5. Results and Discussion
The goal of this analysis is to assess the incremental benefits and costs due to the adoption of the Department's proposed regulations. A fundamental indicator of a publicly acceptable rule is one in which public benefits exceed public costs. The difference between benefits and costs quantified over the planning horizon lifecycle and discounted to the present represent a fundamental indicator of project worth. OMB Circular A-4 stipulates that this difference, the net present value (NPV), is to be regarded as a principal measure of value produced by a benefit-cost analysis when, as here, benefits and costs are separated from each other over time (i.e., when some people benefit from accessible facilities long after their construction). Further, Executive Order 12866 states that agencies should attempt to maximize the net benefits of their rulemakings, subject to statutory requirements. An NPV greater than zero indicates that benefits exceed costs and that the regulation can be expected to increase the general level of economic welfare accordingly. An NPV of less than zero could mean that costs exceed benefits. To further evaluate this latter scenario, the existence and magnitude of unmeasured and qualitative benefits may be assessed in a threshold analysis.
This chapter is divided into several sections. The first section explores, in some depth, the results of the primary baseline scenario (i.e., 1991 Standards, RA = 50% and SH applies). Benefits and costs are aggregated (and expressed in terms of NPV) to show the total incremental impact of the proposed standards with respect to: (a) all requirements collectively; (b) each new and revised requirement; (c) each type of facility; and (d) public versus private facilities. Some of the results are presented with risk-based probabilities and others as expected (i.e., most likely) values. In addition, graphical information is provided that shows the distribution of benefits and costs in the baseline scenario. (Additional and more detailed requirement-by-requirement and facility-by-facility results at the expected value for the primary baseline scenario are also provided in the separate Supplemental Results volume that accompanies this analysis.) These different summaries of results are intended to enable stakeholders to examine the regulatory analysis from their particular perspective.
The second section discusses how the total NPV changes under key alternate scenarios. These alternate scenarios are: safe harbor versus no safe harbor; barrier removal that is assumed to be readily achievable at varying percentages [0%, 50%, and 100%]; and alternate IBC baselines [IBC 2000, IBC 2003, and IBC 2006]. Due to the large number of scenarios, references to single scenarios use these abbreviations for safe harbor (SH), readily achievable barrier removal (RA) and baselines (SH, NSH; RA0, RA50, RA100; and, B1991, B2000, B2003, B2006) respectively. Results for each of these alternate scenarios are only presented as risk-based probabilities.
The third section presents stress analyses that assess the relative impact of varying several key selected assumptions individually. Stress analyses are presented for three different parameters: premium on access time; premium on use time; and, price elasticity of demand for facility use. In addition, to further explore the relative impact of parameter variability on results, this section also includes an assessment of the key drivers behind the risk ranges for the three requirements with the largest negative NPVs [Side Reach (Req. # 37), Water Closet Clearance in Single User Toilet Rooms -- In Swinging Doors (Req. #32), and Passenger Loading Zones (Medical/Long-Term Care) (Req. # 26)], as well as the three requirements with the largest positive NPVs [Passenger Loading Zones (Req. # 19), Accessible Route to Exercise Machines and Equipment (Req. # 70), and Transient Lodging Guest Room Vanities (Req. # 45)].
Lastly, to supplement the quantitative results presented in preceding sections, the fourth section discusses the unquantified benefits of the proposed regulations and their implication for model results. Many of the significant benefits conferred on persons with disabilities, businesses, and society generally by these proposed civil rights standards that implement the ADA defy quantification. Such benefits include: decreased administrative costs for businesses, architects, and state and local governments due to harmonization of the proposed ADA standards with model codes; increased social equity for persons with disabilities through better access to, and use of, public facilities; enhanced social and physical development of children with disabilities through improved access to play areas and other recreational facilities; and greater use of accessibility features by persons without disabilities (such as a parent using an accessible passenger loading zone at an airport to facilitate easier transport of a stroller and wheeled baggage). Given that the overall NPV for the proposed regulation is significantly positive for all scenarios at their respective expected values, such benefits -- even if quantifiable -- would only serve to underscore the overall conclusion that the regulations would promote the general economic welfare. However, for any individual requirement (or facility) with a negative NPV under any particular scenario, consideration of these unquantified benefits could well alter the benefit-cost calculus.
The results presented in this section are dependent to a greater or lesser extent on assumptions about facilities, requirements, and user benefits by persons with disabilities that were necessitated by lack of publicly available data or other published sources. Each of these assumptions is discussed in detail in Chapter 4. Some of these assumptions by HDR and the Department were based on the advice of experts and independent research; others are based on HDR's current understanding of the interaction between facilities, requirements, and users. Because of the nature of this analysis, some of these assumptions may have a significant impact on the final results. While these assumptions reflect HDR's current understanding, they would undoubtedly benefit from further outside review.
5.1 Results Under Primary Baseline Scenario
5.1.1 Total Net Present Value
The scenario considered in this section is characterized by assuming: 1991 Standards baseline, RA = 50% and SH applies. Recall from the earlier discussion that the percentage of elements that are RA represent those that undertake barrier removal. Those elements that are not RA would become compliant following an alterations schedule that tracks from the date that building was constructed. For all revised requirements, BR would apply only when SH is not granted. As such, these results represent costs and benefits from all new construction, all altered elements, and BR of newly regulated elements. It is also worth noting that when SH is not granted, BR becomes the dominant form of compliance with its relatively large cost burden on facilities.
Table 6 and Figure 7 present total NPV for a baseline scenario: Safe Harbor (SH), BR is readily achievable for 50% of elements (RA50) and the baseline standard is 1991 (B1991). Results for both the 3% and 7% discount rates are shown. Each cost curve is a joint distribution of all uncertainties in the model based on a simulation of over 1,000 Monte Carlo simulations.
Under the assumptions used to construct this analysis, these results suggest that the proposed regulations have a net positive public benefit. The numbers on the chart represent the 10th, 50th and 90th percentiles of the distribution. The range between the 10th and 90th percentiles represents an 80% confidence interval. This interval can be interpreted as having 80% confidence that the true NPV would be within this range. The most likely NPV is the median (50th) percentile (in the middle of this range).
Figure 7 presents total NPV summing all discounted costs and benefits for all facilities and requirements at the 3% and 7% discount rates. The 7% discount rate indicates that the 80% confidence interval ranges from $4.7 B to $11.0 B, with a median of $7.6 B. At 3%, this range ($23.2 to $40.6 B) is much wider and more skewed towards positive NPVs. These results indicate that NPV is unlikely to be less than zero. Table 6 indicates the total expected benefits and costs from users and facilities, respectively. Differences between the Total expected NPV in Table 6 ($7.5 B at the 7% discount rate) and the median NPV in Figure 7 ($7.6 B) are caused by the skewness of the distribution of NPVs.
Figure 7: Total NPV - Baseline Scenario: SH/RA50/B1991; 3% and 7% Discount Rates
Table 6: Total Net Present Value in Baseline Scenario at Expected Value (billions $)
(Under Safe Harbor, 50% Readily Achievable Barrier Removal, 1991 Standards for baseline)
| Discount Rate | Expected NPV | Total Expected PV(Benefits) |
Total Expected PV(Costs) |
|---|---|---|---|
| 3% | $31.1 | $53.9 | -$22.8 |
| 7% | $7.5 | $19.5 | -$11.9 |
5.1.2 Distribution of Costs and Benefits
Figure 8 and Figure 9 show the distributions of benefits and costs for the baseline case (SH and 7% discount rate). Time savings for users comprises over 90% of total benefits. Cost savings for facilities associated with less stringent requirements for NC and ALT projects is comparatively small, at about 9%. On the cost side, because this scenario involves SH, most of compliance costs use the ALT cost series. NC applies to only new facilities and BR only occurs for 50% of elements that are subject to requirements for the first time. Among other costs, O&M is larger than lost productive space and replacement costs. Costs to users in terms of lost time are also a significant component of cost.
Figure 8: Distribution of Benefits between Users and Facilities (Cost Savings)
Figure 9: Distribution of Costs between Type of Cost, Type of Construction, Users[1]
5.1.3 Net Present Value by Requirements
Figure 10 shows the NPV for selected requirements including shower spray controls (a revised, more stringent requirement), assisted listening devices (technical) (a revised, more stringent requirement with use value benefits) and accessible routes to bowling lanes (a supplemental requirement with new user benefits).
Figure 10: NPV for Selected Requirements
The table below details the costs, benefits and net benefits (or costs) for each requirement. The NPV refers to the net benefits less the net costs (numbers in parentheses are negative, and those an overall cost to society). The Net Impact to Users reflects the value of the benefits to users; less stringent requirements resulting in negative benefits to users are in parentheses. The column listing the Top 3 drivers of benefits list the facilities which generate the largest benefits for that requirement. Net Impact to Facilities lists the cost to facilities of compliance with the requirement; numbers in parentheses represent a cost to the facilities, number without parentheses represent effect savings due to less stringent requirements. Top three Drivers of Costs list those facilities in which the greatest costs for the requirement are generated.
Table 7 (which follows at the end of Section 5.1.4) deconstructs aggregated results by requirement. The columns in this table include:
- 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 in which the requirement costs 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):
- 23. Passenger loading zones: The high positive NPV ($1.84 B) is due to high users benefits ($1.89 B) and low costs to facilities ($50 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.
- 70. Accessible routes to exercise machines and 71. Accessible exercise machines: New access to exercise facilities also drives high NPVs ($1.10 B and $842 M, 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 accessible routes to exercise machines are fairly low ($15 M), but costs to facilities for the accessible machines are higher ($340 M), this difference accounts for most of the difference in NPV for the requirements, since benefits are very similar ($1.12 B for accessible routes to exercise machines, and $1.18 B for accessible machines).
- 45. Transient lodging room guest vanities. Similar to the NPV for passenger loading zones, the high positive NPV ($1.07 B) for transient lodging room guest vanities is due to high users benefits ($1.09 B) and low costs to facilities ($22 M). Benefits from these requirements 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 -- hotels, inns and motels. Being able to use the vanity comfortably enhances the experience relating to the primary purpose of staying at the hotel (defined as shelter, a bed and use of a bathroom).
- 37. Side reach: The large negative NPV (-$971 M) is the largest NPV in magnitude among all requirements. The large negative impact is driven by the ubiquitous nature of these elements and a relatively small benefit per use compared with capital cost. Total benefits to users are $184 M while the cost to facilities is $1.15 B. The facility category with the largest side reach costs is indoor service establishments, which is also the facility type with the largest number of establishments (more than 3 million).
- 32. Water Closet Clearance in Single-user Toilet Rooms with In-swinging doors. The large negative NPV ($-928 M) for this requirement is due to relatively small benefits to users ($46 M) but large costs to facilities ($974 M). Over 90% of the total cost for in-swinging doors 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 (ALT/BR).[2] Stairs under new construction (#9) has a small positive NPV of $54 M, but it is minimal when paired with the large negative NPV ($-764 M) for stairs under alterations (#10). The benefits for this requirement under alterations are moderate in size ($18 M) when compared to other requirements but the costs to facilities are high ($782 M) due to high unit costs ($7,500 per flight at the median level).
- 100, 102, 104. Accessible play components[3]: The NPV for all accessible play components, new construction, alterations, and barrier removal, totals $769 M. This is due to large users benefits ($823 M) and moderate costs to facilities. In contrast, the requirement for accessible routes to play components has a fairly large cost to facilities of $392 M (plus a slightly lower benefit to users of $549 M), and thus a much lower NPV of $156 M. The benefits and costs for public schools are moderate due to existing program access requirements which already have made a large portion of existing school playgrounds accessible.
5.1.4 Net Present Value by Facilities
Figure 11 shows the NPV for selected facilities, including inns, hotels, and motels.
Figure 11: NPV for Selected Facilities
Table 8 summarizes the results for all facilities at the baseline scenario. Facilities with the largest positive and negative NPVs are discussed below (Details regarding benefits and costs for each requirement in each facility type can be found in the Supplemental Results volume):
- Restaurants: Although costs to restaurants are relatively high ($442 M) benefits to users are much higher ($2.74 B) resulting in a large NPV of $2.30 B. The requirement driving much of the benefits is passenger loading zones, which have very low capital costs but fairly high user benefits (see discussion above). Further amplifying the benefits is the relatively high number of visits for this facility group (48 B), larger than any other facility group.
- Exercise Facilities: The $1.79 B NPV follows directly from the high NPV of exercise facilities' two most important requirements: Accessible route to exercise machines and Accessible machines (as discussed above).
