Accessible Fishing Piers and Platforms
Amusement Parks   734.55     826.86   Accessible Route to Rides Water closet clearance in single-user toilet rooms - out swinging door Ambulatory Accessible Toilet Compartments   (92.30)   Accessible Route to Amusement Rides Maneuvering Space in Load and Unload Area of Amusement Ride Signs at Amusement Park rides
Nursery schools - Daycare   (7.47)     121.85   Water closet clearance in single-user toilet rooms - out swinging door Accessible Play Components (NC) Accessible Route to Play Components (NC)   (129.32)   Accessible Route to Play Components (NC) Water closet clearance in single-user toilet rooms - out swinging door Side Reach
Elementary Private Schools   (29.65)     67.44   Accessible Play Components (BR) Accessible Route to Play Components (BR) Water closet clearance in single-user toilet rooms - out swinging door   (97.09)   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   (10.64)     9.23   Water closet clearance in single-user toilet rooms - out swinging door Wheelchair Space Overlap in Assembly Areas Accessible Exercise Machines and Equipment   (19.87)   Location of Accessible Route to Stages Accessible Lockers Side Reach
Undergraduate and Postgraduate Private Schools   1,475.53     1,628.02   Accessible Exercise Machines and Equipment Water closet clearance in single-user toilet rooms - out swinging door Accessible Dressing Rooms, Fitting Rooms, or Locker Rooms   (152.49)   Primary Accessible Means of Entry to Pools (NC/ALT) Location of Accessible Route to Stages Accessible Exercise Machines and Equipment
Ski Facilities   45.94     46.03   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   138.48     141.08   Social Service Establishments – Clear Floor Space around Beds Water closet clearance in single-user toilet rooms - out swinging door Side Reach   (2.59)   Social Service Establishments – Clear Floor Space around Beds Water closet clearance in single-user toilet rooms - out swinging door Shower Spray Controls
Food Banks   15.70     16.92   Water closet clearance in single-user toilet rooms - out swinging door Parking Spaces Side Reach   (1.22)   Water closet clearance in single-user toilet rooms - out swinging door Side Reach Parking Spaces
Social Service Establishments   (33.20)     1.51   Side Reach Water closet clearance in single-user toilet rooms - in swinging door Door and Gate Surfaces   (34.70)   Water closet clearance in single-user toilet rooms - in swinging door Side Reach Door and Gate Surfaces
Exercise Facilities   1,777.80     2,461.53   Accessible Exercise Machines and Equipment Accessible Route to Exercise Machines and Equipment Accessible Saunas and Steam Rooms (ALT/BR)   (683.72)   Accessible Exercise Machines and Equipment Accessible Saunas and Steam Rooms (ALT/BR) Accessible Lockers
Swimming pools / Aquatic Centers   1,380.45     2,771.53   Accessible Means of Entry to Wading Pools Primary Accessible Means of Entry to Pools (NC/ALT) Accessible Means of Entry to Spas   (1,391.08)   Accessible Means of Entry to Wading Pools Primary Accessible Means of Entry to Pools (NC/ALT) Primary Accessible Means of Entry to Pools (BR)
Bowling Alleys   133.35     134.73   Accessible Route to Bowling Lanes Side Reach Door and Gate Surfaces   (1.37)   Accessible Route to Bowling Lanes Side Reach Door and Gate Surfaces
Golf Courses (private with public access)   805.36     842.80   Accessible Practice Grounds at Driving Ranges Accessible Route to Golf Courses Accessible Teeing Grounds, Putting Greens, and Weather Stations (Alt/BR)   (37.44)   Accessible Teeing Grounds, Putting Greens, and Weather Stations (Alt/BR) Accessible Route to Golf Courses Accessible Practice Grounds at Driving Ranges
Golf Courses (private only)   178.37     199.05   Accessible Practice Grounds at Driving Ranges Accessible Route to Golf Courses Accessible Teeing Grounds, Putting Greens, and Weather Stations (Alt/BR)   (20.69)   Accessible Teeing Grounds, Putting Greens, and Weather Stations (Alt/BR) Accessible Route to Golf Courses Water closet clearance in single-user toilet rooms - in swinging door
Miniature golf courses   951.40     1,045.72   Accessible Route to Mini Golf Holes Accessible Mini Golf Holes Side Reach   (94.33)   Accessible Mini Golf Holes Accessible Route to Mini Golf Holes Water closet clearance in single-user toilet rooms - in swinging door
Recreational Boating Facilities   (1.42)     16.18   Accessible Route for Boating Facilities Accessible Boat Slips (NC) Accessible Boarding Piers (NC)   (17.60)   Accessible Boat Slips (NC) Accessible Route for Boating Facilities Water closet clearance in single-user toilet rooms - in swinging door
Fishing Piers and Platforms   41.40     44.95   Accessible Route to Fishing Piers Accessible Fishing Piers and Platforms     (3.56)   Accessible Fishing Piers and Platforms Accessible Route to Fishing Piers  
Shooting Facilities   256.76     256.22   Shooting Facilities with Firing Positions Door and Gate Surfaces     0.54   Accessible Routes from Site Arrival Points and Within Sites Detectable Warnings (scoping)  
Office Buildings   (1,036.49)     3.55   Passenger Loading Zones Parking Spaces Side Reach   (1,040.03)   Stairs (ALT/BR) Alterations to Existing Elevators Side Reach
Elementary Public Schools   34.55     282.89   Water closet clearance in single-user toilet rooms - out swinging door Accessible Play Components (BR) Accessible Route to Play Components (BR)   (248.34)   Accessible Route to Play Components (BR) Water closet clearance in single-user toilet rooms - in swinging door Side Reach
Secondary Public Schools   181.74     297.85   Water closet clearance in single-user toilet rooms - out swinging door Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments   (116.11)   Location of Accessible Route to Stages Water closet clearance in single-user toilet rooms - in swinging door Side Reach
Undergraduate, postgraduate public schools   (190.52)     20.93   Water closet clearance in single-user toilet rooms - out swinging door Accessible Exercise Machines and Equipment Accessible Means of Entry to Spas   (211.45)   Post Secondary School Multi-Story Dorm Facility Location of Accessible Route to Stages Stairs (ALT/BR)
Public Housing   (25.45)     147.21   Water closet clearance in single-user toilet rooms - out swinging door Accessible Play Components (BR) Accessible Route to Play Components (BR)   (172.66)   Stairs (ALT/BR) Operable Windows Accessible Route to Play Components (BR)
State and Local Judicial Facilities (courthouses)   (156.86)     0.81   Water closet clearance in single-user toilet rooms - out swinging door Side Reach Passenger Loading Zones   (157.67)   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)   (0.20)     0.02   Shower Spray Controls Side Reach Passenger Loading Zones   (0.22)   Shower Spray Controls Side Reach Door and Gate Surfaces
State and Local Correctional Facilities (prisons)   39.98     (7.26)   Mobility Accessible Prison Cell Detectable Warnings (scoping) Accessible Routes from Site Arrival Points and Within Sites   47.24   Mobility Accessible Prison Cell Shower Compartments with Mobility Features Accessible Routes from Site Arrival Points and Within Sites
Parking Garages   203.25     208.40   Mechanical Access Parking Garages Stairs (NC) Stairs (ALT/BR)   (5.15)   Stairs (ALT/BR) Mechanical Access Parking Garages  
Self Service Storage Facilities   23.03     29.32   Self-Service Storage Facility Spaces Side Reach Stairs (NC)   (6.30)   Self-Service Storage Facility Spaces Stairs (ALT/BR) Side Reach
Theatre / Concert Halls (public)   (0.09)     0.03   Water closet clearance in single-user toilet rooms - out swinging door Ambulatory Accessible Toilet Compartments Wheelchair Space Overlap in Assembly Areas   (0.11)   Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments Location of Accessible Route to Stages
Stadiums (public)   (35.72)     48.49   Passenger Loading Zones Wheelchair Space Overlap in Assembly Areas Van Accessible Parking Spaces   (84.22)   Wheelchair Space Overlap in Assembly Areas Water closet clearance in single-user toilet rooms - out swinging door Assistive Listening Systems (technical)
Auditoriums (public)   (0.64)     0.73   Passenger Loading Zones Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments   (1.37)   Wheelchair Space Overlap in Assembly Areas Location of Accessible Route to Stages Ambulatory Accessible Toilet Compartments
Convention Centers (public)   30.17     28.89   Passenger Loading Zones Ambulatory Accessible Toilet Compartments Direct Access Entrances from Parking Structures   1.28   Assistive Listening Systems (scoping) Detectable Warnings (scoping) Handrails
Hospitals (public)   (2.69)     (1.35)   Passenger Loading Zones (Medical / Long-Term Care) Patient Toilet Rooms Multiple Single-User Toilet Rooms   (1.34)   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 (public)   (19.52)     (13.47)   Passenger Loading Zones (Medical / Long-Term Care) Detectable Warnings (scoping) Accessible Routes from Site Arrival Points and Within Sites   (6.05)   Water closet clearance in single-user toilet rooms - out swinging door Accessible Means of Entry to Spas Side Reach
Museums, Historical Sites & Libraries (public)   99.05     111.24   Wheelchair Space Overlap in Assembly Areas Passenger Loading Zones Side Reach   (12.20)   Water closet clearance in single-user toilet rooms - in swinging door Wheelchair Space Overlap in Assembly Areas Stairs (ALT/BR)
Parks or zoos (public)   418.88     601.92   Water closet clearance in single-user toilet rooms - out swinging door Passenger Loading Zones Ambulatory Accessible Toilet Compartments   (183.04)   Accessible Route to Play Components (BR) Water closet clearance in single-user toilet rooms - in swinging door Side Reach
Homeless Shelter (public)   20.28     20.68   Social Service Establishments – Clear Floor Space around Beds Water closet clearance in single-user toilet rooms - out swinging door Side Reach   (0.40)   Social Service Establishments – Clear Floor Space around Beds Water closet clearance in single-user toilet rooms - out swinging door Shower Spray Controls
Exercise Facilities (public)   25.83     35.20   Accessible Exercise Machines and Equipment Ambulatory Accessible Toilet Compartments Accessible Lockers   (9.36)   Accessible Exercise Machines and Equipment Wheelchair Space Overlap in Assembly Areas Accessible Lockers
Social Service Establishments (public)   (13.65)     0.57   Side Reach Water closet clearance in single-user toilet rooms - in swinging door Door and Gate Surfaces   (14.22)   Water closet clearance in single-user toilet rooms - in swinging door Side Reach Door and Gate Surfaces
Swimming pools / Aquatic Centers (public)   125.53     215.22   Accessible Means of Entry to Wading Pools Primary Accessible Means of Entry to Pools (NC/ALT) Accessible Means of Entry to Spas   (89.69)   Accessible Means of Entry to Wading Pools Primary Accessible Means of Entry to Pools (NC/ALT) Primary Accessible Means of Entry to Pools (BR)
Miniature golf courses (public)   27.21     29.94   Accessible Route to Mini Golf Holes Accessible Mini Golf Holes Side Reach   (2.73)   Accessible Mini Golf Holes Water closet clearance in single-user toilet rooms - in swinging door Accessible Route to Mini Golf Holes
Recreational Boating Facilities (public)   4.59     18.33   Accessible Route for Boating Facilities Accessible Boat Slips (NC) Accessible Boarding Piers (NC)   (13.74)   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)   26.24     26.95   Accessible Route to Fishing Piers Accessible Fishing Piers and Platforms     (0.71)   Accessible Fishing Piers and Platforms Accessible Route to Fishing Piers  
Office Buildings (public)   (93.39)     9.70   Passenger Loading Zones Parking Spaces Side Reach   (103.09)   Stairs (ALT/BR) Alterations to Existing Elevators Side Reach
Parking Garages (public)   1.63     1.68   Mechanical Access Parking Garages Stairs (NC) Stairs (ALT/BR)   (0.05)   Stairs (ALT/BR) Mechanical Access Parking Garages  
Golf Courses (public)   85.05     89.49   Water closet clearance in single-user toilet rooms - out swinging door Accessible Practice Grounds at Driving Ranges Accessible Route to Golf Courses   (4.43)   Water closet clearance in single-user toilet rooms - in swinging door Water closet clearance in single-user toilet rooms - out swinging door Side Reach
Restaurants (public)   0.04     0.04   Passenger Loading Zones Parking Spaces Side Reach   (0.00)   Water closet clearance in single-user toilet rooms - in swinging door Side Reach Valet Parking Garages
Amusement Parks (public)   38.83     39.68   Accessible Route to Rides Water closet clearance in single-user toilet rooms - out swinging door Ambulatory Accessible Toilet Compartments   (0.85)   Accessible Route to Rides Location of Accessible Route to Stages Wheelchair Space or Transfer Seat or Transfer Device

 

6.1.5 Net Present Value for Public versus Private Facilities

Figure 14 shows the respective NPVs for the following facility groups: Elementary Public Schools; Elementary Private Schools; Undergraduate and Postgraduate Public Schools; and, Undergraduate and Postgraduate Private Schools. The results show a large discrepancy in NPVs between these types of public and private educational facilities. 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 14: NPV for Selected Public and Private Educational Facilities (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Figure 14: NPV for Selected Public and Private Educational Facilities

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 ($8.6 B) is significantly higher than that for public facilities ($655 M). The private facility groups with the largest (positive or negative) NPV are Exercise Facilities ($1.8 B), Undergraduate and Postgraduate Private Schools ($1.5 B), Motels ($1.4 B), Single Level Stores (-$355 M), Office Buildings (-$1.0 B) and Indoor Service Establishments (-$1.8 B). The public facility group with the greatest benefits is Parks and Zoos, with a positive NPV of $419 M. The public facility group with the largest negative NPV is the Undergraduate and Postgraduate Public Schools facility group (-$191 M).