- Undergraduate and post-graduate private schools: The large NPV of $1.48 B is due to substantial benefits of $1.62 B and while costs total $141 M. These large benefits are due to moderately high benefits (from $147 M to $245 M) for several requirements, including water closet clearance in single-user toilet rooms without-swinging doors, accessible routes to exercise machines, accessible exercise machines and accessible dressing and locker rooms.
- Office buildings: Office buildings posted a large negative NPV of $-1.04 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' alterations followed by side reach alterations.
- Indoor Service Establishments: The large negative NPV (-$1.11 B) for this facility is driven by two requirements 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 for over three-fourths of the facilities' costs, coupled with substantial costs due to lost usable space. Yet the vast majority of user benefits are also due to this same requirement.
- (State and local judicial facilities) Courthouses: This facility has a fairly large negative NPV (-$517 M) primarily due to the large capital costs for Accessible Attorney Areas and Witness Stands (-$302 M). Since visits to these facilities are fairly low in comparison to other facility groups, benefits do have as much opportunity to accumulate.
The table below details the costs, benefits and net benefits (or costs) for each requirement. The NPV refers to the net benefits less the net costs (numbers in parentheses are negative, and those an overall cost to society). The Net Impact to Users reflects the value of the benefits to users; less stringent requirements resulting in negative benefits to users are in parentheses. The column listing the Top 3 drivers of benefits list the facilities which generate the largest benefits for that requirement. Net Impact to Facilities lists the cost to facilities of compliance with the requirement; numbers in parentheses represent a cost to the facilities, number without parentheses represent effect savings due to less stringent requirements. Top three Drivers of Costs list those facilities in which the greatest costs for the requirement are generated.
Table 7: Costs and Benefits per Requirement in Baseline Scenario
| Requirement | NPV (millions of $) |
Net Impact to Users (millions of $) |
Top 3 drivers of benefits | Net Impact to Facilities (millions of $) |
Top 3 drivers of costs |
|---|---|---|---|---|---|
| 1-Public Entrances | (22.08) | (22.31) | Shopping malls Stadiums (public) Stadiums |
0.23 | Shopping malls Stadiums (public) Stadiums |
| 2-Maneuvering Clearance or Standby Power for Automatic Doors | (0.38) | 0.01 | Nursing homes Nursing homes (public) Convention centers (public) |
(0.40) | Nursing homes Nursing homes (public) Convention centers (public) |
| 3-Automatic Door Break-OutOpenings | (3.25) | 0.00 | Motels Hotels Hospitals |
(3.25) | Hotels Motels Hospitals |
| 4-Thresholds at Doorways | 2.18 | 4.35 | Motels Hotels Inns |
(2.16) | Public housing Motels Hotels |
| 5-Door and Gate Surfaces | (83.7) | 2.73 | Motels Museums, historical sites & libraries (public) Parks or zoos (public) |
(86.42) | Office buildings Parks or zoos (public) Office buildings (public) |
| 9-Stairs (NC) | 53.62 | 53.62 | Motels Museums, historical sites& libraries (public) Undergraduate and postgraduate private schools |
0.00 | |
| 10-Stairs (ALT/BR) | (764.21) | 18.26 | Motels Museums, historical sites & libraries (public) Undergraduate and postgraduate private schools |
(782.47) | Office buildings Offices of health care providers Undergraduate, postgraduate public schools |
| 11-Handrails Along Walkways | 0.00 | 0.00 | 0.00 | ||
| 12-Handrails | 14.99 | (24.83) | Exercise facilities Museums, historical sites& libraries (public) Parking garages |
39.82 | Office buildings Office buildings (public) Undergraduate, postgraduate public schools |
| 13-Accessible Routes from Site Arrival Points and Within Sites | 9.89 | (35.35) | Parks or zoos (public) Motels Golf courses (private with public access) |
45.23 | Parks or zoos (public) Motels Terminal (private airports) |
| 14-Standby Power for Platform Lifts | (33.23) | 0.00 | Stadiums (public) Stadiums State and local judicial facilities (courthouses) |
(33.23) | State and local judicialfacilities (courthouses) Stadiums (public) Stadiums |
| 15-Power-Operated Doors for Platform Lifts | (24.74) | 2.37 | Stadiums (public) Stadiums State and local judicial facilities (courthouses) |
(27.11) | State and local judicial facilities (courthouses) Stadiums (public) Stadiums |
| 16-Alterations to Existing Elevators | (339.87) | 2.53 | Nursing homes Undergraduate and postgraduate private schools Hotels |
(342.41) | Office buildings Office buildings (public) State and local judicial facilities (courthouses) |
| 19-Van Accessible Parking Spaces | 52.6 | 59.87 | Parks or zoos (public) Amusement parks Stadiums (public) |
(7.27) | Parks or zoos (public) Terminal (private airports) Undergraduate, postgraduate public schools |
| 20-Valet Parking Garages | (46.28) | 175.22 | Restaurants Hotels Theatre / Concert Hall |
(221.5) | Restaurants Theatre / Concert Hall Hotels |
| 21-Mechanical Access Parking Garages | 186.96 | 187.34 | Parking garages Parking garages (public) |
(0.38) | Parking garages Parking garages (public) |
| 22-Direct Access Entrances from Parking Structures | 44.71 | 44.71 | Shopping malls Convention centers (public) Convention centers |
0.00 | |
| 23-Passenger Loading Zones | 1,835.26 | 1,885.30 | Restaurants Shopping malls Parks or zoos (public) |
(50.03) | Office buildings Parks or zoos (public) Restaurants |
| 24-Parking Spaces | 961.28 | 992.42 | Restaurants Museums, historical sites& libraries (public) Parks or zoos (public) |
(31.15) | Office buildings Restaurants Parks or zoos (public) |
| 25-Parking Spaces (Signs) | (2.89) | (3.27) | Public housing | 0.38 | Public housing |
| 26-Passenger Loading Zones(Medical / Long-Term Care) | (489.01) | (653.23) | Nursing homes Hospitals Nursing homes (public) |
164.22 | Nursing homes Hospitals Nursing homes (public) |
| 27-Ambulatory Accessible Toilet Compartments | 442.06 | 497.81 | Parks or zoos (public) Undergraduate and postgraduate private schools Exercise facilities |
(55.76) | Theatre / Concert Hall Parks or zoos (public) Shopping malls |
| 28-Water closet clearance in single-user toilet rooms - out swinging door | 189.66 | 2,364.31 | Indoor Service Establishments Undergraduate and postgraduate private schools Parks or zoos (public) |
(2,174.64) | Indoor Service Establishments Offices of health care providers Nursing homes |
| 29-Shower Spray Controls | 144.3 | 207.18 | Undergraduate and postgraduate private schools Motels Hotels |
(62.88) | Nursing homes Undergraduate, postgraduate public schools Parks or zoos (public) |
| 30-Urinals | (13.08) | (13.08) | Undergraduate and postgraduate private schools Motels Museums, historical sites & libraries (public) |
0.00 | |
| 31-Multiple Single-User Toilet Rooms | 135.34 | (5.96) | Offices of health care providers Hospitals Theatre / Concert Hall |
141.3 | Offices of health care providers Theatre / Concert Hall Hospitals |
| 32-Water closet clearance in single-user toilet rooms - in swinging door | (928.09) | 46.28 | Restaurants Undergraduate and postgraduate private schools Single level stores |
(974.37) | Single level stores Restaurants Elementary public schools |
| 34-Patient Toilet Rooms | (3.44) | (5.4) | Hospitals Hospitals (public) |
1.96 | Hospitals Hospitals (public) |
| 35-Drinking Fountains | (66.13) | 0.37 | Undergraduate and postgraduate private schools Swimming pools / Aquatic centers Swimming pools / Aquatic centers (public) |
(66.5) | Office buildings Office buildings (public) Swimming pools / Aquatic centers |
| 37-Side Reach | (970.6) | 184.18 | Indoor Service Establishments Restaurants Single level stores |
(1,154.78) | Indoor Service Establishments Office buildings Offices of health careproviders |
| 38-Sales and Service Counters(NC) | 31.42 | (10.99) | Restaurants Museums, historical sites & libraries (public) Indoor Service Establishments |
42.41 | Indoor Service Establishments Single level stores Parks or zoos (public) |
| 39-Sales and Service Counters(Alt) | (64) | (239.6) | Restaurants Indoor Service Establishments Single level stores |
175.6 | Indoor Service Establishments Single level stores Restaurants |
| 40-Washing Machines and Clothes Dryers (technical) | (6.43) | 0.14 | Undergraduate and postgraduate private schools Public housing Undergraduate, postgraduate public schools |
(6.57) | Public housing Undergraduate, postgraduate public schools Undergraduate and postgraduate private schools |
| 41-Washing Machines and Clothes Dryers (Scoping) | (1.93) | 0.07 | Undergraduate and postgraduate private schools Public housing Undergraduate, postgraduate public schools |
(2.00) | Public housing Undergraduate, post graduate public schools Undergraduate and postgraduate private schools |
| 42-Self-Service Storage Access | 17.08 | 19.78 | Self service storage facilities | (2.7) | Self service storage facilities |
| 45-Transient lodging Guest Room Vanities | 1,071.48 | 1,093.72 | Motels Hotels Inns |
(22.24) | Motels Hotels Inns |
| 46-Operable Windows | 169.56 | 204.66 | Motels Undergraduate and postgraduate private schools Hotels |
(35.11) | Public housing Undergraduate, post graduate public schools Motels |
| 47-Dwelling Units with Communication Features [1991] | (13.00) | 0.02 | Public housing |
(13.03) | Public housing |
| 48-Dwelling Units with Communication Features [UFAS] | (3.47) | 0.01 | Public housing |
(3.47) | Public housing |
| 49-Galley Kitchen Clearances | 27.21 | 47.74 | Undergraduate and postgraduate private schools Public housing Undergraduate, postgraduatepublic schools |
(20.53) | Undergraduate, postgraduate public schools Public housing Undergraduate and postgraduate private schools |
| 50-Shower Compartments with Mobility Features | 61.20 | (12.38) | Undergraduate and postgraduate private schools Motels Hotels |
73.58 | Nursing homes Undergraduate, postgraduate public schools Parks or zoos (public) |
| 51-Location of Accessible Route to Stages | (147.16) | 0.16 | Undergraduate and postgraduate private schools Amusement parks Secondary public schools |
(147.32) | Undergraduate, postgraduate public schools Secondary public schools Undergraduate and postgraduate private schools |
| 52-Wheelchair Space Overlap in Assembly Areas | (64.79) | 498.06 | Museums, historical sites & libraries (public) Secondary public schools Museums, historical sites & libraries |
(562.85) | Stadiums (public) Motion Picture House Theatre / Concert Hall |
| 54-Handrails on Aisle Ramps in Assembly Areas | (351.89) | (400.95) | Museums, historical sites& libraries (public) Undergraduate and postgraduate private schools Museums, historical sites& libraries |
49.06 | Parks or zoos (public) Motion Picture House Secondary public schools |
| 55-Wheelchair Spaces in Assembly Areas | 96.11 | (5.82) | Undergraduate and postgraduate private schools Motion Picture House Stadiums (public) |
101.93 | Stadiums (public) Stadiums Undergraduate, postgraduate public schools |
| 56-Accessible Route to Tiered Dining Areas in Sports Facilities (NC) | 5.6 | (0.53) | Stadiums (public) Stadiums |
6.13 | Stadiums (public) Stadiums |
| 57-Accessible Route to Press Boxes | 69.25 | (1.48) | Undergraduate and postgraduate private schools Secondary public schools Undergraduate, postgraduate public schools |
70.74 | Secondary public schools Undergraduate and postgraduate private schools Undergraduate, postgraduate public schools |
| 58-Public TTYS | (3.16) | 0.02 | Shopping malls Convention centers (public) Stadiums (public) |
(3.17) | State and local judicial facilities (courthouses) Shopping malls Terminal (private airports) |
| 59-Public Telephone Volume Controls | (7.78) | 0.01 | Nursing homes Undergraduate and postgraduate private schools Hotels |
(7.8) | State and local judicialfacilities (courthouses) Hotels Shopping malls |
| 60-Two-Way Communication Systems at Entrances | (5.45) | 7.89 | Motels Public housing |
(13.34) | Public housing Motels |
| 61-ATMs and Fare Machines | (14.42) | 37.53 | Indoor Service Establishments Stadiums (public) Stadiums |
(51.95) | Indoor Service Establishments Stadiums (public) Stadiums |
| 62-Assistive Listening Systems(technical) | (185.48) | 1.24 | Museums, historical sites & libraries (public) Secondary public schools Museums, historical sites & libraries |
(186.72) | Secondary public schools Undergraduate, postgraduate public schools Stadiums (public) |
| 64-Detectable Warnings (scoping) | 309.78 | (71.87) | Restaurants Nursing homes Museums, historical sites & libraries (public) |
381.65 | Indoor Service Establishments Office buildings Offices of health care providers |
| 66-Assistive Listening Systems(scoping) | 267.9 | (7.03) | Museums, historical sites & libraries (public) Undergraduate and postgraduate private schools Museums, historical sites & libraries |
274.94 | Stadiums (public) Undergraduate, postgraduate public schools Stadiums |
| 68-Accessible Attorney Areas and Witness Stands | (301.75) | 0.01 | State and local judicial facilities (courthouses) | (301.76) | State and local judicial facilities (courthouses) |
| 70-Accessible Route to Exercise Machines and Equipment | 1,100.40 | 1,115.75 | Exercise facilities Undergraduate and postgraduate private schools Hotels |
(15.35) | Exercise facilities Undergraduate and postgraduate private schools Hotels |
| 71-Accessible Machines and Equipment | 841.53 | 1,181.17 | Exercise facilities Undergraduate and postgraduateprivate schools Hotels |
(339.64) | Exercise facilities Undergraduate and postgraduate private schools Undergraduate, postgraduate public schools |
| 73-Accessible Lockers | 137.1 | 175.07 | Exercise facilities Undergraduate and postgraduate private schools Swimming pools / Aquatic centers |
(37.96) | Exercise facilities Swimming pools / Aquatic centers Undergraduate and postgraduate private schools |
| 74-Accessible Dressing Rooms, Fitting Rooms, or Locker Rooms | 244.76 | 246.96 | Undergraduate and postgraduate private schools Secondary Private Schools |
(2.2.0) | Undergraduate and postgraduate private schools Secondary Private Schools |
| 75-Wheelchair Spaces in Team or Player Seating Areas | (0.82) | 0.01 | Undergraduate and postgraduate private schools Secondary Private Schools |
(0.83) | Undergraduate and postgraduate private schools Secondary Private Schools |
| 77-Accessible Route to Bowling Lanes | 232.37 | 233.56 | Bowling alleys | (1.19) | Bowling alleys |
| 78-Shooting Facilities with Firing Positions | 223.22 | 223.71 | Shooting facilities | (0.49) | Shooting facilities |
| 79-Accessible Means of Entry to Pools (NC/ALT) | 104.51 | 393.53 | Swimming pools / Aquatic centers Undergraduate and postgraduate private schools Motels |
(289.03) | Swimming pools / Aquatic centers Motels Hotels |
| 80-Accessible Means of Entry to Wading Pools | 179.04 | 867.78 | Swimming pools / Aquatic centers Swimming pools / Aquatic centers (public) |
(688.74) | Swimming pools / Aquatic centers Swimming pools / Aquatic centers (public) |
| 81-Accessible Means of Entry to Spas | 598.52 | 779.37 | Swimming pools / Aquatic centers Undergraduate and postgraduate private schools Nursing homes |
(180.84) | Nursing homes Swimming pools / Aquatic centers Hospitals |
| 82-Accessible Route for Boating Facilities | 2.48 | 10.28 | Recreational boating facilities (public) Recreational boating facilities |
(7.79) | Recreational boating facilities (public) Recreational boating facilities |
| 83-Accessible Boarding Piers(NC) | 0.54 | 2.5 | Recreational boating facilities (public) Recreational boating facilities |
(1.96) | Recreational boating facilities (public) Recreational boating facilities |
| 85-Accessible Boat Slips (NC) | (2.25) | 9.42 | Recreational boating facilities Recreational boating facilities (public) |
(11.68) | Recreational boating facilities Recreational boating facilities (public) |
| 87-Accessible Route to Fishing Piers | 31.98 | 32.3 | Fishing piers and platforms Fishing piers and platforms(public) |
(0.32) | Fishing piers and platforms Fishing piers and platforms(public) |
| 88-Accessible Fishing Piers and Platforms | 57.51 | 66.43 | Parks or zoos (public) Fishing piers and platforms Fishing piers and platforms(public) |
(8.91) | Parks or zoos (public) Fishing piers and platforms Parks or zoos |
| 89-Accessible Route to Golf Courses | 207.74 | 220.73 | Golf courses (private with public access) Golf courses (private only) Golf courses (public) |
(12.99) | Golf courses (private with public access) Golf courses (private only) Golf courses (public) |
| 90-Accessible Practice Grounds at Golf Courses (Alt/BR) | (219.03) | 162.36 | Golf courses (private withpublic access) Golf courses (private only) Golf courses (public) |
(381.39) | Golf courses (private withpublic access) Golf courses (private only) Golf courses (public) |
| 92-Accessible Practice Grounds at Driving Ranges | 292.63 | 299.29 | Golf courses (private withpublic access) Golf courses (private only) Golf courses (public) |
(6.65) | Golf courses (private withpublic access) Golf courses (private only) Golf courses (public) |
| 93-Accessible Route to Minigolf Holes | 241.42 | 257.93 | Miniature golf courses Miniature golf courses(public) |
(16.52) | Miniature golf courses Miniature golf courses(public) |
| 94-Accessible Minigolf Holes | 179.9 | 243.92 | Miniature golf courses Miniature golf courses (public) |
(64.02) | Miniature golf courses Miniature golf courses(public) |
| 95-Accessible Route to Rides | 441.25 | 503.57 | Amusement parks Amusement parks (public) |
(62.31) | Amusement parks Amusement parks (public) |
| 96-Wheelchair Space or Transfer Seat or Transfer Device | 3.39 | 4.62 | Amusement parks Amusement parks (public) |
(1.24) | Amusement parks Amusement parks (public) |
| 97-Maneuvering Space in Load and Unload Area | 12.25 | 15.33 | Amusement parks Amusement parks (public) |
(3.08) | Amusement parks Amusement parks (public) |
| 98-Signs at Amusement Parkrides | 3.66 | 5.13 | Amusement parks Amusement parks (public) |
(1.47) | Amusement parks Amusement parks (public) |
| 99-Accessible Route to Play Components (BR) | (13.54) | 194.03 | Elementary public schools Parks or zoos (public) Amusement parks |
(207.58) | Elementary public schools Parks or zoos (public) Elementary private schools |
| 100-Accessible Play Components(BR) | 259.11 | 294.94 | Elementary public schools Parks or zoos (public) Amusement parks |
(35.83) | Elementary public schools Parks or zoos (public) Elementary private schools |
| 101-Accessible Route to Play Components (ALT) | 255.24 | 270.57 | Restaurants Shopping malls Motels |
(15.33) | Restaurants Parks or zoos (public) Elementary public schools |
| 102-Accessible Play Components(ALT) | 398.56 | 402 | Restaurants Shopping malls Motels |
(3.43) | Restaurants Parks or zoos (public) Nursery schools - Daycare |
| 103-Accessible Route to Play Components (NC) | (85.2) | 84.07 | Elementary public schools Restaurants Nursery schools - Daycare |
(169.27) | Elementary public schools Nursery schools - Daycare Elementary private schools |
| 104-Accessible Play Components(NC) | 111.29 | 126.17 | Elementary public schools Restaurants Nursery schools - Daycare |
(14.89) | Elementary public schools Nursery schools - Daycare Elementary private schools |
| 105-Open Captioning in Sports Stadium | (0.53) | 0.00 | Stadiums | (0.53) | Stadiums (public) Stadiums |
| 106-Post Secondary School Multi-Story Dorm Facility | (94.4) | 0.48 | Undergraduate, postgraduate public schools | (94.87) | Undergraduate, postgraduate public schools |
| 109-Social Service Establishment (UFAS) | 81.28 | (24.34) | Homeless Shelter Homeless Shelter (public) |
105.62 | Homeless Shelter Homeless Shelter (public) |
| 110-Social Service Establishment (ADAAG) | 51.18 | 54.56 | Homeless Shelter Homeless Shelter (public) |
(3.38) | Homeless Shelter Homeless Shelter (public) |
| 111-Accessible Saunas and Steam Rooms (ALT/BR) | 344.39 | 553.05 | Exercise facilities Undergraduate andpostgraduate private schools Swimming pools / Aquatic centers |
(208.66) | Exercise facilities Undergraduate and postgraduate private schools Swimming pools / Aquatic centers |
| 112-Accessible Means of Entry to Pools (BR) | 82.51 | 132.57 | Undergraduate and postgraduate private schools Swimming pools / Aquatic centers Hotels |
(50.07) | Swimming pools / Aquaticcenters Hotels Undergraduate and postgraduate private schools |
The table below details the costs, benefits and net benefits (or costs) to each facility type. The NPV refers to the net benefits less the net costs (numbers in parentheses are negative, and those an overall cost to society). The Net Impact to Users reflects the value of the benefits to users; less stringent requirements resulting in negative benefits to users are in parentheses. The column listing the Top 3 drivers of benefits list the requirement which generate the largest benefits at that facility. Net Facility Impact lists the cost to facilities of compliance with the requirement; numbers in parentheses represent a cost to the facilities, number without parentheses represent effect savings due to less stringent requirements. The Top three drivers of Impacts to Facilities lists the requirements with the largest impact on facility costs.