Table 9: Net Present Values for Public and Private Facilities (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Facility Group NPV($ mil)* Impact to Facilities* Facility Group NPV ($ mil)* Impact to Facilities*
A Inns 499.5 (19.7)   No public counterpart
B Hotels 753.5 (478.6)   No public counterpart
C Motels 1,403.1 (431.4)   No public counterpart
D Restaurants 1,403.1 (328.8)   BP Restaurants (public) 0.04 (0.01)
E Motion Picture House -169.4 (178.3)   No public counterpart
F Theatre / Concert Hall (145.5) (170.9)   AW Theatre / Concert Halls (public) (0.1) (0.1)
G Stadiums (10.9) (29.8)   AX Stadiums (public) (35.7) (84.2)
H Auditoriums (9.6) (25.5)   AY Auditoriums (public) (0.6) (1.4)
I Convention Centers 20.1 0.9   AZ Convention Centers (public) 30.2 1.3
J Single Level Stores (354.5) (416.3)   No public counterpart
K Shopping Malls 280.1 (47.9)   No public counterpart
L Indoor Service Establishments (1,758.4) (2,169.2)   No public counterpart
M Offices of Health Care Providers (228.8) (305.8)   No public counterpart
N Hospitals (26.4) (24.7)   BB Hospitals (public) (2.7) (1.3)
O Nursing Homes (192.9) (131.5)   BC Nursing Homes (public) (19.5) (6.0)
P Terminal (private airports) 6.8 1.7   No public counterpart
Q Depots 0.1 0.0   No public counterpart
R Museums, Historical Sites & Libraries 68.8 (6.0)   BD Museums, Historical Sites & Libraries (public) 99.0 (12.2)
S Parks or zoos 42.3 (3.5)   BE Parks or zoos (public) 418.9 (183.0)
T Amusement Parks 734.6 (92.3)   BQ Amusement Parks (public) 38.8 (0.8)
U Nursery schools - Daycare (7.5) (129.3)   No public counterpart
V Elementary Private Schools (29.6) (97.1)   AN Elementary Public Schools 34.5 (248.3)
W Secondary Private Schools (10.6) (19.9)   AO Secondary Public Schools 181.7 (116.1)
X Undergraduate and Postgraduate Private Schools 1,475.5 (152.5)   AP Undergraduate, postgraduate public schools (190.5) (211.5)
Y Ski Facilities 45.9 (0.1)   No public counterpart
Z Homeless Shelter 138.5 (2.6)   BF Homeless Shelter (public) 20.3 (0.4)
AA Food Banks 15.7 (1.2)   No public counterpart
AB Social Service Establishments (33.2) (34.7)   BH Social Service Establishments (public) (13.7) (14.2)
AC Exercise Facilities 1,777.8 (683.7)   BG Exercise Facilities (public) 25.8 (9.4)
AD Aquatic Centers /Swimming Pools 1,380.4 (1,391.1)   BI Aquatic Centers /Swimming Pools (public) 125.5 (89.7)
AE Bowling Alleys 133.4 (1.4)   No public counterpart
AF Golf Courses (private with public access) 805.4 (37.4)   No public counterpart
AG Golf Courses (private only) 178.4 (20.7)   BO Golf Courses (public) 85.1 (4.4)
AH Miniature golf courses 951.4 (94.3)   BJ Miniature golf courses (public) 27.2 (2.7)
AI Recreational Boating Facilities (1.4) (17.6)   BK Recreational Boating Facilities (public) 4.6 (13.7)
AJ Fishing Piers and Platforms 41.4 (3.6)   BL Fishing Piers and Platforms (public) 26.2 (0.7)
AK Shooting Facilities 256.8 0.5   No public counterpart
AM Office Buildings (1,036.5) (1,040.0)   BM Office Buildings (public) (93.4) (103.1)
No private counterpart   AQ Public Housing (25.2) (172.7)
No private counterpart   AR State and Local Judicial Facilities (courthouses) (156.9) (157.7)
No private counterpart   AS State and Local Detention Facilities (jails) (0.2) (0.2)
No private counterpart   AT State and Local Correctional Facilities (prisons) 40.0 47.2
AU Parking Garages 203.2 (5.2)   BN Parking Garages (public) 1.6 (0.05)
AV Self Service Storage Facilities 23.0 (6.3)   No public counterpart

*NPV figures in parentheses are negative net values; Figures in parenthesis under "Impact to Facilities" represent a net cost to that facility group, and when not in parentheses represent a net savings to facilities.

6.2 Results Under Additional Scenarios

This section discusses the three additional scenarios that are modeled in this final regulatory analysis. These three additional scenarios are: barrier removal that would be readily achievable in either 0%, 50%, or 100% of situations (RA0, RA50, and RA100); alternate baselines using either the 1991 Standards or recent IBC editions (B1991, B2000, B2003, and B2006); and, safe harbor (SH) versus no safe harbor (NSH) for existing facilities.[5]

Results for RA0, and RA100 assume SH and B1991. Alternative baselines for B1991 and the various IBC editions (B2000, B2003, and B2006) all assume SH and RA100.

6.2.1 Readily Achievable Scenarios

Figure 15 provides an assessment of how NPV changes with different readily achievable assumptions. The chart shows RA at the 0, 50, and 100% levels.The RA scenarioshave different costs and benefits, since they imply dissimilar rates of barrier removal construction as well as differentaccrual of the benefits associated with them. There are, therefore, twooffsetting effects working simultaneously. The first effect that pushes costs up as the RA% increases isa higherbarrier removal cost due to a highernumber of elements subject to new requirementsundergoingbarrier removal. The secondeffectincreases the benefitsas the RA% increases, becausetherate of completion of elements related to new requirements is higher, and so are the benefits derived from them. The combination of theseeffectsis the cause ofthis dissimilar set of curves.

Figure 15: NPV Comparison – Alternate Readily Achievable Scenarios: RA0, RA50, RA100 (Under Safe Harbor, 1991 Standards for Baseline, 7% Discount Rate)

Figure 15: NPV Comparison – Alternate Readily Achievable Scenarios: RA0, RA50, RA100 (Under Safe Harbor, 1991 Standards for Baseline, 7% Discount Rate)

6.2.2 International Building Code (IBC) Scenarios

Figure 16 presents differences in NPV for different baselines, including the various IBC editions (B2000, B2003, and B2006). These probability curves indicate the effect of changing the set of requirements that apply. The results indicate that B2000 (IBC 2000) has the highest NPV, 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 the requirement for Accessible Attorney Areas and Witness Stands is no longer included. The total NPV using the 2006 IBC is lowest of all the scenarios (though not by much), as the requirements for Bathrooms in Accessible Guest Rooms (vanities and water closet clearances) and Water Closet Clearances with Out-Swinging Doors are no longer included under this scenario.

Figure 16: NPV Comparison – Alternate Baselines: B1991, B2000, B2003, and B2006 (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 7% Discount Rate)

Figure 16: NPV Comparison – Alternate Baselines: B1991, B2000, B2003, and B2006 (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 7% Discount Rate)

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/ANSI adoption by state and local jurisdictions. Nonetheless, to further assist stakeholders in assessing the impact of the Final Rules, the final regulatory analysis includes a more limited assessment of 20 selected requirements relative to state- and requirement-specific alternate IBC/ANSI baselines that reflect the extent to which State and local jurisdictions nationwide have incorporated equivalent IBC/ANSI model code provisions into their respective building or accessibility codes. These requirements were selected for additional research because of their readily identifiable IBC/ANSI counterparts in state or local codes and their predominantly negative net present values. An alternate IBC/ANSI baseline was constructed for each requirement by researching current building and accessibility codes nationwide (i.e., all 50 States, the District of Columbia, and, as applicable, local jurisdictions within States) to identify those jurisdictions that already have adopted its respective IBC/ANSI counterpart(s). Appendix 10 presents a matrix summarizing the results of this research by listing, for each requirement, the State and local jurisdictions that have incorporated equivalent IBC/ANSI model code provisions into their own codes, as well as the types of facilities to which such code provisions apply. Depending on the particular requirement, it is estimated that between 24% and 95% of facilities nationwide are already required to comply with a State or local code standard (based on an IBC and/or ANSII provision) that mirrors one of these requirements. Thus, for purposes of these state- and requirement-specific alternate IBC/ANSI baselines, the expected values for NPV were scaled by the appropriate percentages for each requirement.

Table 10 presents an alternative state- and requirement-specific IBC baseline analysis that demonstrates the estimated impact (in terms of total NPV) of using more refined alternate IBC/ANSI baselines for an illustrative subset of requirements. Since it is not feasible to construct separate IBC baselines for each requirement that precisely track the extent to which the current building or accessibility code in each respective state or local jurisdiction across the country incorporates an IBC or ANSI model code provision that mirrors that requirement, a subset of 20 requirements with both readily-identifiable IBC/ANSI counterparts and generally negative NPVs under the primary baseline (i.e., the subset included one requirement with a positive NPV) was selected for more in-depth study. Table 10 presents the comparative results (in terms of total NPV) for these requirements using a primary baseline (1991 Standards) and a state- and requirement-specific alternate IBC/ANSI baseline. These alternate IBC/ANSI baselines were constructed for each of the requirements by researching current building codes nationwide (i.e., all 50 States, the District of Columbia, and, as applicable, local jurisdictions within States) to determine whether the equivalent IBC/ANSI counterpart(s) for each of these requirements had been adopted and was being enforced as part of the building or accessibility code in the respective State or local jurisdiction. Depending on the particular requirement, it is estimated that between 24% and 95% of facilities nationwide are already required to be compliant with a State or local code standard (based on an IBC and/or ANSI provision) that mirrors one of these requirements. Thus, for purposes of these state- and requirement-specific alternate IBC/ANSI baselines, the expected values for NPV were scaled by the appropriate percentages for each requirement.

These results show that consideration of state- and requirement-specific alternate IBC/ANSI baselines for these requirements results in markedly lower incremental costs (and benefits) as compared to their respective results under the primary baseline. Based on these alternate IBC/ANSI baselines, the likely net costs for this subset of requirements falls from -$4.3 B (1991 Standards baseline) to -$1.3 B (state- and requirement-specific alternate IBC baselines). It is not known, however, what the overall NPV for the Final Rules would be were state and requirement-specific alternate IBC/ANSI baselines developed and applied for all requirements. Application of such alternate IBC/ANSI baselines might lead to a decrease in monetized benefits for some requirements as compared to the 1991 Standards baseline.