Table 8: Total Costs and Benefits per Facility Group in Baseline Scenario
| Facility | NPV (millions of $) |
Total User Impact (millions of $) |
Top 3 drivers of impact to users | Total Facility Impact (millions of $) |
Top 3 drivers of impact to facilities |
|---|---|---|---|---|---|
| Inns | 353.58 | 361.37 | Transient lodging Guest Room Vanities Water closet clearance in single-user toilet rooms - out swinging door Operable Windows |
(7.80) | Water closet clearance in single-user toilet rooms - out swinging door Side Reach Transient lodging Guest Room Vanities |
| Hotels | 594.05 | 764.62 | Transient lodging Guest Room Vanities Water closet clearance in single-user toilet rooms - out swinging door Accessible Route to Exercise Machines and Equipment |
(170.57) | Accessible Means of Entry to Pools (NC/ALT) Water closet clearance in single-user toilet rooms - out swinging door Stairs (ALT/BR) |
| Motels | 718.23 | 854.43 | Transient lodging Guest Room Vanities Water closet clearance in single-user toilet rooms - out swinging door Operable Windows |
(136.20) | Accessible Means of Entry to Pools (NC/ALT) Water closet clearance in single-user toilet rooms - out swinging door Transient lodging Guest Room Vanities |
| Restaurants | 2,296.62 | 2,738.47 | Passenger Loading Zones Parking Spaces Accessible Play Components (ALT) |
(441.85) | Water closet clearance in single-user toilet rooms - in swinging door Valet Parking Garages Side Reach |
| Motion Picture House | (114.02) | 26.73 | Wheelchair Space Overlap in Assembly Areas Passenger Loading Zones Parking Spaces |
(140.75) | Wheelchair Space Overlap in Assembly Areas Assistive Listening Systems (technical) Ambulatory Accessible Toilet Compartments |
| Theatre / Concert Hall | (170.21) | 26.53 | Wheelchair Space Overlap in Assembly Areas Water closet clearance in single-user toilet rooms - out swinging door Ambulatory Accessible Toilet Compartments |
(196.74) | Wheelchair Space Overlap in Assembly Areas Valet Parking Garages Assistive Listening Systems (technical) |
| Stadiums | 4.96 | 19.28 | Passenger Loading Zones Wheelchair Space Overlap in Assembly Areas Accessible Saunas and Steam Rooms (ALT/BR) |
(14.32) | Wheelchair Space Overlap in Assembly Areas Assistive Listening Systems (technical) Water closet clearance in single-user toilet rooms - out swinging door |
| Auditoriums | (3.61) | 9.82 | Passenger Loading Zones Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments |
(13.43) | Wheelchair Space Overlap in Assembly Areas Location of Accessible Route to Stages Ambulatory Accessible Toilet Compartments |
| Convention centers | 14.49 | 14.56 | Passenger Loading Zones Ambulatory Accessible Toilet Compartments ATMs and Fare Machines |
(0.07) | Assistive Listening Systems (technical) Location of Accessible Route to Stages Water closet clearance in single-user toilet rooms - in swinging door |
| Single level stores | (391.45) | (2.90) | Sales and Service Counters (Alt) Sales and Service Counters (NC) Urinals |
(388.55) | Water closet clearance in single-user toilet rooms - in swinging door Side Reach Door and Gate Surfaces |
| Shopping malls | 307.28 | 341.00 | Passenger Loading Zones Ambulatory Accessible Toilet Compartments Direct Access Entrances from Parking Structures |
(33.72) | Stairs (ALT/BR) Ambulatory Accessible Toilet Compartments Water closet clearance in single-user toilet rooms - in swinging door |
| Indoor Service Establishments | (1,109.49) | 524.84 | Water closet clearance in single-user toilet rooms - out swinging door Side Reach ATMs and Fare Machines |
(1,634.33) | Water closet clearance in single-user toilet rooms - out swinging door Side Reach ATMs and Fare Machines |
| Offices of health care providers | (222.72) | 116.86 | Water closet clearance in single-user toilet rooms - out swinging door Side Reach Stairs (NC) |
(339.58) | Water closet clearance in single-user toilet rooms - out swinging door Stairs (ALT/BR) Side Reach |
| Hospitals | (29.56) | (10.27) | Passenger Loading Zones (Medical / Long-Term Care) Patient Toilet Rooms Multiple Single-User Toilet Rooms |
(19.29) | Accessible Means of Entry to Spas Water closet clearance in single-user toilet rooms - out swinging door Water closet clearance in single-user toilet rooms - in swinging door |
| Nursing homes | (303.38) | (188.68) | Passenger Loading Zones (Medical / Long-Term Care) Detectable Warnings (scoping) Accessible Routes from Site Arrival Points and Within Sites |
(114.70) | Water closet clearance in single-user toilet rooms - out swinging door Accessible Means of Entry to Spas Side Reach |
| Terminal (private airports) | 1.58 | 0.06 | Direct Access Entrances from Parking Structures Passenger Loading Zones Water closet clearance in single-user toilet rooms - out swinging door |
1.53 | Accessible Routes from Site Arrival Points and Within Sites Detectable Warnings (scoping) Sales and Service Counters (NC) |
| Depots | 0.06 | 0.05 | Passenger Loading Zones Water closet clearance in single-user toilet rooms - in swinging door Door and Gate Surfaces |
0.01 | Detectable Warnings (scoping) Handrails Sales and Service Counters (NC) |
| Museums, historical sites & libraries | 44.88 | 51.85 | Wheelchair Space Overlap in Assembly Areas Passenger Loading Zones Parking Spaces |
(6.97) | Water closet clearance in single-user toilet rooms - in swinging door Wheelchair Space Overlap in Assembly Areas Assistive Listening Systems (technical) |
| Parks or zoos | 45.50 | 48.27 | Water closet clearance in single-user toilet rooms - out swinging door Passenger Loading Zones Accessible Play Components (BR) |
(2.77) | Accessible Route to Play Components (BR) Water closet clearance in single-user toilet rooms - in swinging door Accessible Fishing Piers and Platforms |
| Amusement parks | 773.40 | 844.76 | Accessible Route to Rides Water closet clearance in single-user toilet rooms - out swinging door Ambulatory Accessible Toilet Compartments |
(71.36) | Accessible Route to Rides Maneuvering Space in Load and Unload Area Location of Accessible Route to Stages |
| Nursery schools - Daycare | (23.15) | 84.15 | Water closet clearance in single-user toilet rooms - out swinging door Accessible Play Components (NC) Accessible Route to Play Components (NC) |
(107.30) | Accessible Route to Play Components (NC) Water closet clearance in single-user toilet rooms - out swinging door Side Reach |
| Elementary private schools | (33.10) | 80.61 | Accessible Play Components (BR) Accessible Route to Play Components (BR) Water closet clearance in single-user toilet rooms - out swinging door |
(113.71) | Accessible Route to Play Components (BR) Accessible Route to Play Components (NC) Water closet clearance in single-user toilet rooms - in swinging door |
| Secondary Private Schools | (10.68) | 9.72 | Wheelchair Space Overlap in Assembly Areas Water closet clearance in single-user toilet rooms - out swinging door Ambulatory Accessible Toilet Compartments |
(20.40) | Location of Accessible Route to Stages Accessible Lockers Assistive Listening Systems (technical) |
| Undergraduate and postgraduate private schools | 1,482.99 | 1,624.15 | Accessible Dressing Rooms, Fitting Rooms, or Locker Rooms Accessible Machines and Equipment Accessible Route to Exercise Machines and Equipment |
(141.16) | Accessible Means of Entry to Pools (NC/ALT) Location of Accessible Route to Stages Accessible Machines and Equipment |
| Ski facilities | 53.21 | 53.30 | Water closet clearance in single-user toilet rooms - out swinging door Passenger Loading Zones Door and Gate Surfaces |
(0.09) | Water closet clearance in single-user toilet rooms - out swinging door Door and Gate Surfaces Passenger Loading Zones |
| Homeless Shelter | 152.47 | 66.96 | Social Service Establishment (ADAAG) Water closet clearance in single-user toilet rooms - out swinging door Shower Spray Controls |
85.51 | Social Service Establishment (UFAS) Shower Compartments with Mobility Features Detectable Warnings (scoping) |
| Food banks | 13.25 | 14.36 | Water closet clearance in single-user toilet rooms - out swinging door Parking Spaces Side Reach |
(1.11) | Water closet clearance in single-user toilet rooms - out swinging door Side Reach Parking Spaces |
| Social service establishments | (31.04) | 0.14 | Side Reach Water closet clearance in single-user toilet rooms - in swinging door Door and Gate Surfaces |
(31.18) | Water closet clearance in single-user toilet rooms - in swinging door Side Reach Door and Gate Surfaces |
| Exercise facilities | 1,790.96 | 2,315.14 | Accessible Machines and Equipment Accessible Route to Exercise Machines and Equipment Accessible Saunas and Steam Rooms (ALT/BR) |
(524.18) | Accessible Machines and Equipment Accessible Saunas and Steam Rooms (ALT/BR) Accessible Lockers |
| Swimming pools / Aquatic centers | 766.02 | 1,586.53 | Accessible Means of Entry to Wading Pools Accessible Means of Entry to Spas Accessible Means of Entry to Pools (NC/ALT) |
(820.51) | Accessible Means of Entry to Wading Pools Accessible Means of Entry to Pools (NC/ALT) Accessible Means of Entry to Spas |
| Bowling alleys | 234.83 | 236.40 | Accessible Route to Bowling Lanes Side Reach Door and Gate Surfaces |
(1.57) | Accessible Route to Bowling Lanes Side Reach Door and Gate Surfaces |
| Golf courses (private with public access) | 296.68 | 567.80 | Accessible Practice Grounds at Driving Ranges Accessible Route to Golf Courses Accessible Practice Grounds at Golf Courses (Alt/BR) |
(271.12) | Accessible Practice Grounds at Golf Courses (Alt/BR) Accessible Route to Golf Courses Water closet clearance in single-user toilet rooms - in swinging door |
| Golf courses (private only) | 87.83 | 222.87 | Accessible Practice Grounds at Driving Ranges Accessible Route to Golf Courses Accessible Practice Grounds at Golf Courses (Alt/BR) |
(135.04) | Accessible Practice Grounds at Golf Courses (Alt/BR) Water closet clearance in single-user toilet rooms - in swinging door Accessible Route to Golf Courses |
| Miniature golf courses | 401.84 | 485.14 | Accessible Route to Minigolf Holes Accessible Minigolf Holes Side Reach |
(83.30) | Accessible Minigolf Holes Accessible Route to Minigolf Holes Water closet clearance in single-user toilet rooms - in swinging door |
| Recreational boating facilities | (3.93) | 11.38 | Accessible Boat Slips (NC) Accessible Route for Boating Facilities Accessible Boarding Piers (NC) |
(15.31) | Accessible Boat Slips (NC) Accessible Route for Boating Facilities Water closet clearance in single-user toilet rooms - in swinging door |
| Fishing piers and platforms | 45.23 | 48.44 | Accessible Route to Fishing Piers Accessible Fishing Piers and Platforms |
(3.21) | Accessible Fishing Piers and Platforms Accessible Route to Fishing Piers |
| Shooting facilities | 221.29 | 220.99 | Shooting Facilities with Firing Positions Door and Gate Surfaces |
0.30 | Accessible Routes from Site Arrival Points and Within Sites Detectable Warnings (scoping) |
| Office buildings | (1,036.79) | 3.80 | Passenger Loading Zones Parking Spaces Stairs (NC) |
(1,040.59) | Stairs (ALT/BR) Alterations to Existing Elevators Side Reach |
| Elementary public schools | 53.97 | 332.79 | Accessible Play Components (BR) Water closet clearance in single-user toilet rooms - out swinging door Accessible Route to Play Components (BR) |
(278.82) | Accessible Route to Play Components (BR) Water closet clearance in single-user toilet rooms - in swinging door Accessible Route to Play Components (NC) |
| Secondary public schools | 161.26 | 296.93 | Wheelchair Space Overlap in Assembly Areas Water closet clearance in single-user toilet rooms - out swinging door Ambulatory Accessible Toilet Compartments |
(135.67) | Assistive Listening Systems (technical) Location of Accessible Route to Stages Water closet clearance in single-user toilet rooms - in swinging door |
| Undergraduate, postgraduate public schools | (228.83) | 17.33 | Water closet clearance in single-user toilet rooms - out swinging door Accessible Machines and Equipment Ambulatory Accessible Toilet Compartments |
(246.16) | Post Secondary School Multi-Story Dorm Facility Location of Accessible Route to Stages Stairs (ALT/BR) |
| Public housing | (0.47) | 168.54 | Water closet clearance in single-user toilet rooms - out swinging door Accessible Play Components (BR) Accessible Route to Play Components (BR) |
(169.01) | Stairs (ALT/BR) Accessible Route to Play Components (BR) Operable Windows |
| State and local judicial facilities (courthouses) | (516.95) | 0.85 | Water closet clearance in single-user toilet rooms - out swinging door Passenger Loading Zones Parking Spaces |
(517.80) | Accessible Attorney Areas and Witness Stands Water closet clearance in single-user toilet rooms - out swinging door Standby Power for Platform Lifts |
| State and local detention facilities (jails) | (3.11) | 0.02 | Shower Spray Controls Passenger Loading Zones Parking Spaces |
(3.14) | Shower Spray Controls Side Reach Door and Gate Surfaces |
| State and local correctional facilities (prisons) | (0.83) | 3.60 | Accessible Machines and Equipment Shower Spray Controls Passenger Loading Zones |
(4.42) | Stairs (ALT/BR) Accessible Machines and Equipment Shower Spray Controls |
| Parking garages | 182.97 | 187.80 | Mechanical Access Parking Garages Stairs (NC) Stairs (ALT/BR) |
(4.83) | Stairs (ALT/BR) Mechanical Access Parking Garages |
| Self service storage facilities | 15.11 | 19.50 | Self-Service Storage Access Stairs (NC) Side Reach |
(4.39) | Self-Service Storage Access Stairs (ALT/BR) Alterations to Existing Elevators |
| Theatre / Concert Halls (public) | (0.13) | 0.03 | Water closet clearance in single-user toilet rooms - out swinging door Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments |
(0.16) | Wheelchair Space Overlap in Assembly Areas Valet Parking Garages Assistive Listening Systems (technical) |
| Stadiums (public) | 12.42 | 50.37 | Passenger Loading Zones Wheelchair Space Overlap in Assembly Areas ATMs and Fare Machines |
(37.95) | Wheelchair Space Overlap in Assembly Areas Assistive Listening Systems (technical) Water closet clearance in single-user toilet rooms - out swinging door |
| Auditoriums (public) | 0.05 | 1.01 | Passenger Loading Zones Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments |
(0.97) | Wheelchair Space Overlap in Assembly Areas Location of Accessible Route to Stages Ambulatory Accessible Toilet Compartments |
| Convention centers (public) | 21.73 | 21.84 | Passenger Loading Zones Ambulatory Accessible Toilet Compartments ATMs and Fare Machines |
(0.11) | Assistive Listening Systems (technical) Location of Accessible Route to Stages Water closet clearance in single-user toilet rooms - in swinging door |
| Hospitals (public) | (4.68) | (4.02) | Passenger Loading Zones (Medical / Long-Term Care) Patient Toilet Rooms Multiple Single-User Toilet Rooms |
(0.66) | Water closet clearance in single-user toilet rooms - out swinging door Water closet clearance in single-user toilet rooms - in swinging door Accessible Means of Entry to Spas |
| Nursing homes (public) | (31.63) | (26.93) | Passenger Loading Zones (Medical / Long-Term Care) Detectable Warnings (scoping) Accessible Routes from Site Arrival Points and Within Sites |
(4.70) | Water closet clearance in single-user toilet rooms - out swinging door Side Reach Accessible Means of Entry to Spas |
| Museums, historical sites & libraries (public) | 91.31 | 105.48 | Wheelchair Space Overlap in Assembly Areas Passenger Loading Zones Parking Spaces |
(14.17) | Water closet clearance in single-user toilet rooms - in swinging door Wheelchair Space Overlap in Assembly Areas Assistive Listening Systems (technical) |
| Parks or zoos (public) | 465.75 | 617.36 | Water closet clearance in single-user toilet rooms - out swinging door Passenger Loading Zones Ambulatory Accessible Toilet Compartments |
(151.61) | Water closet clearance in single-user toilet rooms - in swinging door Accessible Route to Play Components (BR) Side Reach |
| Homeless Shelter (public) | 22.78 | 10.01 | Social Service Establishment (ADAAG) Water closet clearance in single-user toilet rooms - out swinging door Shower Spray Controls |
12.78 | Social Service Establishment (UFAS) Shower Compartments with Mobility Features Detectable Warnings (scoping) |
| Exercise facilities (public) | 13.92 | 20.41 | Accessible Machines and Equipment Ambulatory Accessible Toilet Compartments Accessible Lockers |
(6.49) | Accessible Machines and Equipment Wheelchair Space Overlap in Assembly Areas Side Reach |
| Social service establishments (public) | (13.28) | 0.06 | Side Reach Water closet clearance in single-user toilet rooms - in swinging door Door and Gate Surfaces |
(13.34) | Water closet clearance in single-user toilet rooms - in swinging door Side Reach Door and Gate Surfaces |
| Swimming pools / Aquatic centers (public) | 62.44 | 115.30 | Accessible Means of Entry to Wading Pools Accessible Means of Entry to Spas Accessible Means of Entry to Pools (NC/ALT) |
(52.87) | Accessible Means of Entry to Wading Pools Accessible Means of Entry to Pools (NC/ALT) Accessible Means of Entry to Spas |
| Miniature golf courses (public) | 15.03 | 16.88 | Accessible Route to Minigolf Holes Accessible Minigolf Holes Side Reach |
(1.84) | Accessible Minigolf Holes Water closet clearance in single-user toilet rooms - in swinging door Accessible Route to Minigolf Holes |
| Recreational boating facilities (public) | 0.94 | 10.62 | Accessible Route for Boating Facilities Accessible Boat Slips (NC) Accessible Boarding Piers (NC) |
(9.68) | Accessible Route for Boating Facilities Water closet clearance in single-user toilet rooms - in swinging door Accessible Boat Slips (NC) |
| Fishing piers and platforms (public) | 15.60 | 16.02 | Accessible Route to Fishing Piers Accessible Fishing Piers and Platforms |
(0.42) | Accessible Fishing Piers and Platforms Accessible Route to Fishing Piers |
| Office buildings (public) | (93.02) | 12.54 | Passenger Loading Zones Parking Spaces Stairs (NC) |
(105.56) | Stairs (ALT/BR) Alterations to Existing Elevators Side Reach |
| Parking garages (public) | 1.64 | 1.68 | Mechanical Access Parking Garages Stairs (NC) Stairs (ALT/BR) |
(0.04) | Stairs (ALT/BR) Mechanical Access Parking Garages |
| Golf courses (public) | 45.94 | 60.86 | Water closet clearance in single-user toilet rooms - out swinging door Accessible Route to Golf Courses Accessible Practice Grounds at Driving Ranges |
(14.92) | Accessible Practice Grounds at Golf Courses (Alt/BR) Water closet clearance in single-user toilet rooms - in swinging door Side Reach |
| Restaurants (public) | 0.07 | 0.09 | Passenger Loading Zones Parking Spaces Accessible Play Components (ALT) |
(0.02) | Water closet clearance in single-user toilet rooms - in swinging door Valet Parking Garages Side Reach |
| Amusement parks (public) | 33.65 | 34.20 | Accessible Route to Rides Water closet clearance in single-user toilet rooms - out swinging door Ambulatory Accessible Toilet Compartments |
(0.54) | Accessible Route to Rides Location of Accessible Route to Stages Wheelchair Space or Transfer Seat or Transfer Device |
5.1.5 Net Present Value for Public versus Private Facilities
Figure 12 shows the NPV for public and privately owned elementary and postgraduate schools. The results show a large discrepancy between public and private undergraduate and postgraduate schools. This result reflects how public facilities are not subject to the readily achievable barrier removal requirement. In this comparison, the supplemental requirements for exercise equipment are not costed for undergraduate and postgraduate public schools.
Figure 12: NPV for Selected Facilities with Public and Private
Table 9 presents the NPV for all private and all public facilities analyzed. While the total NPV is positive for both sets of groups, the NPV for private facilities ($7.4 B) is significantly higher than that for public facilities ($126 M). This is primarily due to the fact that there are significantly more private than public establishments.
The private facilities with the largest (positive or negative) NPV are Restaurants ($2.3 B), Exercise Facilities ($1.8 B), Undergraduate and Postgraduate Private Schools ($1.5 B) and Indoor Service Establishments (-$1.1 B). The public facility with the greatest benefits is Parks and zoos, with a positive NPV of $0.5 B. The public facility with the largest negative NPV is State and local Judicial Facilities (-$0.5 B).
Table 9: Net Present Value for Public and Private Facilities
| Facility Group | Private Facility Code | NPV Private Facilities ($ mil) |
Impact to Private Facilities |
Public Facility Code | NPV Public Facility ($ mil) |
Impact to Public Facilities |
|---|---|---|---|---|---|---|
| Inns | A | 353.58 | (7.80) | No public counterpart | ||
| Hotels | B | 594.05 | (170.57) | No public counterpart | ||
| Motels | C | 718.23 | (136.20) | No public counterpart | ||
| Restaurants | D | 2296.62 | (441.85) | BP | 0.07 | (0.02) |
| Motion Picture House | E | (114.02) | (140.75) | No public counterpart | ||
| Theatre / Concert Hall | F | (170.21) | (196.74) | AW | (0.13) | (0.16) |
| Stadiums | G | 4.96 | (14.32) | AX | 12.42 | (37.95) |
| Auditoriums | H | (3.61) | (13.43) | AY | 0.05 | (0.97) |
| Convention centers | I | 14.49 | (0.07) | AZ | 21.73 | (0.11) |
| Single level stores | J | (391.45) | (388.55) | No public counterpart | ||
| Shopping malls | K | 307.28 | (33.72) | No public counterpart | ||
| Indoor Service Establishments | L | (1109.49) | (1634.33) | No public counterpart | ||
| Offices of health care providers | M | (222.72) | (339.58) | No public counterpart | ||
| Hospitals | N | (29.56) | (19.29) | BB | (4.68) | (0.66) |
| Nursing homes | O | (303.38) | (114.70) | BC | (31.63) | (4.70) |
| Terminal (private airports) | P | 1.58 | 1.53 | No public counterpart | ||
| Depots | Q | 0.06 | 0.01 | No public counterpart | ||
| Museums, historical sites & libraries | R | 44.88 | (6.97) | BD | 91.31 | (14.17) |
| Parks or zoos | S | 45.50 | (2.77) | BE | 465.75 | (151.61) |
| Amusement parks | T | 773.40 | (71.36) | BQ | 33.65 | (0.54) |
| Nursery schools - Daycare | U | (23.15) | (107.30) | No public counterpart | ||
| Elementary schools | V | (33.10) | (113.71) | AN | 53.97 | (278.82) |
| Secondary Schools | W | (10.68) | (20.40) | AO | 161.26 | (135.67) |
| Undergraduate and postgraduate schools | X | 1482.99 | (141.16) | AP | (228.83) | (246.16) |
| Ski facilities | Y | 53.21 | (0.09) | No public counterpart | ||
| Homeless Shelter | Z | 152.47 | 85.51 | BF | 22.78 | 12.78 |
| Food banks | AA | 13.25 | 85.51 | No public counterpart | ||
| Social service establishments | AB | (31.04) | (31.18) | BH | (13.28) | (13.34) |
| Exercise facilities | AC | 1790.96 | (524.18) | BG | 13.92 | (6.49) |
| Aquatic centers / swimming pools | AD | 766.02 | (820.51) | BI | 62.44 | (52.87) |
| Bowling alleys | AE | 234.83 | (1.57) | No public counterpart | ||
| Golf courses (private with public access) | AF | 296.68 | (271.12) | No public counterpart | ||
| Golf courses | AG | 87.83 | (135.04) | BO | 45.94 | (14.92) |
| Miniature golf courses | AH | 401.84 | (83.30) | BJ | 15.03 | (1.84) |
| Recreational boating facilities | AI | (3.93) | (15.31) | BK | 0.94 | (9.68) |
| Fishing piers and platforms | AJ | 45.23 | (3.21) | BL | 15.60 | (0.42) |
| Shooting facilities | AK | 221.29 | 0.30 | No public counterpart | ||
| Office buildings | AM | (1036.79) | (1040.59) | BM | (93.02) | (105.56) |
| Public housing | No public counterpart | AQ | (0.47) | (169.01) | ||
| State and local judicial facilities (courthouses) | No public counterpart | AR | (516.95) | (517.80) | ||
| State and local detention facilities (jails) | No public counterpart | AS | (3.11) | (3.14) | ||
| State and local correctional facilities (prisons) | No public counterpart | AT | (0.83) | (4.42) | ||
| Parking garages | AU | 182.97 | (4.83) | BN | 1.64 | (0.04) |
| Self service storage facilities | AV | 15.11 | (4.39) | No public counterpart |
5.2 Results Under Additional Scenarios
This section discusses a few of the scenarios that are analyzed in this report. The scenarios are discussed in comparison with one or more other scenarios given a common basis. For review, the scenarios modeled in this analysis include: safe harbor (SH) and no safe harbor (NSH) for existing facilities compliant under the 1991 Standards; barrier removal that would be readily achievable in either 0%, 50%, or 100% of situations (RA0, RA50, and RA100); and alternate baselines using either the 1991 Standards or recent IBC editions (B1991, and B2000, B2003, and B2006)[4].
Results under safe harbor (SH) versus no safe harbor (NSH) are discussed assuming that 50% of barrier removal is readily achievable (RA50) and with the 1991 Standards as the baseline (B1991). In addition, results for RA0, and RA100 also assume SH and B1991. Alternative baselines for B1991, and the various IBC editions (B2000, B2003, and B2006) all assume SH and RA100.
5.2.1Safe Harbor and No Safe Harbor Scenarios
The following graphs (Figure 13, Figure 14, and Figure 15) show the NPV results for other scenarios. Figure 13 compares SH and NSH policies (both assuming RA50 and 1991 Standards). The difference in NPV is significant. Without SH, benefits are most likely to exceed costs by about $3.3 B whereas with SH, benefits exceed costs by over $7.6 B. Part of the explanation for this discrepancy is that under NSH, BR costs are applied to more stringent requirements and the level of benefits for many element's barrier removal are lower than costs. The larger costs are then magnified because of the larger numbers of facilities that would be required to undertake BR before the next rule-making occurs.
Figure 13: NPV Comparison -- Safe Harbor Policy: SH/RA50/ B1991 , NSH/RA50/ B1991
5.2.2 Readily Achievable Scenarios
Figure 14 provides an assessment of how NPV changes with different readily achievable assumptions. There is little variation among the three RA scenarios (RA0, RA50, and RA100): One of the reasons that the results of the RA scenarios do not vary significantly under safe harbor is that there are three offsetting effects working simultaneously. The first effect that pushes costs up is a higher barrier removal cost due to a higher number of elements subject to new requirements undergoing barrier removal. The second effect reduces costs because a higher RA% implies fewer alterations on elements subject to new requirements. Finally, the third effect increases the benefits as the RA% increases, because the rate of completion of elements related to new requirements is higher, and so are the benefits derived from them (benefits can be shown to increase at a decreasing rate). The combination of these three effects keeps the RA curves close to one another.
Figure 14: NPV Comparison -- Alternate Readily Achievable %: SH/ RA0, RA50, RA100/ B1991
5.2.3International Building Code (IBC) Scenarios
Figure 15 represents differences in NPV for different baselines, including the various IBC editions (B2000, B2003, and B2006). These probability curves indicate that the effect of changing the set of requirements that apply. The results indicate that B2000 (IBC 2000) has the highest NPV and B2006 (IBC 2006) has the lowest and B1991 is less than B2003 (IBC 2003). These results are due to changes in the make-up of the set of requirements that are included in each alternative baseline.
The alternative baselines for the different IBC fluctuate as various requirements, some with positive NPVs and some with negative NPVs, are included under the various IBC years. The NPV using the 2000 IBC as a baseline is highest of the four, and well above that for the 1991 Standards as twelve elements are no longer costed. This difference is primarily driven by the fact that the Side Reach requirement is already under the 2000 IBC and its NPV is not included. Using the 2003 IBC as a baseline, the NPV is still higher than under the 1991 Standards as a baseline, but lower than the 2000 IBC. This is largely due to the fact that Passenger Loading Zones are covered under the 2003 IBC and are thus no longer included, though it is counterbalanced by the fact that Accessible Attorney Areas and Witness Stands) and Location of Accessible Routes to are also no longer included. The total NPV using the 2006 IBC is lowest of all the scenarios (though not by much), as Transient Lodging Guest Room Vanities and Water Closet Clearances with Out-Swinging Doors are no longer included under this scenario.