Table 10: NPV Comparison using Primary (1991 Standards) Baseline and State-by-State Requirement-Specific Alternate IBC/ANSI Baseline (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 7% Discount Rate)

Req. ID Requirement % of Facilities Covered by IBC NPV 1991 Baseline (million $) NPV IBC/ ANSI Baseline (million $)
3 Automatic Door Break-Out Openings 87% ($8) ($1)
5 Door and Gate Surfaces 53% ($23) ($11)
10 Stairs (Alt/BR) 95% ($808) ($41)
14 Standby Power for Platform Lifts 80% ($8) ($2)
15 Power-Operated Doors for Platform Lifts 51% ($6) ($3)
16 Alterations to Existing Elevators 70% ($339) ($102)
20 Valet Parking Garages 52% $83 $40
28 Water closet clearance in single-user toilet rooms - out swinging door 49% ($898) ($454)
32 Water closet clearance in single-user toilet rooms - in swinging door 73% ($975) ($266)
35 Drinking Fountains 47% ($66) ($36)
37 Side Reach 72% ($555) ($153)
41 Washing Machines and Clothes Dryers (Scoping) 31% ($2) ($1)
51 Location of Accessible Route to Stages 36% ($152) ($97)
52 Wheelchair Space Overlap in Assembly Areas 86% ($318) ($43)
58 Public TTYS 31% ($2) ($1)
59 Public Telephone Volume Controls 31% ($6) ($4)
60 Two-Way Communication Systems at Entrances 24% ($9) ($7)
61 ATMs and Fare Machines 31% ($30) ($21)
62 Assistive Listening Systems (technical) 24% ($26) ($20)
68 Accessible Attorney Areas and Witness Stands 39% ($106) ($64)
Sum of Above Requirements ($4,256) ($1,288)

6.2.3 Safe Harbor and No Safe Harbor Scenarios

The following graph compares the net benefits under safe harbor (SH) and without safe harbor (NSH) policies for the entire rule (both assuming RA50 and 1991 Standards). The difference in NPV is significant. Without SH, benefits would most likely exceed costs by a little more than $6 B whereas with a SH policy, benefits are expected to exceed costs by more than $9 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 17: Safe Harbor vs. No Safe Harbor (Under 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Figure 17: Safe Harbor vs. No Safe Harbor (Under 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

6.3 Relative Impact of Selected Assumptions

As noted in Sections 3.3 and 4.3, this regulatory impact analysis incorporates a risk analysis process that simultaneously varies all estimated inputs within their distributions to generate more realistic assessments of the likely range of not only the total monetized costs and benefits of the Final Rules., but also a better understanding of the potential impact on results of the uncertainty surrounding such inputs.  The results presented in preceding sections of this Final RIA illustrate how parameters of multiple uncertainties translate into variability of NPVs.

To further explore the relative impact of alternate assumptions for certain selected parameters or  inputs, Two sets of additional analyses were conducted which Ð unlike the risk analysis approach otherwise used throughout the Final RIA --varied each assumption individually. Such an approach is similar to traditional sensitivity analysis which assesses the impact in results from a hypothetical change to one parameter.  The two sets of additional analyses consist of: (1) a set of "stress tests" examining the impact on results (when the value of one selected input is altered while holding all other parameters constant; and (2) a series of analyses exploring the relative impact of the variability (risk ranges) for inputs that serve as the key drivers of the overall costs and benefits for the three requirements with the largest negative NPVs under the primary baseline, as well as the three requirements with the largest positive NPVs under this same baseline.  The results from each set of additional sensitivity-type analyses are presented and discussed separately below.  All changes to costs and benefits in these analyses are assessed under the primary baseline (i.e., (Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, and 7% Discount Rate).

The stress tests analyses examine the relative impact on costs and benefits of varying the following six selected inputs individually: the premium on access time; the premium on use time; the price elasticity of demand for facility visits; the alterations rate for existing facilities; the indirect cost of a business owner's time to review new guidelines (as requested by business and industry-related commenters); and, the number of persons with disabilities expected to benefit from the Final Rules.  The results of these analyses are presented below in Tables 11 – 16.

The first stress test examines the impact of reducing the access time premium.  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.

Table 11 provides the results of this first stress analysis relative to all requirements assessed in the Final RIA. Some requirements have no data since, in the primary 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 0.5 instead of 1) reduces the benefits to users by that factor. Lowering the premium by one half reduces total net benefits from $9.2 B to $5.8 B, or 37%.

Table 11: Impact on Results of Reduced to Access Time Premium (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Requirement NPV
(Million $)
Impact of Reduced Premium On Net Benefits to Users Premium = .5NPV (Million $)
Public Entrances (8.1) (6.1)
Maneuvering Clearance or Standby Power for Automatic Doors (0.3) (0.3)
Automatic Door Break-Out Openings (8.0) (8.0)
Thresholds at Doorways 0.1 (0.2)
Door and Gate Surfaces (23.1) (23.8)
Location of Accessible Routes - -
Common Use Circulation Paths in Employee Work Areas - -
Accessible Means of Egress - -
Stairs (NC) 52.5 39.2
Stairs (ALT/BR) (808.4) (813.5)
Handrails Along Walkways - -
Handrails (23.7) (16.9)
Accessible Routes from Site Arrival Points and Within Sites (0.9) 5.2
Standby Power for Platform Lifts (8.5) (8.5)
Power-Operated Doors for Platform Lifts (5.7) (6.3)
Alterations to Existing Elevators (339.0) (339.5)
Platform Lifts in Hotel Guest Rooms and Dwelling Units - -
"LULA" and Private Residence Elevators - -
Van Accessible Parking Spaces 58.8 44.9
Valet Parking Garages 82.5 55.0
Mechanical Access Parking Garages 206.5 153.0
Direct Access Entrances from Parking Structures 7.8 5.9
Passenger Loading Zones 1,292.4 967.2
Parking Spaces 604.0 447.9
Parking Spaces (Signs) (2.6) (1.8)
Passenger Loading Zones (Medical / Long-Term Care) (280.5) (177.1)
Ambulatory Accessible Toilet Compartments 414.8 326.2
Water closet clearance in single-user toilet rooms - out swinging door (898.4) (1,209.3)
Shower Spray Controls 136.8 108.0
Urinals (11.0) (9.3)
Multiple Single-User Toilet Rooms 94.1 95.0
Water closet clearance in single-user toilet rooms - in swinging door (974.7) (982.7)
Water Closet Location and Rear Grab Bar - -
Patient Toilet Rooms (2.1) (1.2)
Drinking Fountains (66.5) (66.6)
Sinks - -
Side Reach (555.0) (734.1)
Sales and Service Counters (NC) 4.7 7.0
Sales and Service Counters (Alt) 85.1 127.7
Washing Machines and Clothes Dryers (technical) (6.3) (6.3)
Washing Machines and Clothes Dryers (Scoping) (1.9) (1.9)
Self-Service Storage Access 25.6 18.2
Limited Access Spaces and Machinery Spaces - -
Operable Parts - -
Bathrooms with vanities and water closet clearance out-swinging doors 1,788.4 1,355.5
Operable Windows 240.0 166.5
Dwelling Units with Communication Features [1991] (13.9) (13.9)
Dwelling Units with Communication Features [UFAS] (3.7) (3.7)
Galley Kitchen Clearances 23.8 18.7
Shower Compartments with Mobility Features 59.8 60.7
Location of Accessible Route to Stages (152.0) (152.0)
Wheelchair Space Overlap in Assembly Areas (318.1) (331.1)
Lawn Seating in Assembly Areas - -
Handrails on Aisle Ramps in Assembly Areas (366.7) (262.3)
Wheelchair Spaces in Assembly Areas 107.1 108.8
Accessible Route to Tiered Dining Areas in Sports Facilities (NC) 6.3 6.6
Accessible Route to Press Boxes 61.9 62.3
Public TTYS (1.7) (1.7)
Public Telephone Volume Controls (6.1) (6.1)
Two-Way Communication Systems at Entrances (9.2) (11.7)
ATMs and Fare Machines (30.5) (37.4)
Assistive Listening Systems (technical) (25.8) (25.8)
Visible Alarms in Alterations to Existing Facilities - -
Detectable Warnings (scoping) 318.0 331.3
Detectable Warnings (technical) - -
Assistive Listening Systems (scoping) 273.9 275.8
Accessible Courtroom Stations - -
Accessible Attorney Areas and Witness Stands (106.3) (106.3)
Raised Courtroom Stations Not for Members of the Public - -
Accessible Route to Exercise Machines and Equipment 967.7 807.8
Accessible Machines and Equipment 1,411.8 1,096.0
Accessible Saunas and Steam Rooms (NC) 192.2 165.8
Accessible Lockers 160.4 127.7
Accessible Dressing Rooms, Fitting Rooms, or Locker Rooms 169.9 126.5
Wheelchair Spaces in Team or Player Seating Areas (0.8) (0.8)
Accessible Route in Court Sport Facilities - -
Accessible Route to Bowling Lanes 132.9 129.1
Shooting Facilities with Firing Positions 260.1 256.3
Primary Accessible Means of Entry to Pools (NC/ALT) 383.6 132.6
Accessible Means of Entry to Wading Pools 221.1 (29.6)
Accessible Means of Entry to Spas 782.5 565.8
Accessible Route for Boating Facilities 6.6 4.7
Accessible Boarding Piers (NC) 6.1 0.8
Accessible Boarding Piers (ALT/BR) - -
Accessible Boat Slips (NC) (0.7) (1.9)
Accessible Boat Slips (Alt/BR) - -
Accessible Route to Fishing Piers 35.6 35.0
Accessible Fishing Piers and Platforms 81.6 71.7
Accessible Route to Golf Courses 292.4 275.4
Accessible Teeing Grounds, Putting Greens, and Weather Stations (Alt/BR) 196.2 184.1
Accessible Teeing Grounds, Putting Greens, and Weather Stations (NC) - -
Accessible Practice Grounds at Driving Ranges 391.5 369.3
Accessible Route to Minigolf Holes 535.1 477.7
Accessible Minigolf Holes 449.9 396.3
Accessible Route to Rides 440.7 391.0
Wheelchair Space or Transfer Seat or Transfer Device 5.6 4.6
Maneuvering Space in Load and Unload Area 14.7 12.3
Signs at Amusement Park rides 4.2 3.4
Accessible Route to Play Components (BR) 14.0 (42.2)
Accessible Play Components (BR) 323.6 240.1
Accessible Route to Play Components (ALT) 133.3 93.8
Accessible Play Components (ALT) 234.7 176.1
Accessible Route to Play Components (NC) (77.1) (93.4)
Accessible Play Components (NC) 98.8 74.7
Roll-In Showers - -
Post Secondary School Multi-Story Dorm Facility (64.0) (64.1)
Mobility Accessible Prison Cell 44.1 47.0
Communication Accessible Prison Cell (5.8) (5.9)
Social Service Establishments – Elevator Access (NC) 6.7 6.7
Social Service Establishments – Clear Floor Space around Beds 105.7 77.5
Accessible Saunas and Steam Rooms (ALT/BR) 179.6 118.8
Primary Accessible Means of Entry to Pools (BR) 39.3 9.8
Housing at Places of Education – Kitchen Turning Space 49.7 43.7
Housing at Places of Education – Kitchen Work Surfaces (0.2) (1.1)
Secondary Accessible Means of Entry into Pools (NC/ALT) 132.9 95.8
Secondary Accessible Means of Entry into Pools (BR) 12.0 6.1
Social Service Establishments – Roll-in Shower (0.1) (0.1)
TOTAL 9,249.98 5,805.63

The second stress test examines the impact of reducing the use time premium. 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. Table 12 below presents results only for those requirements with use values. This analysis shows that reducing the premium for use time by half (i.e., using a use time premium of 0.175 instead of 0.35) lowers total NPV for the rule from $9.2 B to $8.9 B, or less than 4%.