Figure 15: NPV Comparison -- Alternate Baselines: SH/RA100/ B1991, B2000, B2003, B2006
As discussed previously in Section 2.4.3, it was not feasible to construct alternate IBC baselines for each requirement and facility nationwide that took into account actual IBC adoption by state and local jurisdictions. Nonetheless, to further assist stakeholders in assessing the impact of the proposed regulations, several more limited assessments were conducted that compared four illustrative proposed requirements against requirement-specific alternate IBC/ANSI baselines based on current IBC adoption by states and local jurisdictions nationwide. The results of these analyses demonstrate that consideration of requirement-specific alternate IBC/ANSI baselines on a requirement-by-requirement basis would likely lead to markedly lower incremental costs (and benefits) for many requirements.
Table 10 presents total comparative costs, benefits, and NPV for two illustrative proposed requirements when using either the primary baseline (1991 Standards) or a requirement-specific alternate IBC baseline. The two illustrative requirements -- barrier removal and alteration requirements for existing stairs (RIA Req. #10) and alterations requirements for existing elevators (RIA Req. # 16) -- were selected because they both appear in the "main" chapters of the IBC for which adoption is near universal. It is estimated that 95.63% of facilities nationwide are currently covered by IBC provisions that mirror these two proposed requirements for existing stairs and elevators. Thus, for purposes of these alternate IBC baselines, the expected values for costs and benefits were scaled by this same percentage. Using this methodology, the likely costs for these two requirements falls from $1.1 billion using the 1991 Standards as a baseline to $49 million using requirement-specific alternate IBC baselines.
Table 10: Costs, Benefits and NPV Comparison using Primary (1991 Standards) Baseline and Requirement-Specific Alternate IBC Baseline -- Req. # 10 and 16
1991 Standards Baseline ($ millions)| Requirement | Impact to Users (Benefits) | Impact to Facilities (Costs) * | NPV |
|---|---|---|---|
| 10-Stairs (ALT/BR) | 18.3 | (782.5) | (764.2) |
| 16-Alterations to Existing Elevators | 2.5 | (342.4) | (339.9) |
| Sum | 20.8 | (1,124.9) | (1,104.1) |
Alternate IBC Baseline ($ millions)
| Requirement | Impact to Users (Benefits) | Impact to Facilities (Costs) * | NPV |
|---|---|---|---|
| 10-Stairs (ALT/BR) | 0.8 | (34.1) | (33.3) |
| 16-Alterations to Existing Elevators | 0.1 | (14.9) | (14.8) |
| Sum | 0.9 | (49.0) | (48.1) |
Table 11 presents total costs, benefits, and NPV for two other illustrative proposed requirements using the same comparative baselines. This second set of illustrative proposed requirements -- water closet clearance requirements in single-user toilet rooms with in-swinging doors (RIA Req. # 32) and side reach requirements (RIA Req. # 37) -- were selected because they both appear in Chapter 11 of the IBC (through incorporation by reference of ANSI A117.1) which has been less widely adopted than some other IBC chapters. Nonetheless, it is still estimated that 31.03% of facilities nationwide are currently covered by IBC/ANSI A117.1 provisions that mirror these two proposed requirements for water closet clearances and side reach. Likely costs and benefits were thus scaled in a manner similar to that described above. Using this methodology, the likely costs for this second set of illustrative proposed requirements falls from $2.1 billion using the 1991 Standards as a baseline to $1.5 billion using requirement-specific alternate IBC/ANSI baselines.
Table 11: Costs, Benefits and NPV Comparison Using Primary (1991 Standards) Baseline and Requirement-Specific Alternate IBC/ANSI Baselines -- Req # 32 and 37
1991 Standards Baseline ($ millions)| Requirement | Impact to Users (Benefits) | Impact to Facilities (Costs) * | NPV |
|---|---|---|---|
| 32-Water closet clearance in single-user toilet rooms - in swinging door | 46.3 | (974.4) | (928.1) |
| 37-Side Reach | 184.2 | (1,154.8) | (970.6) |
| Sum | 230.5 | (2,129.2) | (1,898.7) |
Alternate IBC/ANSI A117.1 Baseline ($ millions)
| Requirement | Impact to Users (Benefits) | Impact to Facilities (Costs) * | NPV |
|---|---|---|---|
| 32-Water closet clearance in single-user toilet rooms - in swinging door | 31.9 | (672.0) | (640.1) |
| 37-Side Reach | 127.0 | (796.4) | (669.4) |
| Sum | 158.9 | (1,468.4) | (1,309.5) |
5.3 Relative Impact of Selected Assumptions
As noted in sections 3.4 and 4.3, this regulatory impact analysis incorporates risk analysis to understand the potential impact on results of the uncertainty surrounding assumptions and some data estimates. The results presented in preceding sections illustrate how parameters of uncertainties translate into variability of NPVs.
An additional assessment of impact of parameter values explores the change in benefits from alternate assumptions. The change in benefits is assessed at expected value. This approach of assessing impact is not a sensitivity analysis in which viable values are assessed, justified in economic literature. Instead, this approach is a stress analysis to asses the impact in results from a hypothetical change in one parameter. The approach is conducted for three variables: the premium on access time, the premium on use time, and the price elasticity of demand for facility visits.
The access time premium is defined in the model to range from 0.75 to 1.25 percent of the value of time. (The median of the range is 1.) This stress analysis assesses the impact on reducing the premium to 0.5. In other words, the access time change is valued at 50% of the base VOT.
The results below are for the complete list of requirements. Some requirements have no data since, in the baseline scenario, they were not costed (see Table 4). Reducing the premium used for access time by half (i.e. using an access premium of .5 instead of 1) reduces the benefits to users by that factor. Lowering the premium by one half reduces total net benefits to users from $16.3 billion to $10.7 billion, or 34%.[5]
Table 12: Impact on Results of Reduced to Access Time Premium
| Requirement (millions of dollars) | Baseline Scenario Premium=1 Impact to Users (Benefits and Costs) |
Impact of Reduced Premium On Net Benefits to Users Premium=.5 Impact to Users (Benefits and Costs) |
|---|---|---|
| Public Entrances | (22.3) | (11.1) |
| Maneuvering Clearance or Standby Power for Automatic Doors | 0.0 | 0.0 |
| Automatic Door Break-Out Openings | 0.0 | 0.0 |
| Thresholds at Doorways | 4.3 | 2.1 |
| Door and Gate Surfaces | 2.7 | 1.6 |
| Location of Accessible Routes | - | - |
| Common Use Circulation Paths in Employee Work Areas | - | - |
| Accessible Means of Egress | - | - |
| Stairs (NC) | 53.6 | 26.6 |
| Stairs (ALT/BR) | 18.3 | 9.1 |
| Handrails Along Walkways | - | - |
| Handrails | (24.8) | (14.2) |
| Accessible Routes from Site Arrival Points and Within Sites | (35.3) | (24.5) |
| Standby Power for Platform Lifts | 0.0 | 0.0 |
| Power-Operated Doors for Platform Lifts | 2.4 | 1.2 |
| Alterations to Existing Elevators | 2.5 | 1.3 |
| Platform Lifts in Hotel Guest Rooms and Dwelling Units | - | - |
| "LULA" and Private Residence Elevators | - | - |
| Van Accessible Parking Spaces | 59.9 | 35.9 |
| Valet Parking Garages | 175.2 | 87.4 |
| Mechanical Access Parking Garages | 187.3 | 91.8 |
| Direct Access Entrances from Parking Structures | 44.7 | 22.3 |
| Passenger Loading Zones | 1,885.3 | 968.7 |
| Parking Spaces | 992.4 | 500.4 |
| Parking Spaces (Signs) | (3.3) | (1.6) |
| Passenger Loading Zones (Medical / Long-Term Care) | (653.2) | (326.8) |
| Ambulatory Accessible Toilet Compartments | 497.9 | 322.8 |
| Water closet clearance in single-user toilet rooms - out swinging door | 2,364.4 | 1,398.0 |
| Shower Spray Controls | 207.2 | 152.1 |
| Urinals | (13.1) | (9.3) |
| Multiple Single-User Toilet Rooms | (6.0) | (3.0) |
| Water closet clearance in single-user toilet rooms - in swinging door | 46.3 | 28.5 |
| Water Closet Location and Rear Grab Bar | - | - |
| Patient Toilet Rooms | (5.4) | (2.7) |
| Drinking Fountains | 0.4 | 0.2 |
| Sinks | - | - |
| Side Reach | 184.2 | 99.8 |
| Sales and Service Counters (NC) | (11.0) | (5.6) |
| Sales and Service Counters (Alt) | (239.6) | (120.1) |
| Washing Machines and Clothes Dryers (technical) | 0.1 | 0.1 |
| Washing Machines and Clothes Dryers (Scoping) | 0.1 | 0.0 |
| Self-Service Storage Access | 19.8 | 9.9 |
| Limited Access Spaces and Machinery Spaces | - | - |
| Operable Parts | - | - |
| Transient lodging Guest Room Vanities | 1,093.7 | 623.3 |
| Operable Windows | 204.7 | 102.2 |
| Dwelling Units with Communication Features [1991] | 0.0 | 0.0 |
| Dwelling Units with Communication Features [UFAS] | 0.0 | 0.0 |
| Galley Kitchen Clearances | 47.7 | 38.0 |
| Shower Compartments with Mobility Features | (12.4) | (11.0) |
| Location of Accessible Route to Stages | 0.2 | 0.1 |
| Wheelchair Space Overlap in Assembly Areas | 498.1 | 474.3 |
| Lawn Seating in Assembly Areas | - | - |
| Handrails on Aisle Ramps in Assembly Areas | (400.9) | (200.8) |
| Wheelchair Spaces in Assembly Areas | (5.8) | (2.9) |
| Accessible Route to Tiered Dining Areas in Sports Facilities (NC) | (0.5) | (0.3) |
| Accessible Route to Press Boxes | (1.5) | (0.7) |
| Public TTYS | 0.0 | 0.0 |
| Public Telephone Volume Controls | 0.0 | 0.0 |
| Two-Way Communication Systems at Entrances | 7.9 | 3.9 |
| ATMs and Fare Machines | 37.5 | 18.8 |
| Assistive Listening Systems (technical) | 1.2 | 1.2 |
| Visible Alarms in Alterations to Existing Facilities | - | - |
| Detectable Warnings (scoping) | (71.9) | (35.9) |
| Detectable Warnings (technical) | - | - |
| Assistive Listening Systems (scoping) | (7.0) | (3.5) |
| Accessible Courtroom Stations | - | - |
| Accessible Attorney Areas and Witness Stands | 0.0 | 0.0 |
| Raised Courtroom Stations Not for Members of the Public | - | - |
| Accessible Route to Exercise Machines and Equipment | 1,115.9 | 809.6 |
| Accessible Machines and Equipment | 1,181.3 | 866.1 |
| Accessible Saunas and Steam Rooms (NC) | - | - |
| Accessible Lockers | 175.1 | 127.0 |
| Accessible Dressing Rooms, Fitting Rooms, or Locker Rooms | 247.1 | 122.8 |
| Wheelchair Spaces in Team or Player Seating Areas | 0.0 | 0.0 |
| Accessible Route in Court Sport Facilities | - | - |
| Accessible Route to Bowling Lanes | 233.6 | 221.9 |
| Shooting Facilities with Firing Positions | 223.7 | 218.1 |
| Accessible Means of Entry to Pools (NC/ALT) | 393.6 | 241.3 |
| Accessible Means of Entry to Wading Pools | 867.8 | 584.3 |
| Accessible Means of Entry to Spas | 779.5 | 470.2 |
| Accessible Route for Boating Facilities | 10.3 | 8.4 |
| Accessible Boarding Piers (NC) | 2.5 | 2.0 |
| Accessible Boarding Piers (ALT/BR) | - | - |
| Accessible Boat Slips (NC) | 9.4 | 7.7 |
| Accessible Boat Slips (Alt/BR) | - | - |
| Accessible Route to Fishing Piers | 32.3 | 31.4 |
| Accessible Fishing Piers and Platforms | 66.4 | 55.5 |
| Accessible Route to Golf Courses | 220.7 | 198.8 |
| Accessible Practice Grounds at Golf Courses (Alt/BR) | 162.4 | 146.2 |
| Accessible Practice Grounds at Golf Courses (NC) | - | - |
| Accessible Practice Grounds at Driving Ranges | 299.3 | 269.5 |
| Accessible Route to Minigolf Holes | 257.9 | 211.6 |
| Accessible Minigolf Holes | 243.9 | 200.6 |
| Accessible Route to Rides | 503.6 | 417.6 |
| Wheelchair Space or Transfer Seat or Transfer Device | 4.6 | 3.5 |
| Maneuvering Space in Load and Unload Area | 15.3 | 11.5 |
| Signs at Amusement Park rides | 5.1 | 3.9 |
| Accessible Route to Play Components (BR) | 194.0 | 116.0 |
| Accessible Play Components (BR) | 294.9 | 179.2 |
| Accessible Route to Play Components (ALT) | 270.6 | 136.2 |
| Accessible Play Components (ALT) | 402.0 | 202.6 |
| Accessible Route to Play Components (NC) | 84.1 | 46.1 |
| Accessible Play Components (NC) | 126.2 | 69.8 |
| Open Captioning in Sports Stadium | 0.0 | 0.0 |
| Post Secondary School Multi-Story Dorm Facility | 0.5 | 0.2 |
| Mobility Accessible Prison Cell | - | - |
| Communication Accessible Prison Cell | - | - |
| Social Service Establishment (UFAS) | (24.3) | (12.1) |
| Social Service Establishment (ADAAG) | 54.6 | 27.2 |
| Accessible Saunas and Steam Rooms (ALT/BR) | 553.1 | 404.8 |
| Accessible Means of Entry to Pools (BR) | 132.6 | 73.5 |
| Total for Entire Rule | 16,264.7 | 10,720.2 |
The use time premium is defined in the benefits model to range from 0.2 to 0.5 the base VOT (with the median use time premium at 0.35 the base VOT). This stress analysis examines the impact on reducing the median use time to 0.175. The results are shown below for the requirements with use value only. Reducing the premium used for use time by a half (i.e. using a use time premium of .175 instead of .35) lowers total net benefits to users[6] from $16.3 billion to $16.0 billion, or 2%.