Table 12: Impact on Results of Reduced to Use Time Premium (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Requirement Baseline Use Value = .35NPV (Million $) Alternate Use Value = .175 NPV (Million $)
Ambulatory Accessible Toilet Compartments $414.78 $409.07
Water closet clearance in single-user toilet rooms - out swinging door ($898.43) ($927.69)
Shower Spray Controls $136.79 $98.67
Urinals ($11.03) ($9.23)
Water closet clearance in single-user toilet rooms - in swinging door ($974.75) ($977.63)
Bathrooms with vanities and water closet clearance out-swinging doors $1,788.45 $1,665.19
Galley Kitchen Clearances $23.81 $12.22
Shower Compartments with Mobility Features $59.81 $64.00
Wheelchair Space Overlap in Assembly Areas ($318.10) ($404.57)
Wheelchair Spaces in Assembly Areas $107.15 $108.63
Assistive Listening Systems (technical) ($25.77) ($26.35)
Accessible Exercise Machines and Equipment $1,411.82 $1,395.64
Accessible Fishing Piers and Platforms $81.61 $78.30
Accessible Mini Golf Holes $449.95 $448.23
Accessible Play Components (BR) $323.58 $322.42
Accessible Play Components (ALT) $234.68 $234.37
Accessible Play Components (NC) $98.80 $98.29
Housing at Places of Education – Kitchen Turning Space $49.66 $34.84
Housing at Places of Education – Kitchen Work Surfaces ($0.17) ($0.74)
Total for Entire Rule $9,249.98 $8,921.00

The third stress analysis assesses the impact of reducing the price elasticity of demand for each facility. The results presented in Table 13 show that changing the slope of the demand curve (which is derived, in part, from the elasticity) has only a minor overall impact on consumer surplus. Reducing the elasticities by half (meaning that each reduction in price leads to a smaller change in demand) reduces net benefits to users from $19.2 B to $15.4 B. 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. Only one facility NPV changes from positive to negative: Public Recreational Boating Facilities' NPV declines from the small positive value of $4.6 M to -$1.4 M.

Table 13: Impact on Results of Reduced Demand Elasticity At All Facilities (millions) (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Facility Group (Million$) Results Using Literature Elasticities Results Using Elasticity Estimates Reduced by Half Difference In NPV
Impact to Users NPV Impact to Users NPV Million$ %
Inns $519.2 $499.5 $516.9 $497.3 ($2.3) 0.5%
Hotels $1,232.1 $753.5 $1,225.8 $747.2 ($6.3) 0.8%
Motels $1,834.5 $1,403.1 $1,804.7 $1,373.3 ($29.8) 2.2%
Restaurants $1,742.5 $1,413.8 $1,740.0 $1,411.3 ($2.5) 0.2%
Motion Picture House $8.8 ($169.4) $8.8 ($169.5) ($0.1) 0.0%
Theatre / Concert Hall $25.4 ($145.5) $25.4 ($145.5) ($0.0) 0.0%
Stadiums $18.9 ($10.9) $18.8 ($10.9) ($0.0) -0.2%
Auditoriums $15.8 ($9.6) $15.8 ($9.6) ($0.0) -0.1%
Convention Centers $19.3 $20.1 $19.2 $20.1 ($0.1) 0.3%
Single Level Stores $61.8 ($354.5) $61.8 ($354.5) ($0.0) 0.0%
Shopping Malls $328.0 $280.1 $327.4 $279.5 ($0.6) 0.2%
Indoor Service Establishments $410.8 ($1,758.4) $410.8 ($1,758.4) ($0.0) 0.0%
Offices of Health Care Providers $77.0 ($228.8) $77.0 ($228.8) ($0.0) 0.0%
Hospitals ($1.7) ($26.4) ($1.7) ($26.4) ($0.0) 0.0%
Nursing Homes ($61.5) ($192.9) ($61.5) ($193.0) ($0.1) 0.0%
Terminal (private airports) $0.1 $1.8 $0.1 $1.8 ($0.0) 0.0%
Depots $0.1 $0.1 $0.1 $0.1 ($0.0) 0.2%
Museums, Historical Sites & Libraries $74.8 $68.8 $74.6 $68.6 ($0.2) 0.4%
Parks or zoos $45.7 $42.3 $35.2 $31.7 ($10.5) 33.2%
Amusement Parks $826.9 $734.6 $540.3 $448.0 ($286.5) 64.0%
Nursery schools - Daycare $121.9 ($7.5) $121.7 ($7.6) ($0.1) -1.4%
Elementary Private Schools $67.4 ($29.6) $67.3 ($29.8) ($0.1) -0.5%
Secondary Private Schools $9.2 ($10.6) $9.2 ($10.6) ($0.0) 0.0%
Undergraduate and Postgraduate Private Schools $1,628.0 $1,475.5 $1,618.0 $1,465.5 ($10.0) 0.7%
Ski Facilities $46.0 $45.9 $24.6 $24.5 ($21.4) 87.6%
Homeless Shelter $141.1 $138.5 $139.5 $136.9 ($1.5) 6.1%
Food Banks $16.9 $15.7 $16.9 $15.7 ($0.0) 0.1%
Social Service Establishments $1.5 ($33.2) $1.5 ($33.2) ($0.0) 0.0%
Exercise Facilities $2,461.5 $1,777.8 $1,478.9 $795.2 ($982.6) 123.6%
Swimming pools / Aquatic Centers $2,771.5 $1,380.4 $1,708.1 $317.0 ($1,063.4) 335.5%
Bowling Alleys $134.7 $133.4 $71.9 $70.5 ($62.9) 89.2%
Golf Courses (private with public access) $842.8 $805.4 $482.6 $445.1 ($360.2) 80.9%
Golf Courses (private only) $199.1 $178.4 $114.2 $93.5 ($84.9) 90.8%
Miniature golf courses $1,045.7 $951.4 $603.9 $509.5 ($441.8) 86.7%
Recreational Boating Facilities $16.2 ($1.4) $10.9 ($6.7) ($5.3) -78.9%
Fishing Piers and Platforms $45.0 $41.4 $23.4 $19.9 ($21.5) 108.2%
Shooting Facilities $256.2 $256.8 $131.1 $131.6 ($125.1) 95.1%
Office Buildings $3.5 ($1,036.5) $3.5 ($1,036.5) ($0.0) 0.0%
Elementary Public Schools $282.9 $34.5 $282.6 $34.2 ($0.3) 0.9%
Secondary Public Schools $297.9 $181.7 $297.8 $181.6 ($0.1) 0.1%
Undergraduate, postgraduate public schools $20.9 ($190.5) $20.7 ($190.7) ($0.2) -0.1%
Public Housing $147.2 ($25.5) $140.8 ($31.9) ($6.4) -20.2%
State and Local Judicial Facilities (courthouses) $0.8 ($156.9) $0.8 ($156.9) $0.0 0.0%
State and Local Detention Facilities (jails) $0.0 ($0.2) $0.0 ($0.2) $0.0 0.0%
State and Local Correctional Facilities (prisons) ($7.3) $40.0 ($7.3) $40.0 $0.0 0.0%
Parking Garages $208.4 $203.2 $203.5 $198.3 ($4.9) 2.5%
Self Service Storage Facilities $29.3 $23.0 $29.2 $22.9 ($0.1) 0.6%
Theatre / Concert Halls (public) $0.0 ($0.1) $0.0 ($0.1) ($0.0) 0.0%
Stadiums (public) $48.5 ($35.7) $48.4 ($35.8) ($0.1) -0.1%
Auditoriums (public) $0.7 ($0.6) $0.7 ($0.6) ($0.0) -0.1%
Convention Centers (public) $28.9 $30.2 $28.8 $30.1 ($0.1) 0.3%
Hospitals (public) ($1.4) ($2.7) ($1.4) ($2.7) ($0.0) 0.0%
Nursing Homes (public) ($13.5) ($19.5) ($13.5) ($19.5) ($0.0) -0.1%
Museums, Historical Sites & Libraries (public) $111.2 $99.0 $110.9 $98.7 ($0.4) 0.4%
Parks or zoos (public) $601.9 $418.9 $453.2 $270.1 ($148.8) 55.1%
Homeless Shelter (public) $20.7 $20.3 $20.5 $20.1 ($0.2) 6.1%
Exercise Facilities (public) $35.2 $25.8 $20.8 $11.4 ($14.4) 126.5%
Social Service Establishments (public) $0.6 ($13.7) $0.6 ($13.7) ($0.0) 0.0%
Swimming pools / Aquatic Centers (public) $215.2 $125.5 $130.7 $41.0 ($84.6) 206.3%
Miniature golf courses (public) $29.9 $27.2 $17.3 $14.6 ($12.6) 86.8%
Recreational Boating Facilities (public) $18.3 $4.6 $12.3 ($1.4) ($6.0) -424.8%
Fishing Piers and Platforms (public) $27.0 $26.2 $14.1 $13.3 ($12.9) 96.7%
Office Buildings (public) $9.7 ($93.4) $9.7 ($93.4) ($0.0) 0.0%
Parking Garages (public) $1.7 $1.6 $1.6 $1.6 ($0.0) 2.5%
Golf Courses (public) $89.5 $85.1 $49.0 $44.6 ($40.5) 90.8%
Restaurants (public) $0.0 $0.0 $0.0 $0.0 ($0.0) 0.0%
Amusement Parks (public) $39.7 $38.8 $21.1 $20.2 ($18.6) 92.1%
Total $19,230.9 $9,250.0 $15,359.3 $5,378.4 ($3,871.6) 72.0%

The fourth stress test estimates the impact on total costs and NPV of increasing the assumed alterations rate for existing facilities from once every 40 years to of once every 30 years. The initial estimate on the average amount of time between major renovations was 40 years. A lodging trade association provided alterations data for hotel bathrooms that adjust the alterations rate for those facilities to once every 15 years (see Section 5 for greater detail). Additional data on the average rate of major alterations for other facilities was not found. Table 14 below shows the results of assuming an increased alterations rate. If an average alterations rate of once every 30 years (in between 15 and 40 years) is used, NPV increases from $9.2 B to $9.5 B.

Table 14: Impact on NPV of Increased Rate of Alterations(Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Facility Group (Million$) Results Using 40-year alterations schedule (15-year for inns, hotels, and motels) Results Using 30-year alterations schedule (15-year for inns, hotels, and motels) Change In NPV
Impact to Users Impact to Facilities NPV Impact to Users Impact to Facilities NPV $
Inns $519.2 -$19.7 $499.5 $519.2 -$19.7 $499.5 $0.0
Hotels $1,232.1 ($478.6) $753.5 $1,232.1 ($478.6) $753.5 $0.0
Motels $1,834.5 ($431.4) $1,403.1 $1,834.5 ($431.4) $1,403.1 $0.0
Restaurants $1,742.5 ($328.8) $1,413.8 $2,349.9 ($449.7) $1,900.2 $486.5
Motion Picture House $8.8 ($178.3) ($169.4) $15.1 ($254.3) ($239.2) ($69.8)
Theatre / Concert Hall $25.4 ($170.9) ($145.5) $33.7 ($241.2) ($207.5) ($62.0)
Stadiums $18.9 ($29.8) ($10.9) $24.8 ($57.9) ($33.2) ($22.3)
Auditoriums $15.8 ($25.5) ($9.6) $21.5 ($35.6) ($14.1) ($4.5)
Convention Centers $19.3 $0.9 $20.1 $24.1 $0.9 $25.0 $4.9
Single Level Stores $61.8 ($416.3) ($354.5) $69.2 ($465.7) ($396.5) ($42.0)
Shopping Malls $328.0 ($47.9) $280.1 $198.0 ($27.3) $170.7 ($109.5)
Indoor Service Establishments $410.8 ($2,169.2) ($1,758.4) $577.7 ($3,064.4) ($2,486.7) ($728.3)
Offices of Health Care Providers $77.0 ($305.8) ($228.8) $145.0 ($611.0) ($466.0) ($237.2)
Hospitals ($1.7) ($24.7) ($26.4) ($3.1) ($27.1) ($30.2) ($3.8)
Nursing Homes ($61.5) ($131.5) ($192.9) ($112.7) ($173.8) ($286.6) ($93.6)
Terminal (private airports) $0.1 $1.7 $1.8 $0.1 $1.7 $1.8 $0.0
Depots $0.1 $0.0 $0.1 $0.1 $0.0 $0.1 $0.0
Museums, Historical Sites & Libraries $74.8 ($6.0) $68.8 $108.9 ($8.8) $100.1 $31.2
Parks or zoos $45.7 ($3.5) $42.3 $55.4 ($4.0) $51.3 $9.1
Amusement Parks $826.9 ($92.3) $734.6 $979.3 ($103.1) $876.2 $141.6
Nursery schools - Daycare $121.9 ($129.3) ($7.5) $144.7 ($152.1) ($7.4) $0.1
Elementary Private Schools $67.4 ($97.1) ($29.6) $73.6 ($110.2) ($36.5) ($6.9)
Secondary Private Schools $9.2 ($19.9) ($10.6) $11.7 ($26.0) ($14.3) ($3.7)
Undergraduate and Postgraduate Private Schools $1,628.0 ($152.5) $1,475.5 $1,913.6 ($191.1) $1,722.5 $247.0
Ski Facilities $46.0 ($0.1) $45.9 $59.0 ($0.1) $58.9 $13.0
Homeless Shelter $141.1 ($2.6) $138.5 $181.3 ($4.9) $176.5 $38.0
Food Banks $16.9 ($1.2) $15.7 $22.0 ($1.7) $20.2 $4.5
Social Service Establishments $1.5 ($34.7) ($33.2) $2.1 6.3.1 ($48.8) 6.3.2 ($46.7) 6.3.3 ($13.5)
Exercise Facilities $2,461.5 ($683.7) $1,777.8 $2,711.6 ($732.9) $1,978.7 $200.9
Swimming pools / Aquatic Centers $2,771.5 ($1,391.1) $1,380.4 $3,319.0 ($1,604.3) $1,714.6 $334.2
Bowling Alleys $134.7 ($1.4) $133.4 $135.0 ($1.5) $133.5 $0.2
Golf Courses (private with public access) $842.8 ($37.4) $805.4 $1,022.2 ($46.6) $975.7 $170.3
Golf Courses (private only) $199.1 ($20.7) $178.4 $241.5 ($26.0) $215.4 $37.0
Miniature golf courses $1,045.7 ($94.3) $951.4 $1,222.5 ($102.2) $1,120.3 $168.9
Recreational Boating Facilities $16.2 ($17.6) ($1.4) $19.7 ($20.5) ($0.8) $0.6
Fishing Piers and Platforms $45.0 ($3.6) $41.4 $52.5 ($3.7) $48.8 $7.4
Shooting Facilities $256.2 $0.5 $256.8 $300.1 $0.5 $300.6 $43.9
Office Buildings $3.5 ($1,040.0) ($1,036.5) $5.0 ($1,457.3) ($1,452.4) ($415.9)
Elementary Public Schools $282.9 ($248.3) $34.5 $320.6 ($296.7) $24.0 ($10.6)
Secondary Public Schools $297.9 ($116.1) $181.7 $402.9 ($165.6) $237.3 $55.6
Undergraduate, postgraduate public schools $20.9 ($211.5) ($190.5) $27.1 ($274.2) ($247.0) ($56.5)
Public Housing $147.2 ($172.7) ($25.5) $179.1 ($223.1) ($44.1) ($18.6)
State and Local Judicial Facilities (courthouses) $0.8 ($157.7) ($156.9) $1.1 ($211.3) ($210.2) ($53.4)
State and Local Detention Facilities (jails) $0.0 ($0.2) ($0.2) $0.0 ($0.3) ($0.2) ($0.0)
State and Local Correctional Facilities (prisons) ($7.3) $47.2 $40.0 ($10.0) $65.9 $55.9 $15.9
Parking Garages $208.4 ($5.2) $203.2 $266.4 ($7.8) $258.6 $55.3
Self Service Storage Facilities $29.3 ($6.3) $23.0 $37.8 ($10.4) $27.4 $4.3
Theatre / Concert Halls (public) $0.0 ($0.1) ($0.1) $0.0 ($0.2) ($0.1) ($0.0)
Stadiums (public) $48.5 ($84.2) ($35.7) $66.2 ($168.9) ($102.6) ($66.9)
Auditoriums (public) $0.7 ($1.4) ($0.6) $1.0 ($1.9) ($0.9) ($0.3)
Convention Centers (public) $28.9 $1.3 $30.2 $36.1 $1.4 $37.5 $7.4
Hospitals (public) ($1.4) ($1.3) ($2.7) ($1.8) ($2.7) ($4.5) ($1.8)
Nursing Homes (public) ($13.5) ($6.0) ($19.5) ($17.9) ($9.3) ($27.2) ($7.7)
Museums, Historical Sites & Libraries (public) $111.2 ($12.2) $99.0 $161.9 ($17.9) $144.0 $44.9
Parks or zoos (public) $601.9 ($183.0) $418.9 $752.0 ($230.8) $521.1 $102.2
Homeless Shelter (public) $20.7 ($0.4) $20.3 $26.6 ($0.7) $25.8 $5.6
Exercise Facilities (public) $35.2 ($9.4) $25.8 $45.2 ($11.2) $34.0 $8.2
Social Service Establishments (public) $0.6 ($14.2) ($13.7) $0.8 ($20.0) ($19.2) ($5.5)
Swimming pools / Aquatic Centers (public) $215.2 ($89.7) $125.5 $274.5 ($112.3) $162.3 $36.7
Miniature golf courses (public) $29.9 ($2.7) $27.2 $38.4 ($3.5) $34.9 $7.7
Recreational Boating Facilities (public) $18.3 ($13.7) $4.6 $23.2 ($18.1) $5.1 $0.5
Fishing Piers and Platforms (public) $27.0 ($0.7) $26.2 $34.5 ($0.9) $33.6 $7.4
Office Buildings (public) $9.7 ($103.1) ($93.4) $13.6 ($145.6) ($131.9) ($38.6)
Parking Garages (public) $1.7 ($0.0) $1.6 $2.1 ($0.1) $2.1 $0.4
Golf Courses (public) $89.5 ($4.4) $85.1 $119.8 ($6.4) $113.3 $28.3
Restaurants (public) $0.0 ($0.0) $0.0 $0.1 ($0.0) $0.1 $0.0
Amusement Parks (public) $39.7 ($0.8) $38.8 $50.1 ($1.1) $49.0 $10.2
Total $19,230.9 ($9,981.0) $9,250.0 $22,361.1 ($12,853.9) $9,507.2 $257.2

The fifth stress test examines the relative impact per facility group of including indirect costs (in terms of monetized time) for businesses or governmental entities to examine the new guidelines and determine whether changes are needed to their respective existing facilities. Because the safe harbor protects elements that are already compliant with the 1991 Standards from retrofit obligations, this stress test assumes that only owners or operators of existing facilities with elements affected by the supplemental requirements, such as pools and play areas, would incur such indirect costs. For the facilities with these elements, it is assumed that business or facility owners would spend an average of 4.5 hours reading the new guidelines per element affected by the supplemental requirements and determining whether or not a change would be needed. This time is valued at the average wage rate of all manager occupations in the U.S. ($48.23 per hour). The increase in costs per typical facility with an element subject to the supplemental requirements is shown in the Table 15 below. The Nursery Schools-Daycare facility group has the most significant change in NPV at 225.5% due to the playground elements at these facilities and the large number of facilities of this type.

Table 15: Impact on NPV of Estimated Managerial Costs for Supplemental Requirements at All Facilities (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Facilities With Elements Subject To Supplemental Requirements Supplemental Requirements (#67-112) 2010 Number Of Facilities Cost Per Facility Type Baseline NPV (Mill$) NPV w/ Mngrial Costs (Mill$) % Change In NPV
Hotels 7 15,165 -$3,291,319 $753 $750 -0.4%
Motels 8 21,092 -$4,577,706 $1,403 $1,399 -0.3%
Restaurants 6 566,856 -$123,027,659 $1,656 $1,533 -7.4%
Stadiums 12 444 -$96,377 -$33 -$33 0.3%
Single Level Stores 1 812,456 -$176,331,313 -$397 -$573 44.5%
Shopping Malls 6 10,092 -$2,190,293 $171 $168 -1.3%
Hospitals 12 3,915 -$849,680 -$30 -$31 2.8%
Nursing Homes 1 15,014 -$3,258,592 -$287 -$290 6.1%
Parks or zoos 10 1,327 -$288,011 $51 $51 -0.6%
Amusement Parks 130 543 -$117,843 $876 $876 0.0%
Nursery schools - Daycare 6 76,398 -$16,581,007 -$7 -$24 225.5%
Elementary Private Schools 6 18,275 -$3,966,248 -$37 -$40 10.9%
Secondary Private Schools 61 2,841 -$616,537 -$14 -$15 4.3%
Undergraduate and Postgraduate Private Schools 56 2,574 -$558,636 $1,723 $1,722 0.0%
Homeless Shelter 2 8,715 -$1,891,531 $176 $175 -1.1%
Social Service Establishments 2 66,236 -$14,375,528 -$47 -$61 30.8%
Exercise Facilities 42 32,609 -$7,077,300 $1,979 $1,972 -0.4%
Swimming pools / Aquatic Centers 15 12,368 -$2,684,231 $1,715 $1,712 -0.2%
Bowling Alleys 3 4,688 -$1,017,432 $134 $133 -0.8%
Golf Courses (private with public access) 14 9,485 -$2,058,521 $976 $974 -0.2%
Golf Courses (private only) 17 4,645 -$1,008,226 $215 $214 -0.5%
Miniature golf courses 3 9,475 -$2,056,406 $1,120 $1,118 -0.2%
Recreational Boating Facilities 16 5,198 -$1,128,085 -$1 -$2 145.3%
Fishing Piers and Platforms 2 1,714 -$372,033 $49 $48 -0.8%
Shooting Facilities 1 5,095 -$1,105,833 $301 $300 -0.4%
Elementary Public Schools 6 68,781 -$14,927,783 $24 $9 -62.3%
Secondary Public Schools 94 23,388 -$5,076,014 $237 $232 -2.1%
Undergraduate, postgraduate public schools 87 1,792 -$388,825 -$247 -$247 0.2%
Public Housing 6 27,767 -$6,026,327 -$44 -$50 13.7%
State and Local Judicial Facilities (courthouses) 31 9,458 -$2,052,615 -$210 -$212 6.0%
State and Local Correctional Facilities (prisons) 6 1,244 -$270,022 $56 $56 -0.5%
Stadiums (public) 12 1,333 -$289,353 -$103 -$103 0.3%
Hospitals (public) 12 1,113 -$241,548 -$4 -$5 5.4%
Nursing Homes (public) 1 1,229 -$266,770 -$27 -$27 6.0%
Parks or zoos (public) 10 120,224 -$26,092,852 $521 $495 -5.0%
Homeless Shelter (public) 2 1,302 -$282,643 $26 $26 -1.1%
Exercise Facilities (public) 40 1,196 -$259,539 $34 $34 -0.8%
Social Service Establishments (public) 2 26,940 -$5,847,008 -$19 -$25 30.5%
Swimming pools / Aquatic Centers (public) 13 1,773 -$384,724 $162 $162 -0.2%
Miniature golf courses (public) 3 947 -$205,641 $35 $35 -0.6%
Recreational Boating Facilities (public) 16 7,797 -$1,692,128 $5 $3 -33.4%
Fishing Piers and Platforms (public) 2 1,714 -$372,033 $34 $33 -1.1%
Golf Courses (public) 14 2,640 -$572,973 $113 $113 -0.5%
Restaurants (public) 6 7 -$1,520 $0 $0 -2.8%
Amusement Parks (public) 130 11 -$2,411 $49 $49 -0.005%
Total for Facilities with Supplemental Requirement Elements -$435,779,078 $13,086 $12,651 -3.3%

Lastly, the sixth stress test examines the impact of raising the estimated percentage of the United States population that would benefit from the increase in accessibility as a result of the Final Rules. The primary analysis uses estimates of population by type of disability based on data collected by the United States Census Bureau (see Appendix 4E). Many have argued, though, that the definitions used by the Census Bureau are too narrow and do not adequately capture the number of persons whose mobility, sight, hearing or other characteristics limit their accessibility to facilities in some way. Because no consensus estimates were found to adjust the Census Bureau population estimates, an analysis was conducted to evaluate the level of impact on NPV if the estimates of population by category of disability or limitation were actually one-third higher than Census Bureau estimates. Table 16 below shows that increasing by one-third the estimated number of persons with disabilities assumed to benefit from the Final Rules results in a net impact to users that is 28% higher, and an NPV that is 57% greater as compared to the results under the primary analysis.