Table 13: Impact on Results of Reduced to Use Time Premium
| Requirement (millions of dollars) | Impact to Users Baseline Use Value = .35 |
Impact to Users Alternate Use Value = .175 |
|---|---|---|
| Ambulatory Accessible Toilet Compartments | 497.86 | 489.93 |
| Water closet clearance in single-user toilet rooms - out swinging door | 2,364.39 | 2,308.18 |
| Shower Spray Controls | 207.18 | 160.14 |
| Urinals | -13.09 | -10.48 |
| Multiple Single-User Toilet Rooms | -5.96 | -5.96 |
| Water closet clearance in single-user toilet rooms - in swinging door | 46.28 | 42.70 |
| Transient lodging Guest Room Vanities | 1,093.72 | 1,013.12 |
| Shower Compartments with Mobility Features | -12.38 | -8.13 |
| Wheelchair Space Overlap in Assembly Areas | 498.06 | 396.24 |
| Assistive Listening Systems(technical) | 1.24 | 0.94 |
| Accessible Machines and Equipment | 1,181.32 | 1,167.83 |
| Accessible Fishing Piers and Platforms | 66.43 | 64.19 |
| Accessible Minigolf Holes | 243.92 | 243.06 |
| Accessible Play Components (BR) | 294.94 | 292.83 |
| Accessible Play Components (ALT) | 402.00 | 401.85 |
| Accessible Play Components (NC) | 126.17 | 125.75 |
| Total for Entire Rule | 16,264.7 | 15,940.5 |
The last stress analysis assesses the impact of reducing the price elasticity of demand for each facility. This analysis shows the overall minor impact the slope of the demand curve (which is derived, in part, from the elasticity) has on the change in consumer surplus. Reducing the elasticities by a half (meaning that each reducing in price leads to a smaller change in demand) reduces net benefits to users from $16.3 billion to $13.2 billion. The elasticity impacts only new uses of a facility and the new users of a newly independent accessible facility (e.g. aquatic centers / swimming pools). The facilities with a significant change in user benefits when the elasticity is reduced are the facilities with expected new users, brought about by the supplemental requirements.
Table 14: Impact on Results of Reduced Demand Elasticity At All Facilities
| Facility Group | Facility Index | Results Using Literature Elasticities Impact to Users | Results Using Literature Elasticities NPV | Results Using Elasticity Estimates Reduced by Half Impact to Users | Results Using Elasticity Estimates Reduced by Half NPV | Difference In Benefits $ |
Difference In Benefits % |
|---|---|---|---|---|---|---|---|
| Inns | A | 361.37 | 353.58 | 359.58 | 351.78 | (1.8) | -0.5% |
| Hotels | B | 764.62 | 594.05 | 761.52 | 590.95 | (3.1) | -0.4% |
| Motels | C | 854.43 | 718.23 | 845.26 | 709.06 | (9.2) | -1.1% |
| Restaurants | D | 2,738.47 | 2,296.62 | 2,732.40 | 2,290.55 | (6.1) | -0.2% |
| Motion Picture House | E | 26.73 | (114.02) | 26.66 | (114.09) | (0.1) | -0.3% |
| Theatre / Concert Hall | F | 26.53 | (170.21) | 26.51 | (170.23) | (0.0) | -0.1% |
| Stadiums | G | 19.28 | 4.96 | 19.26 | 4.94 | (0.0) | -0.1% |
| Auditoriums | H | 9.82 | (3.61) | 9.81 | (3.62) | (0.0) | -0.1% |
| Convention centers | I | 14.56 | 14.49 | 14.53 | 14.45 | (0.0) | -0.2% |
| Single level stores | J | (2.90) | (391.45) | (2.90) | (391.45) | 0.0 | 0.0% |
| Shopping malls | K | 341.00 | 307.28 | 340.47 | 306.75 | (0.5) | -0.2% |
| Indoor Service Establishments | L | 524.84 | (1,109.49) | 524.80 | (1,109.52) | (0.0) | 0.0% |
| Offices of health care providers | M | 116.86 | (222.72) | 116.86 | (222.72) | 0.0 | 0.0% |
| Hospitals | N | (10.27) | (29.56) | (10.27) | (29.56) | 0.0 | 0.0% |
| Nursing homes | O | (188.68) | (303.38) | (188.79) | (303.49) | (0.1) | 0.1% |
| Terminal (private airports) | P | 0.06 | 1.58 | 0.06 | 1.58 | 0.0 | 0.0% |
| Depots | Q | 0.05 | 0.06 | 0.05 | 0.06 | 0.0 | 0.0% |
| Museums, historical sites & libraries | R | 51.85 | 44.88 | 51.59 | 44.63 | (0.3) | -0.5% |
| Parks or zoos | S | 48.27 | 45.50 | 36.57 | 33.80 | (11.7) | -32.0% |
| Amusement parks | T | 844.76 | 773.40 | 537.02 | 770.43 | (307.7) | -57.3% |
| Nursery schools - Daycare | U | 84.15 | (23.15) | 84.08 | (23.22) | (0.1) | -0.1% |
| Elementary private schools | V | 80.61 | (33.10) | 80.46 | (33.25) | (0.2) | -0.2% |
| Secondary Private Schools | W | 9.72 | (10.68) | 9.72 | (10.69) | 0.0 | 0.0% |
| Undergraduate and postgraduate private schools | X | 1,624.15 | 1,482.99 | 1,615.61 | 1,474.45 | (8.5) | -0.5% |
| Ski facilities | Y | 53.30 | 53.21 | 28.21 | 53.21 | (25.1) | -88.9% |
| Homeless Shelter | Z | 66.96 | 152.47 | 66.83 | 152.34 | (0.1) | -0.2% |
| Food banks | AA | 14.36 | 13.25 | 14.34 | 13.23 | (0.0) | -0.1% |
| Social service establishments | AB | 0.14 | (31.04) | 0.14 | (31.04) | 0.0 | 0.0% |
| Exercise facilities | AC | 2,315.14 | 1,790.96 | 1,368.39 | 844.22 | (946.8) | -69.2% |
| Aquatic centers / swimming pools | AD | 1,586.53 | 766.02 | 967.77 | 695.29 | (618.8) | -63.9% |
| Bowling alleys | AE | 236.40 | 234.83 | 124.53 | 122.96 | (111.9) | -89.8% |
| Golf courses (private with public access) | AF | 567.80 | 296.68 | 319.40 | 294.77 | (248.4) | -77.8% |
| Golf courses (private only) | AG | 222.87 | 87.83 | 125.60 | 48.42 | (97.3) | -77.4% |
| Miniature golf courses | AH | 485.14 | 401.84 | 276.71 | 310.89 | (208.4) | -75.3% |
| Recreational boating facilities | AI | 11.38 | (3.93) | 7.41 | (7.90) | (4.0) | -53.6% |
| Fishing piers and platforms | AJ | 48.44 | 45.23 | 25.17 | 34.01 | (23.3) | -92.5% |
| Shooting facilities | AK | 220.99 | 221.29 | 112.69 | 215.12 | (108.3) | -96.1% |
| Office buildings | AM | 3.80 | (1,036.79) | 3.79 | (1,036.80) | (0.0) | -0.3% |
| Elementary public schools | AN | 332.79 | 53.97 | 332.44 | 53.62 | (0.4) | -0.1% |
| Secondary public schools | AO | 296.93 | 161.26 | 296.83 | 161.16 | (0.1) | 0.0% |
| Undergraduate, postgraduate public schools | AP | 17.33 | (228.83) | 17.19 | (228.97) | (0.1) | -0.8% |
| Public housing | AQ | 168.54 | (0.47) | 162.05 | (6.95) | (6.5) | -4.0% |
| State and local judicial facilities (courthouses) | AR | 0.85 | (516.95) | 0.85 | (516.95) | 0.0 | 0.0% |
| State and local detention facilities (jails) | AS | 0.02 | (3.11) | 0.02 | (3.11) | 0.0 | 0.0% |
| State and local correctional facilities (prisons) | AT | 3.60 | (0.83) | 3.60 | (0.83) | 0.0 | 0.0% |
| Parking garages | AU | 187.80 | 182.97 | 184.02 | 179.19 | (3.8) | -2.1% |
| Self service storage facilities | AV | 19.50 | 15.11 | 19.42 | 15.03 | (0.1) | -0.4% |
| Theatre / Concert Halls (public) | AW | 0.03 | (0.13) | 0.03 | (0.13) | 0.0 | 0.0% |
| Stadiums (public) | AX | 50.37 | 12.42 | 50.33 | 12.38 | (0.0) | -0.1% |
| Auditoriums (public) | AY | 1.01 | 0.05 | 1.01 | 0.05 | 0.0 | 0.0% |
| Convention centers (public) | AZ | 21.84 | 21.73 | 21.79 | 21.68 | (0.1) | -0.2% |
| Hospitals (public) | BB | (4.02) | (4.68) | (4.02) | (4.68) | 0.0 | 0.0% |
| Nursing homes (public) | BC | (26.93) | (31.63) | (26.95) | (31.65) | (0.0) | 0.1% |
| Museums, historical sites & libraries (public) | BD | 105.48 | 91.31 | 104.96 | 90.79 | (0.5) | -0.5% |
| Parks or zoos (public) | BE | 617.36 | 465.75 | 453.67 | 302.06 | (163.7) | -36.1% |
| Homeless Shelter (public) | BF | 10.01 | 22.78 | 9.99 | 22.76 | (0.0) | -0.2% |
| Exercise facilities (public) | BG | 20.41 | 13.92 | 11.98 | 5.49 | (8.4) | -70.4% |
| Social service establishments (public) | BH | 0.06 | (13.28) | 0.06 | (13.28) | 0.0 | 0.0% |
| Aquatic centers / swimming pools (public) | BI | 115.30 | 62.44 | 69.16 | 58.69 | (46.1) | -66.7% |
| Miniature golf courses (public) | BJ | 16.88 | 15.03 | 9.62 | 11.87 | (7.3) | -75.5% |
| Recreational boating facilities (public) | BK | 10.62 | 0.94 | 6.92 | (2.76) | (3.7) | -53.5% |
| Fishing piers and platforms (public) | BL | 16.02 | 15.60 | 8.33 | 11.89 | (7.7) | -92.3% |
| Office buildings (public) | BM | 12.54 | (93.02) | 12.49 | (93.08) | (0.0) | -0.4% |
| Parking garages (public) | BN | 1.68 | 1.64 | 1.65 | 1.61 | (0.0) | -1.8% |
| Golf courses (public) | BO | 60.86 | 45.94 | 34.20 | 45.74 | (26.7) | -78.0% |
| Restaurants (public) | BP | 0.09 | 0.07 | 0.09 | 0.07 | 0.0 | 0.0% |
| Amusement parks (public) | BQ | 34.20 | 33.65 | 17.97 | 17.61 | (16.2) | -90.3% |
| Total | 16,264.7 | 7,541.8 | 13,231.5 | 5,999.6 | (3,033.2) | -22.9% |
The three requirements with the largest positive NPVs and the three requirements with the largest negative NPVs can be characterized as key drivers of the overall costs and benefits to the Rule. The following figures present the driving factors behind the risk range for the NPV estimates for each of these requirements. Each graph indicates the level of risk attributable to each variable. Those factors that explain the largest portion of the risk are the ones that will have the largest impact on the overall NPV.