Table 16: Impact on NPV of Increased Estimates of Persons with Disabilities (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

  Primary Estimates (millions $) Estimates If Persons With Disabilities Higher by 1/3 % Increase
NPV for Entire Rule $9.25 $14.56 57.4%
Net Impact to Users $19.23 $24.54 27.6%

Turning to the second set of sensitivity analyses addressed in this section, these sensitivity-type studies examine the relative significance of the variability (risk ranges) of inputs for each of "top three" requirements in terms of the largest negative and positive NPVs respectively. The three requirements with the largest positive NPVs and largest negative NPVs, respectively, were selected because they can be characterized as key drivers of the overall costs and benefits of the Final Rules. The charts below (Figures 18 – 23) present the driving factors behind the risk range for the NPV estimates for each of these six requirements. These charts indicate, for each respective requirement, the level of risk attributable to those variables with the most significant impact on the overall NPV for that requirement. Those factors that explain the largest portion of the risk are the ones that will have the largest impact on the overall NPV.

Three Requirements With Highest Negative NPVs Under the Primary Baseline

The Water Closet Clearance in Single-User Toilet Rooms with In-Swinging Doors requirement (Req. # 32) has the highest negative NPV (-$975 million) of the requirements assessed in the Final RIA. Figure 11 illustrates the relative impact of the variability around some of the key inputs for this requirement's NPV. The estimated range (which is incorporated to account for uncertainty regarding the actual figure) for the "likelihood of occurrence" input is the most significant driver of the range in results for the requirement's NPV. The estimated range for alterations costs has the second-most significant impact on the NPV range for this requirement. The estimated range of the input for "frequency of occurrence" at single-level stores is the third-most important driver of the NPV range due to the large number of single-level stores.

Figure 18: Distribution of Sensitivities for Requirement 32: Water Closet Clearance in Single-User Toilet Rooms – In-Swinging Doors

Figure 18: Distribution of Sensitivities for Requirement 32: Water Closet Clearance in Single-User Toilet Rooms – In-Swinging Doors

The Water Closet Clearance in Single-User Toilet Rooms with Out-Swinging Doors requirement (Req. # 28) has the second highest negative NPV (-$898.4 million) under the primary baseline. Figure 12 illustrates the relative impact of the variability around some of the key inputs influencing this requirement's NPV. The estimated range for the "access time saved" input is the most significant driver for the range of results for the requirement's NPV, followed by the estimated range for the "likelihood of benefiting from use of the element" input.

Figure 19: Distribution of Sensitivities for Requirement 28: Water Closet Clearance in Single-User Toilet Rooms – Out-Swinging door

Figure 19: Distribution of Sensitivities for Requirement 28: Water Closet Clearance in Single-User Toilet Rooms – Out-Swinging door

The requirement with the third highest negative NPV (-$808.4 million) under the primary baseline is the requirement for Stairs (Alt/BR) (req. # 10). Figure 20 illustrates the relative impact of the variability around some of the key inputs driving the NPV for this requirement. The estimated range for the "likelihood of occurrence" parameter is the most significant driver of requirement's NPV. The estimated range for alterations costs has the second-most significant impact on NPV range. The estimated range for O&M costs is the third-most important driver of NPV, followed closely by the estimated range for the "frequency of occurrence in office buildings" parameter due to the high number of facilities in this facility group.

Figure 20: Distribution of Sensitivities for Requirement 10: Stairs (ALT/BR)

Figure 20: Distribution of Sensitivities for Requirement 10: Stairs (ALT/BR)

Three Requirements With Highest Positive NPVs Under the Primary Baseline

The requirement with the largest positive NPV ($1,788.5 million) under the primary baseline of all requirements assessed in the Final RIA is the Bathrooms in Accessible Guest Rooms (vanities and water closet clearances) requirement (Req. # 45). Figure 21 illustrates the relative impact of the variability around some of the key inputs that serve as the driving forces behind the NPV for this requirement. The estimated range for the "access time savings per use" input is the most significant driver of this requirement's NPV range, followed by the estimated ranges for the "frequency of occurrence in inns" and the "likelihood of benefiting" inputs respectively.

Figure 21: Distribution of Sensitivities for Requirement 45: Bathrooms In Accessible Guest Rooms (vanities and water closet clearances)

Figure 21: Distribution of Sensitivities for Requirement 45: Bathrooms In Accessible Guest Rooms (vanities and water closet clearances)

The Accessible Exercise Machines and Equipment requirement for facilities with exercise equipment (Req. # 71) has the second-highest NPV ($1,411.8 million) under the primary baseline. Figure 22 illustrates the relative impact of various assumptions on the NPV for the Accessible Exercise Machines and Equipment requirement. The estimated range for the "likelihood of benefiting" input is the most significant driver of the requirement's NPV range, followed by the estimated range for the "access time savings" parameter.

Figure 22: Distribution of Sensitivities for Requirement 71: Accessible Exercise Machines and Equipment

Figure 22: Distribution of Sensitivities for Requirement 71: Accessible Exercise Machines and Equipment

The Passenger Loading Zones requirement (Req. # 23) has the third-highest NPV ($1,292.4 million) under the primary baseline. Figure 23 illustrates the relative impact of various assumptions on NPV for this requirement. The estimated range for the "likelihood of benefitting" input is the most significant driver of this requirement's NPV range, followed by the range of estimates around the "frequency of use" and "likelihood of occurrence" parameters.

Figure 23: Distribution of Sensitivities for Requirement 23: Passenger Loading Zones

Figure 23: Distribution of Sensitivities for Requirement 23: Passenger Loading Zones

In sum, 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 cost estimate ranges, which were developed separately at high, medium, and low for each requirement (and at new construction, alterations, and barrier removal).

6.4 Changes in Facility Visits

The increased accessibility of facilities due to the requirements should generate additional visits to those facilities by persons with disabilities (and presumably by additional persons without disabilities who might visit facilities together with persons with disabilities as a group, such as a family at a restaurant). The increase in demand generated by the decrease in price is presented in Section 3.2 (see Figure 3).Thus, while facilities incur some costs to become in compliance with the Final Rules, many are also expected to experience greater activity than would otherwise have been the case. Overall, facilities are expected to experience 0.5% more visits by persons with disabilities, or 75 million visits. The facilities likely to experience the largest increases are the newly scoped recreational facilities (e.g., Aquatic Centers, Exercise Facilities, Miniature Golf Courses), as well as Public Housing.

Table 17: Estimated Change in the Number of Facility Visits (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Facility Group Total Number of Facilities (2010) Number of Small Entity Facilities (2010) % of Total Facilities that are Small Entity Facilities Sales (or Expenditures) per Typical Facility (All sizes) ($) Estimated Sales (or Expenditures) per Small Entity Facility 2007 ($) Average Sales (or Expenditures) per Small Entity as Percent of Average Sales for All Sizes
Private Facilities (Owned or Operated by Small Businesses or Small Nonprofit Organizations)
Inns 16,953 16,614 98% $276,669 $276,669 100%
Hotels 15,165 4,095 27% $11,453,808 $1,259,919 11%
Motels 21,092 20,670 98% $504,294 $504,294 100%
Restaurants 566,856 442,148 78% $880,642 $308,225 35%
Motion Picture House 4,971 2,287 46% $2,419,713 $314,563 13%
Theatre / Concert Hall 9,348 8,974 96% $1,454,100 $348,984 24%
Auditoriums 2,676 1,980 74% $5,994,548 $659,400 11%
Single Level Stores 812,456 552,470 68% $3,526,173 $352,617 10%
Shopping Malls[1] 10,092 8,881 88% $3,880,720 $3,880,720 100%
Indoor Service Establishments 3,857,022 1,465,669 38% $1,620,570 $372,731 23%
Offices of Health Care Providers 549,803 483,826 88% $1,403,290 $435,020 31%
Hospitals 3,915 1,057 27% $164,921,961 $1,649,220 1%
Nursing Homes 15,014 6,306 42% $11,515,088 $1,381,811 12%
Museums, Historical Sites & Libraries 4,766 4,337 91% $1,912,720 $401,671 21%
Parks or zoos 1,327 1,115 84% $2,910,019 $582,004 20%
Amusement Parks 543 434 80% $29,606,564 $2,368,525 8%
Nursery schools - Daycare 76,398 65,702 86% $420,833 $164,125 39%
Elementary Private Schools 18,275 15,168 83% $1,616,245 $468,711 29%
Secondary Private Schools 2,841 2,358 83% $3,024,170 $877,009 29%
Ski Facilities 403 310 77% $5,830,410 $641,345 11%
Homeless Shelter 8,715 7,757 89% $1,629,925 $342,284 21%
Food Banks 4,357 3,181 73% $1,480,257 $370,064 25%
Social Service Establishments 66,236 49,015 74% $1,242,276 $347,837 28%
Exercise Facilities 32,609 29,674 91% $839,372 $268,599 32%
Aquatic Centers /Swimming Pools 12,368 11,997 97% $420,073 $189,033 45%
Bowling Alleys 4,688 4,125 88% $687,018 $295,418 43%
Golf Courses (private public access) 9,485 8,441 89% $2,335,087 $863,982 37%
Golf Courses (private only) 4,645 4,134 89% $1,452,612 $537,467 37%
Miniature golf courses 9,475 9,096 96% $293,107 $111,381 38%
Recreational Boating Facilities 5,198 4,990 96% $826,080 $710,429 86%
Shooting Facilities 5,095 4,891 96% $828,387 $712,413 86%
Parking Garages 13,377 3,077 23% $694,211 $270,742 39%
Self Service Storage Facilities 14,418 10,814 75% $647,296 $608,458 94%
Public Facilities (Owned or Operated by Small Governmental Jurisdictions)
Elementary Public Schools 68,781 19,946 29% $2,871,139 $344,537 12%
Secondary Public Schools 23,388 6,549 28% $11,109,976 $999,898 9%
Public Housing 27,767 7,219 26% $540,120 $442,899 82%
State and Local Judicial Facilities (courthouses) 9,458 2,554 27% $528,720 $269,647 51%
State and Local Correctional Facilities (prisons) 1,244 336 27% $12,170,556 $4,746,517 39%
Hospitals (public) 1,113 300 27% $33,947,412 $33,947,412 100%
Parks or zoos (public) 120,224 32,461 27% $218,530 $209,788 96%
Office Buildings (public) 74,846 19,460 26% $112,487 $112,487 100%

6.5 Impacts Not Estimated in the Primary Analysis

In addition to the monetized benefits presented above, additional benefits are likely to result from the new standards. Many of these benefits are more difficult to quantify. Among the potential benefits that have been discussed by researchers and advocates are: reduced administrative costs due to harmonized guidelines; increased business opportunities; increased social development; and improved health benefits.[6] For example, the Final Rules will substantially increase accessibility at newly scoped facilities like recreational facilities and judicial facilities, which previously had been very difficult for persons with disabilities to access but should now give them the same opportunities for recreational enjoyment and more equitable judicial facility experiences.

The range of potential benefits likely to accrue with increased accessibility can theoretically be organized into those that result from direct use of the accessibility improvement and those that are not related directly to such use. Use-related benefits include thoseaccruing to individuals with disabilities, including time savings, quality of life enhancement, and safety, as well as those accruing to those without disabilities who may also make use of the accommodations. A typical example of use benefits to non-disabled populations is the use of expanded bathroom stalls by families with children, which may enhance their comfort and convenience.

Non-use benefits include cross-sector effects (savings arising from reduced social service agency activity as persons are more independent) and third-party employment effects. Other non-use benefits include option/insurance values (the value persons without disabilities derive from the "option" of using accessible features should they need to in the future) and existence values (the benefit that individuals get from the mere existence of a good, service, or resource). Figure 27 presents a preliminary framework for organizing many of the benefits of increased accessibility by use and non-use categories.