Top Negative Requirements (NPV $ millions)
The Side Reach requirement has one of the largest negative NPVs (-$970.6 million at the median) among the nearly one hundred requirements in the proposed Rule. Figure 16 illustrates the relative impact of various assumptions on the side reach NPV. The unit cost estimates for alterations are a significant driver for this requirement, and substantially greater than the impact from other assumptions. Unit costs for side reach under alterations can vary greatly, from $0 to $1,500 and with a median estimate of $150.
Figure 16: Distribution of Sensitivities for Requirement 37: Side Reach. NPV = -$970.6
Figure 17 illustrates the relative impact of various assumptions on the Water closet clearance in single user toilet rooms -- in swinging doors NPV. The range of estimates (incorporated to account for uncertainty regarding the actual figure) on the likelihood of occurrence are the most significant drivers for the range of results for the requirement's NPV. The range of alterations costs has the next most significant impact on the NPV range. The frequency of occurrence at single-level stores is the third most important driver of the NPV range, since there are a large number of single-level stores.
Figure 17: Distribution of Sensitivities for Requirement 32: Water closet clearance in single user toilet rooms -- in swinging doors. NPV = -928.1
Figure 18 illustrates the relative impact of various assumptions on the Passenger Loading Zones (Medical / Long-Term Care) NPV. The range of estimates (incorporated to account for uncertainty regarding the actual figure) on access time saved is the most significant drivers for the range of results for the requirement's NPV, followed closely by the frequency of use of the element.
Figure 18: Distribution of Sensitivities for Requirement 26: Passenger Loading Zones (Medical / Long-Term Care). NPV = -489.0
Top Positive Requirements (NPV $ millions)
Figure 19 illustrates the relative impact of various assumptions on the Passenger Loading Zones NPV. The range of estimates (incorporated to account for uncertainty regarding the actual figure) on likelihood that a user would experience benefits is the most significant driver on the requirement's NPV range, followed by the range of estimates around the likelihood that the element occurs and around the frequency of using the element.
Figure 19: Distribution of Sensitivities for Requirement 23: Passenger Loading Zones. NPV = 1,835.3
Figure 20 illustrates the relative impact of various assumptions for the Accessible Route to Exercise Machines and Equipment NPV. The range of estimates on likelihood that a user would experience benefits is the most significant driver on the requirement's NPV range, followed by range of estimates for the frequency of using the element and around the access time savings.
Figure 20: Distribution of Sensitivities for Requirement 70: Accessible Route to Exercise Machines and Equipment. NPV = 1,100.4
Figure 21 illustrates the relative impact of various assumptions on the Transient lodging Guest Room Vanities NPV. The range of estimates on access time savings is the most significant driver on the requirement's NPV range, followed by the range of estimates around the frequency of its use at motels, at hotels, and at inns.
Figure 21: Distribution of Sensitivities for Requirement 45: Transient lodging Guest Room Vanities. NPV = 1,071.5
The range of estimates modeled for several factors appear repeatedly as key drivers behind many of the requirements with the largest positive and negative NPV:
Likelihood that an element occurs,
Likelihood of benefiting from a requirement,
Frequency of use, and
Access time.
The two likelihood factors have standard rules to apply ranges around the point estimate in most cases (see Appendix 3F, 3G, and 4M). The frequency of use and access time estimates were developed based upon responses from the RAP Benefits Panel. These differ from the unit costs estimates ranges, which were developed separately at high, medium, and low for each requirement (and at new construction, alterations, and barrier removal).
Unquantified Benefits -- Option and Existence Values
In addition to the monetized benefits presented above, there are numerous other benefits that are likely to result from the proposed standards. Many of these benefits cannot be quantified, let alone monetized.[7] These benefits include: harmonized guidelines; increased business opportunities; increased social development; improved health benefits; higher social equity levels; user benefits for people without disabilities; and benefits to employees. Other qualitative benefits that are important, but unaccounted for, in the user benefits include option (or insurance) value and existence value. The option value is the value that people with and without disabilities derive from the opportunity to obtain the benefit of accessible facilities. The existence value is the value that people both with and without disabilities derive from the guarantees of equal protection and non-discrimination that are accorded through the provision of accessible facilities.
Other Unquantifiable Benefits
Substantial effort was taken in the development of the guidelines upon which the proposed standards will be based to ensure that they would be consistent with model codes such as the IBC 2003. This harmonization of other model codes with the ADA Standards will yield substantial benefits to businesses, architects, and State and local governments, in addition to the benefits generated for people with disabilities. The proposed standards represent essentially one set of requirements which eliminates confusion and unintentional failure to meet standards. It also reduces administrative costs associated with determining the exact requirements. The proposed standards will also make it easier for State and local codes to be certified as meeting or exceeding Federal standards.
Evidence supports the notion of children both with and without disabilities benefiting from interaction with one another.[8] Therefore, there will undoubtedly be social development benefits generated by an increase in accessible play areas. However, these are nearly impossible to quantify for several reasons. One, there is no guarantee that accessibility will generate play opportunities between children with and without disabilities. Two, there may be substantial overlap between other opportunities for these two groups to interact, such as schools and religious facilities. Three, it is not even certain what the unit of measurement for social development should be.
Increased access to play areas (for children) and recreational facilities such as gyms (for adults) can also provide improved health benefits.[9] Although, again, there may be an overlap with other opportunities for exercise,[10] this makes the actual impact of the new requirements difficult to quantify.
In addition, the proposed standards will substantially increase social equity, particularly for newly scoped facilities like play areas, recreational facilities, and judicial, detention and correctional facilities. Methods of measuring existence value attempt to measure some portion of this benefit, but only that portion of increased equity that is valued by non-users.
Finally, there is clearly a use benefit that individuals without disabilities get from certain accessibility features. Curb cuts in sidewalks make life easier for those using wheeled suitcases and backpacks or pushing a baby stroller. For people with a lot of baggage or a need to change clothes, the larger bathroom stalls can be a highly valued commodity. It is not just persons with disabilities who derive use value from accessibility features.
Employees with disabilities will also benefit from the proposed standards. Employees of the establishments in compliance with the proposed standards will experience greater accessibility when doing their work. The benefits an employee experiences in an accessible workplace are realized through the same changes in access time that are experienced by non-employee users. Employees perceive the time change as enabling more work to be done with greater ease. Increased efficiency is valuable to employees looking for advancement and valuable to employers who benefit from more productive workers. However, measuring benefits to employees with disabilities is difficult, in large part because there is little to no data on the number of employees with disabilities per facility group or establishment type, which would be necessary to generate the benefits per employee per facility.
From all this it can be determined that, in some cases, benefits may be underestimated. However, it is also possible to overestimate benefits. For example, consider a city block that already contains two facilities with play areas. Under the proposed standards, a new facility with a play area must make itself accessible even at an increased construction cost. The cost will be the same as for any other play area undergoing construction, but the benefit is likely to be lower given that play area demand for that area is likely already being well filled. This is impossible to take into account in a model that is designed to abstract away from these sorts of details. However, the possibility that benefits will actually fall short of median levels is taken into account using risk analysis.
Non-User Benefits: Insurance Value
Just because an individual is a non-user of accessible elements today, does not mean that he or she will remain so tomorrow. In any given year, there is some probability of an individual developing a disability (either temporary or permanent) that will necessitate use of these features. Therefore, even individuals who have no direct use for accessibility features today get a direct benefit from the knowledge of their existence should they need them in the future. This is like an insurance policy against any future disability -- hence the term insurance value or insurance benefit.
Non-User Benefits: Existence Value
As the name suggests, existence value is the benefit that individuals get from the mere existence of a good, service or resource -- in this case, accessibility. Unlike user value and insurance value, existence value does not require an individual to ever use the resource or even plan on using the resource in the future. There can be numerous reasons why individuals might value accessibility even if they do not require it now and do not ever anticipate needing it in the future. These include: bequest motives, benevolence toward relatives and/or friends who require accessibility features,[11] and general feelings of empathy and responsibility toward individuals with disabilities.
Bequest values -- the wish to leave accessible features to future generations -- do not seem appropriate in the present context. For something like a natural resource that has an infinite lifecycle (barring natural disaster or society's failure to preserve it), bequest values make sense. For structural changes made to facilities that may last up to forty years, but which might change again in more or less time, bequests make less sense. Even in buildings that comply fully with the proposed standards, it is unclear whether they will stand long enough to accumulate substantial bequest valuations.
Empathy and/or feelings of responsibility are closely related to another unquantified benefit -- social equity. Clearly this is a real phenomenon, as so many individuals without disabilities have worked toward the adoption of both the current and the proposed standards. However, it is difficult to measure and even more difficult to separate from other existence value benefits, like altruism which risks double-counting.[12]
Existence values run into an additional problem, in that even with appropriate surveys, users tend to carry over their use values into their evaluation of existence values. This makes the existence valuations of users and nonusers inconsistent with one another.[13] What remains are estimates of willingness-to-pay. One method which can be employed is to evaluate how much nonusers of one resource are willing to pay to use another similar resource. This option does not appear to be available in the case of accessibility features, however. As with altruism, the literature relies on surveys to estimate the actual willingness-to-pay values.
Relation to Model Results
Given that the range of possible NPV values for the entire rule is unlikely to be less than zero (see Section 5.1), the foregoing discussion of unquantified benefits has greatest potential impact on those particular requirements with negative NPVs. If requirements and their impacts can be considered separately, those with negative monetized NPVs will warrant closer evaluation. For these requirements, the actual total overall value to society includes the non-monetized benefits discussed above, and the true NPV for each is some value greater than the figure presented here.
[1] The costs to users are the increases in time that would result from less stringent requirements.
[2] New construction was modeled separately from alterations and barrier removal due to differences in other underlying assumptions.
[3] New construction, alterations, and barrier removal were all modeled separately in order to adequately take into account the impact of program access for public facilities and the exemptions provided to small playgrounds.
[4] See section 4.2.1 for a discussion of safe harbor and section 2.4.3 for a discussion of the relationship between the 1991 Standards and recent IBC editions.
[5] This $16.3 billion is not the same as the estimate for Total Expected Benefits in Table 5, because the latter includes any benefits to facilities from any less stringent requirements and does not net out the costs to users from less stringent requirements.
[6] Ibid.
[7] Many of these benefits were discussed in the Access Board's various regulatory assessments.
[8] The United States Architectural and Transportation Barriers Compliance Board, Final Accessibility Guidelines For Play Areas: Economic Assessment (October 2000), contains references supporting this. A copy is located at: http://www.access-board.gov/play/assess.htm.
[9] The United States Architectural And Transportation Barriers Compliance Board, Assessment of Benefits and Costs of Final Accessibility Guidelines for Recreation Facilities (September 2002), contains references supporting this. A copy is located at: http://www.access-board.gov/recreation/reg-assessment.htm.
[10] Although clearly there will be fewer alternatives absent the proposed standards.
[11] This is different from altruism, because altruism assumes no direct connection between the altruist and the recipient of the benefit. Altruism is a concept closely related to existence value, although it can be present among users and non-users alike. The Office of Budget and Management (OMB) rejects the notion of general altruism because it impacts costs and benefits equally (See OMB Circular A-4). In other words, the concern for the welfare of others would be present for users as well as industries. Since there is no reason to expect selective altruism in the ADA context, this type of altruism can be ignored in the analysis of existence value. Much of the material on altruism comes from McConnell, "Does Altruism Undermine Existence Value?" Journal of Environmental Economics and Management 32 (1997): 22-37.
[12] See, for example, Lazo, McClelland, and Schulze. "Economic Theory and Psychology of Non-Use Values." Land Economics 73, No. 3 (August, 1997): 358-371.
[13] Silberman, Gerlowski, and Williams. "Estimating Existence Value for Users and Nonusers of New Jersey Beaches." Land Economics 68, no. 2 (May, 1992): 225-236.
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last updated December 9, 2010