Figure 24: Framework for Accounting for All Benefits Resulting from Accessibility Improvements

Figure 24: Framework for Accounting for All Benefits Resulting from Accessibility Improvements

This Final RIA, tasked to measure those costs and benefits of the Rule which can be monetized, is necessarily limited in its capacity to confidently place a robust value on many of the benefits noted here. Most will agree that the psychological and social impacts of the ability of persons with disabilities to fully participate in public and commercial activities without discrimination, fear of embarrassment, or unequal access has value; the challenge is to put a dollar figure on it in terms of economic value (i.e., in of terms of people's willingness to pay for such benefits or their willingness to be compensated to go without them). Similarly, the value that a society places on civil rights is a complex issue, not likely to be easily measured in terms of economic value. Nevertheless, a value of this Rule to society is that it advances civil rights. The RIA can attempt to measure the benefits that arise from improved time usage by persons with disabilities, but cannot adequately assess all the psychological and social benefits of the Rule. Thus, the benefits measured in the Final RIA are necessarily less than those actually bestowed upon society. Therefore, in the main cost-benefit analysis of this rule, this RIA quantifies only a subset of the user benefits. Figure 25 highlights those benefits that are quantified in the primary estimation of this analysis. (Preliminary estimates for avoided stigmatic harm are utilized in the Threshold Analysis, Section 1.6).

Figure 25: Quantified and Non-quantified Benefits within the Accounting Framework

Figure 25: Quantified and Non-quantified Benefits within the Accounting Framework

In addition to benefits that cannot reasonably be quantified or monetized, there may be negative consequences and costs that fall into this category as well. The absence of a quantitative assessment of such costs in the formal regulatory analysis is not meant to minimize their importance to affected entities: rather, it is to acknowledge the inherent difficulty in their estimation. Areas where the Department believes entities may incur costs that are not monetized in the formal analysis include, but may not be limited to, the following:

Costs from deferring or foregoing alterations. Entities covered by the final rules may choose to delay otherwise desired alterations to their facilities due to the increased incremental costs imposed by compliance with the new rules' requirements. This may lead to facility deterioration and loss in the value of such facilities. In extreme cases, the costs of complying with the rules' requirements may lead some entities to opt to not build certain facilities at all. For example, the Department estimates that the incremental costs of building a new wading pool associated with the final rules will increase by about $142,500, on average. Some facilities may opt to not build such pools to avoid incurring this increased cost.

Loss of productive space while modifying an existing facility. During complex alterations where moving walls or plumbing systems will be necessary to comply with the final rules, productive space may be unavailable until the alterations are complete. For example, a hotel altering its bathrooms to comply with the final rules will be unable to allow guests to occupy these rooms while construction activities are underway, and thus the hotel may forgo revenue from these rooms during this time. While the amount of time to perform alterations varies significantly, the costs of unavailable, lost space could be high in certain cases especially if space is already limited or if an entity or facility is located in an area where space is of particular high value (e.g., New York or San Francisco).

Change in use of non-productive space. Some requirements may necessitate a change in the use of space which is not directly used to generate sales or revenue but which may add to the appeal or aesthetics of a particular facility and, thus, indirectly affect business volume. This can be described as a ‘repurposing’ of non-productive space. For example, in hotels such spaces may include lobbies, hallways, publically-available restrooms, or other spaces which, while not available for rental by guests, may nonetheless add value to the overall experience and appeal of the facility. If a requirement in the Final Rules necessitates that some of the space which previously served as the lobby (or hallway) must now be used to comply with requirements governing single-user toilet rooms, there may be a ‘cost’ to the facility if the business value of that space is greater as part of the lobby than as part of an ADA-compliant single-user toilet room. No data was found regarding what the potential incremental value of such changes in non-productive space might be; consequently, the speculative (and indirect) cost of such repurposing of non-productive space is not estimated in the Final RIA. This regulatory analysis does, however, provide a quantitative assessment of the value of changes in productive space (i.e., space changes expected to have a direct impact on sales or revenue) that are attributable to requirements in the Final Rules. See Final RIA §3.1.3.

Administrative/Legal Fees. Another type of cost to entities that is not monetized in the formal analysis is legal fees to determine what, if anything, a facility needs to do in order to comply with the new rules or to respond to lawsuits. Likewise, covered entities may need to retain the services of engineers, architects, or other consultants to determine what modifications to their facilities are needed to comply with the new requirements. The Department has not quantified the costs of retaining the services of these kinds of experts. Several commenters indicated that entities will incur increased legal costs because the requirements are changing for the first time since 1991. Since litigation risk could increase, entities could spend more on legal fees than in the past.

Reduction in facility value and losses to individuals without disabilities due to the new accessibility requirements. It is possible that some changes made by entities to their facilities in order to comply with the new requirements may result in fewer individuals without disabilities using such facilities (because of less enjoyment) and may create a disadvantage for individuals without disabilities, even though the change might increase accessibility for individuals with disabilities. For example, the rules' requirements for wading pools might decrease the value of the pool for the entity that owns it (because the rules' requirements for a sloped entry might make the pool too shallow) due to fewer individuals using it. Similarly, several commenters from the miniature golf industry expressed concern that it would be difficult to comply with the regulations for accessible holes without significantly degrading the experience for other users. Finally, with respect to costs to individuals who do not have disabilities, a very tall person, for example, may be inconvenienced by having to reach further for a lowered light switch.

6.5.1 Use Benefits Not Estimated in Primary Analysis Accruing to Persons With Disabilities

There are benefits to persons with disabilities that would arise from improved access due to the Final Rules in terms of an overall improved sense of well-being that comes from the belief that places of public accommodation are generally accessible, as well as improved individual experiences.

Some of the most frequently cited qualitative benefits of increased access highlighted by advocacy groups and individuals within the disability community are the increase in personal sense of dignity that arises from increased access and the decline in possibly humiliating incidents due to accessibility barriers. Struggling to join classmates on a stage, to use a bathroom with too little clearance, or to visit a swimming pool all negatively affect a person's sense of independence. In some instances, struggling in a bathroom or to get on a stage for a graduation can lead to humiliating accidents, derisive comments, or just embarrassment. The impact of such incidents can be temporary – such as a period of embarrassment – or more long-term, such as in the case of a student who drops participation in band because he/she is always embarrassed about being unable to get on stage. These humiliations, together with feelings of being "stigmatized . . . as different or inferior" from being relegated to use other, noticeably less comfortable or pleasant elements of a facility (such as a bathroom instead of a kitchen sink for rinsing a coffee mug at work), all have a negative impact on persons with disabilities.[7]

Reversing the problems outlined above can lead to other benefits. Increased accessibility may well lead to decreased isolation among some persons with disabilities. It has been noted by commenters to the NPRMs that limits to accessibility at some types of facilities, particularly recreational facilities, lead some persons with disabilities to venture out to those facilities less frequently, further separating them from the larger community. As barriers to access are lowered, it becomes easier to access facilities, more persons with disabilities visit entities outside the home, and social interaction increases. Society values the ability for all members to fully interact with each other, even if adequate measures of its value have not yet been developed.

Similarly, increased accessibility may lead to more effective participation of persons with disabilities within the legal system. Some have raised the possibility that jurors may unconsciously view the testimony of witnesses who need additional assistance to the witness stand differently from that of other witnesses. Similarly, the arguments of a lawyer or the culpability of a defendant may be viewed somewhat differently by some persons if that lawyer or defendant cannot independently access the traditional witness stand or attorney areas and either needs to be helped to these places by another person or struggles to reach the place. If any jurors view such witnesses, attorneys, or others before the court differently, just because of their difficulty accessing a place in the courtroom, then there is the possibility that decisions could be affected. Increased participation and decreased humiliation or stigmatization while arguing a case or testifying may well help Justice be blind, so to speak.

There are additional health and safety benefits likely to follow from the Rules. Increased access to play areas (for children) and recreational facilities such as gyms (for adults) provide improved health benefits.[8] Since there may be an overlap with other opportunities for exercise,[9] this makes the actual health impact of the new requirements difficult to quantify. Safety benefits from the Rules range from those due to explicit safety-focused changes, such as those relating to alterations of stairs (to ensure easier and safer egress), to less obvious benefits such as the decreased likelihood of falls by persons of short stature needing to stand on unsteady surfaces to reach a hotel thermostat or other controls. The totality of possible accidents avoided by the new Rules could be substantial, but is difficult to assess.[10]

Additionally, there is the possibility that increased access to educational facilities could lead to improved academic performance among children with disabilities, in turn leading to greater lifetime income. Such impacts would have an economic impact over time, but are difficult to isolate and predict.

6.5.2 Use Benefits Not Estimated in Primary Analysis Accruing to Persons Without Disabilities

Improved accessibility can affect more than just the Rule's target population; persons without disabilities may also benefit from many of the requirements. Even though the requirements were not designed to benefit persons without disabilities, any time savings experienced or easier access to a facility is also a benefit that should properly be attributed to that change in accessibility. Curb cuts in sidewalks make life easier for those using wheeled suitcases or pushing a baby stroller. For people with a lot of luggage or a need to change clothes, the larger bathroom stalls can be a highly valued commodity. A ramp into a pool can allow a child (or adult) with a fear of water to ease into that pool. Safety features such as particular detectable warning signs may alert distracted persons without disabilities more quickly in the case of an emergency. All are examples of "unintended' positive impacts of the Rules to people the Rules were not intended to help. And ideally, all should be part of the calculus of the benefits to society of the Rules.

Additionally, evidence supports the notion of children both with and without disabilities benefiting from interaction with one another.[11] There will likely 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.

And finally, any impacts on judicial decisions that arise due to improve accessibility and decreased stigmatization in judicial facilities impacts all persons without disabilities as well; citizens place value on a better working judicial system.

6.5.3 Non-Use Benefits Not Estimated in Primary Analysis

There are additional benefits to society that arise from improved accessibility, even if not directly generated from the use of the facility or requirement at the moment. For instance, cross-sector benefits may occur from resource savings arising from reduced social service agency outlays when people are able to access centralized points of service delivery rather than receiving home-based care. Home-based and other social services may include home health care visits and welfare benefits. Third party employment effects can arise when enhanced accessibility results in increasing rates of consumption by disabled and/or non-disabled populations, which in turn results in reduced unemployment.

Two additional forms of benefits are discussed less often, let alone quantified: insurance and existence values. Option value is the value that people with and without disabilities derive from the option of using accessible facilities at some point in the future. Like insurance, people derive benefit from the knowledge that the option to use the accessible facility exists, even if it ultimately goes unused. 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. For example, the 2000 Census found that 41.9% of adults 65 years and older identified themselves as having a disability. Census Bureau figures, moreover, project that the number of people 65 and older will more than double between 2000 and 2030 – from 35 million to 71.5 million. 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.

Existence value is the benefit that individuals get from the plain existence of a good, service, or resource – in this case, accessibility. It can also be described as 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. In other words, people value living in a country that affords protections to persons with disabilities, whether or not they themselves are directly or indirectly affected. 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,[12] 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 Final Rules, it is unclear whether they will stand long enough to accumulate substantial bequest valuations.

Feelings of empathy or 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 Final Rules. However, it is difficult to measure and even more difficult to separate from other existence value benefits, like altruism, which risks double-counting.[13]

6.5.4 Other Benefits

Other benefits more specific to the manner of implementation and coordination may also arise due to these Rules. These benefits reflect more the effectiveness of policy management and implementation as opposed to benefits inherent in the existence of accessibility itself; in other words they are the product of the process of improving accessibility, not of having better accessibility, and are thus not included in the above framework. Substantial effort was taken in the development of the guidelines upon which the Final Rules are 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 Final Rules represent essentially one set of requirements that eliminates confusion and unintentional failure to meet standards while reducing administrative costs associated with determining the exact requirements. The Final Rules will also make it easier for State and local codes to be certified as meeting or exceeding Federal standards.

Employees with disabilities will also benefit from the Final Rules. Employees of the establishments in compliance with the Final Rules 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 evaluate the benefits per employee per facility.

6.6 Threshold Analysis

Given that the range of possible NPV values for the entire Final Rules are unlikely to be less than zero (see Section 6), the foregoing discussion of unquantified benefits has greatest potential impact on particular requirements with negative NPVs.[14] 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.

To gain additional perspective on the full range of benefits, this RIA includes several analyses in a Threshold Analysis. In cases where quantitatively measured costs exceed the quantitatively measured benefits by $100 million or more over the life of the rule, the "threshold value" is the value that society would need to assign to the unquantified benefits to "balance the ledger" (to balance benefits with costs). This threshold analysis is applied in relation to the value of stigmatic harm, safety and insurance value for several requirements, and as well as an annualized estimate over 54 years (after which those last facilities built before the expected new rule with safe harbor would likely be complete replaced) for the two requirements with the largest negative NPVs (Water closet clearance in single-user toilet rooms - out swinging door and Water closet clearance in single-user toilet rooms - in swinging door).

The requirements relating the water closet clearances are among the most costly (in monetary terms) of the new provisions. Although the monetized costs of these requirements substantially exceed the monetized benefits, the benefits that have not been monetized (avoiding stigma and humiliation, protecting safety, and enhancing independence) are expected to be quite high. The added clearance ensures that wheelchair users can effect a side transfer, which may often obviate the need for obtaining the assistance of another person to engage in what is, for most people, among the most private of activities.

We estimate that the costs of the requirement as applied to out-swinging doors will exceed the monetized benefits by $454 million, which when annualized over 54 years equals a net cost of approximately $32.6 million a year.[15]

We estimate that people with the relevant disabilities will use a newly accessible single-user toilet room with an out-swinging door approximately 677 million times per year. Dividing the $32.6 million annual cost by the 677 million annual uses, we conclude that for the costs and benefits to break even in this context, people with the relevant disabilities will have to value safety, independence, and the avoidance of stigma and humiliation at just under 5 cents per use.

There are substantially fewer single-user toilet rooms with in-swinging doors, and substantially fewer people with disabilities will benefit from making those rooms accessible. And the alterations costs to make a single-user toilet room with an in-swinging door accessible are substantially higher (because of the space taken up by the door) than the equivalent costs of making a room with an out-swinging door accessible. Thus, we calculate that the costs of applying the toilet room accessibility standard to rooms with in-swinging doors will exceed the monetized benefits of doing so by $266.3 million over the life of the regulation, or approximately $19.14 million per year when annualized over 54 years.

We estimate that people with the relevant disabilities will use a newly accessible single-user toilet room with an in-swinging door approximately 8.7 million times per year. Dividing the $19.14 million annual cost by the 8.7 million annual uses, we conclude that for the costs and benefits to break even in this context, people with the relevant disabilities will have to value safety, independence, and the avoidance of stigma and humiliation at approximately $2.20 per use.

6.6.1 Value of Stigmatic Harm

The threshold analysis presented here is applied using an estimate on the value of stigmatic harm, safety benefits (for some requirements) and insurance value. In other words, the analysis seeks to estimate by how much society would need to value reduced stigmatic harm, fewer injuries and the option value of using the increased accessibility in the future in order to balance benefits with costs. For purposes of the threshold value, the value of eliminating stigmatic harm may be inferred from studies and analysis of behavior associated with transit use. Similar to values that are applied in the main cost-benefit analysis related to the quality of the trip, additional insight may be gained from studies that evaluated the likelihood of using segregated vehicles compared to integrated vehicles. For instance, by observing the proportion of persons with disabilities who elect to use adapted transit when dial-a-ride is available at equal or lesser fare and better time costs, their preference for transit can be attributed to its public availability. In other words, the proportion of people that choose to take integrated transportation service as opposed to segregated service suggests an interest in avoiding the stigma of being disabled.

Studies collect information about the proportion of persons with disabilities who use segregated dial-a-ride service when regular service is available. One study found that approximately 80% of persons with disabilities elected to use dial-a-ride; in other words, while their motivations are certainly not definitively known, 20% of users may have chosen regular service to avoid stigmatic harm, or at least part of their rationale could have included this aspect of value.

This proportion can be converted to a weight on the value of time (similar to quality of time adjustments related to access time) for use in the threshold analysis. The equivalent weight would be computed from the proportion's inverse value, or [1/(proportion of dial-a-ride users)]. While this conversion formula may be overly simplistic, the rationale is consistent with theory. For example, when the proportion of dial-a-ride users is 100%, there is no value of stigmatic harm. At the opposite extreme, if no persons with disabilities choose dial-a-ride, the potential for significant stigmatic harm would likely be part of the reason for this choice. For our example of a user population of 80%, the weight on the value of time to avoid stigmatic harm is 1.25, or 25% above the normal value of time.

Adding an additional factor to the value of time saved by improved accessibility that accounts for the avoided stigmatic harm will increase benefits for all requirements that are more stringent, but will also increase the disbenefits that arise from relaxed requirements. Since more stringent requirements outweigh less stringent requirements in this rule, the overall impact of incorporating the avoidance of stigmatic harm would be to increase the overall net benefits of the rule.

Based on the above, an estimated premium of 0.25 for avoiding stigmatic harm can be applied to the estimation (this premium was not included in the primary analysis partly because the research behind this estimation is not as extensive as the research behind estimates of premiums for travel comfort). The effect of this premium on the negative NPVs is best calculated on the IBC-specific NPV (in which costs and benefits were adjusted according to a state-by-state review of whether the States/counties had adopted that specific requirement out of the IBC), where available. Thus, for the four more stringent requirements which have individual IBC-specific NPVs that are negative by at least $100 million, incorporating the avoidance for stigmatic harm into the benefits calculations shrinks the State-IBC Specific NPVs from $1.0 B to $0.8 B.

Table 18: Impact of 0.25 Premiums on Value of Time for Avoiding Stigmatic Harm for Select Requirements (million $) (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Number Requirement NPV, Baseline of 1991 Standards, Safe Harbor, 50% Readily Achievable, 7% discount rate % of All Facilities Covered by Individual State Adoption of IBC NPV Using State-Specific IBC for Baseline NPV Using State-Specific IBC for Baseline and Including .25 Premium on Time for Avoided Stigmatic Harm
16 Alterations to Existing Elevators -$339.0 70% -$102 -$102
28 Water Closet Clearance in Single-User Toilet Rooms – Out-Swinging Doors -$898.4 46% -$454 -$316
32 Water Closet Clearance in Single-User Toilet Rooms – In-Swinging Doors -$974.7 72% -$266 -$271
37 Side Reach -$555.0 72% -$153 -$105
Total -$975 -$794

A ‘threshold premium’ on the value of time can be calculated for each of these individual requirements. This "threshold premium' is the premium required on the value of time in order to shift the NPV for that individual requirement to zero. In other words, this premium represents how many more people would value avoiding the stigma or embarrassment that the new requirement addresses. For two of these requirements – Water Closet Clearance in Single-User Toilet Rooms With Out-Swinging Door (Req. # 28) and Side Reach (Req. # 37) the threshold premium would only need to be 1.4 and 1.5 respectively for their NPVs to be equal to zero using a requirement-specific alternate IBC/ANSI baseline. To put these stigmatic threshold premiums into perspective, the 1.4 threshold premium for the water closet clearance requirement for single-user toilet rooms with out-swinging doors means that the negative NPV for this requirement would be reduced to zero if a person with a disability who needed to use the restroom at a shopping mall valued avoiding stigmatic harm while accessing the mall's single-user toilet room by at little as 16 cents.[16]

Table 19: Threshold Premium for Select Requirements (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Number Requirements Expected NPV in Main Analysis (million$) State-IBC Specific NPV (million$) Avoided Stigmatic Harm Threshold Premium* NPV at Threshold
16 Alterations to Existing Elevators -$339.0 -$102 220.7 $0.0
28 Water Closet Clearance in Single-User Toilet Rooms – Out-Swinging Doors -$898.4 -$454 1.4 $0.0
32 Water Closet Clearance in Single-User Toilet Rooms – In-Swinging Doors -$974.7 -$266 46.9 $0.0
37 Side Reach -$555.0 -$153 1.5 $0.0
*Premium for stigmatic harm (applied to all requirements) which would result in an NPV of zero for the requirements.

As noted above, promulgation of the final rules would also likely generate many other substantial unquantified benefits aside from avoidance of stigmatic harm. For persons with disabilities, these additional benefits might well include avoided humiliation (i.e., embarrassment which goes beyond the general desire to avoid "standing out" as a person with a disability) and strengthened safety measures. Persons without disabilities may also experience benefits from believing that the final will improve access/decrease discrimination encountered by persons with disabilities, or by placing value on the "insurance" of improved accessibility for their potential use in the future if needed.

Another threshold analysis contains two calculations to explore the potential value significance of these additional – and in relation to the same four requirements. The first (Scenario A) estimates the average monetary value that persons with the types of disabilities expected to benefit from the improved access generated by each of these requirement must place per facility visit on avoiding humiliation and/or increased safety in order for the NPV for each respective requirement to equal zero under a requirement-specific alternate IBC/ANSI baseline. (These figures are calculated by dividing the state-specific NPV by the number of visit to facilities with these elements by persons with the targeted disability over a fifteen year period, after which new rules are expected). Under this methodology, for three of these four requirements, persons with disabilities need place a value of less than 1cent on the benefits of avoided humiliation and/or improved safety (or any other non-monetized benefits) on each visit to facilities with elements affected by these requirements in order to make each requirements' respective NPVs equal zero.

The second threshold estimate, by contrast, calculates the average monetary value each American (on a per capita basis) would need to place annually (over a fifteen year period) on the "existence" of improved accessibility for persons with disabilities (or the "insurance" of improved accessibility for their own potential use in the future) in order for the NPVs for each respective requirement to equal zero. Under this methodology, if Americans on average placed an "existence" value and/or "insurance" value of between 2 cents on the low end to 7 cents on the high end per requirement, then the NPVs for each of these requirements would be zero. Note that this later calculation assumes no added value of avoided humiliation, of increase safety and increased independence.

Table 20: Additional Threshold Analyses (Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for Baseline, 7% Discount Rate)

Number Requirements Expected NPV in Main Analysis(million$) State-IBC Specific NPV(million$) Additional Value per Visit By Person with Disability to Reach $0 NPV Additional Annual Value per Capita to Reach $0 NPV
16 Alterations to Existing Elevators -$339.00 -$102 $0.00 $0.02
28 Water Closet Clearance in Single-User Toilet Rooms – Out-Swinging Doors -$898.40 -$454 $0.00 $0.07
32 Water Closet Clearance in Single-User Toilet Rooms – In-Swinging Doors -$974.70 -$266 $0.02 $0.06
37 Side Reach -$555.00 -$153 $0.00 $0.02

 

[1] See Initial Regulatory Impact Analysis of the Proposed Revised Regulations Implementing Titles II And III of the ADA, Including Revised ADA Standards For Accessible Design, May 9, 2008.

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

[3] New construction, alterations, and barrier removal are modeled separately in order to adequately take into account the impact of program access for public facilities and other differences in underlying assumptions related to sizes of play areas and facility groups.

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

[5] See Section 2.4.1 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.

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

[7] The phrase and example are from Vande Zande v. Wis. Dept. of Admin., 44 F.3d 538, 546 (7th Cir. 1995)., See also, Cass Sunstein, "Cost-Benefit Analysis without Analyzing Costs or Benefits: Reasonable Accommodation, Balancing and Stigmatic Harms, 74 U. CHI L. REV. 1895 (2007).

[8] 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.

[9] Although clearly there will be fewer alternatives absent the Final Rules.

[10] A survey could be conducted to estimate for possible safety benefits, but would be based on a great deal of uncertainty and was beyond the scope of this effort.

[11] 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.

[12] 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 measurement of general altruism in regulatory analysis 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.

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

[14] It is important to remember that despite all the benefits not included in the main analysis, it is also possible to overestimate benefits. For example, consider a city block that already contains two facilities with play areas. Under the Final Rules, 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 from these sorts of details. However, the possibility that benefits will actually fall short of median levels is taken into account using risk analysis.

[15] While a the analysis assumes a new rule after 15 years, those facilities built just before the promulgation of those new rules are expected to be covered by a safe harbor provision for the expect 40 year average expected before the facilities is replaced. Thus, some benefits and recurring costs are expected in years 15 through 54.

[16] The analysis assumes that visitors with the targeted disability use and benefit from the requirements during approximately one-fourth of their visits to these facilities and that the base value of time at shopping mall is approximately $4.25. The monetary value of the threshold premium for avoided stigmatic harm was calculated using the following formula: [(Threshold Premium for Avoided Stigmatic Harm – Req. #28) x (Base Value of Time @ Facility Group K) x (Est. Time Change in Hours –Req. # 28) – ((Base Value of Time @ Facility Group K) x (Est. Time Change in Hours –Req. # 28)].

 

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