Introduction
With the anticipated adoption of the revised regulations implementing Titles II and III of the Americans with Disabilities Act (ADA), including revised ADA Standards for Accessible Design (proposed standards), the Department of Justice (the Department) has commissioned this Final Regulatory Impact Analysis (RIA or regulatory analysis). The new standards are based upon the ADA/ABA Accessibility Guidelines (2004 ADAAG) published by the Architectural and Transportation Barriers Compliance Board (Access Board) on July 23, 2004.
The new standards will apply to new construction and alterations for both Title II and Title III entities. Types of facilities include single purpose facilities, such as hotels and classes of facilities, such as retail stores (e.g. clothing, etc.) or service establishments (e.g., banks, dry cleaners, etc.). Over one hundred substantive changes to the 1991 Standards and ADA regulations have been analyzed.
The Department is adopting a safe harbor (SH) policy for existing facilities that are compliant with the 1991 Standards. Under the safe harbor, the Department would deem compliance with the scoping and technical requirements in the 1991 Standards to constitute compliance with the ADA for purposes of meeting barrier removal obligations. Only elements in a covered facility that are in compliance with the 1991 Standards would be eligible for the safe harbor.
The "Final Regulatory Impact Analysis of The Proposed Revised Regulations Implementing Titles II and III of the ADA, Including Revised ADA Standards for Accessible Design: FINAL REPORT" includes a detailed discussion of the methodology and data used in the analysis and aggregate results.
This volume, the Supplemental Results, presents detailed tables of assumptions used and total likely benefits, costs and net benefits for each facility and each requirement. These results were calculated assuming the 1991 Standards as a baseline, Safe Harbor and 50% of barrier removal to be readily achievable. HDR|HLB
Key to Understanding Detailed CBA Chart (Facility)
Overview:
- These charts summarize details for requirements and facilities. The first table is the familiar breakdown of what is in our report: NPV, Total User Benefits, and Total Facility Costs and top drivers of each. The succeeding tables contain most of the specific information for understanding each facility. This document summarizes the key information cells.
Facility Data
Header Section
- Top left corner: Facility index, facility name
- Middle column: description whether facility is public or private (currently – will be expanded for facilities with both types)
- Number: number of existing facilities
- Growth: annual growth of facilities (determines number of new facilities)
- Elasticity: facility users' price responsiveness to increased use (based on published data)
- Market Price: total expenditures per visit per visit (if applicable)
- Sales $MM: total annual sales (if applicable)
- IA: income adjustment (proportion of disabled community that would go to a facility compared to general population)
- EOA & EOAn: measures ease of access at a facility. The ratio EOAn / EOA reflects the proportion of users who would have latent demand and would go more often with the proposed requirements.
- SA: percentage of total sales to persons with disabilities
- Savings minutes: total savings at the facility (all requirements)
- VOT average: average because different value of time for some different requirements
- VOTS: generalized price change = value of time * total time savings
- M: slope for demand curve (estimated from elasticity)
- Q0: total number of annual visits by persons with disabilities
- CS: annual consumer surplus (without new users)
- CSadj: Consumer surplus adjusted for new independent users
- Price per sf: used to estimate lost productive space cost
Data Section: Results are provided for each facility
- #: ID number
- Requirement: Name of requirement
- BR: Total discounted barrier removal capital cost
- Alt: Total discounted alterations capital cost
- NC: Total discounted new construction capital cost
- OM: Total discounted OM cost
- Space: Total discounted loss of productive space cost
- Replace: Total discounted replacement cost
- SV: Total discounted salvage value cost (if necessary)
- Benf: Total discounted benefits
- NPV: Net present value
| Facility | NPV (millions of $) | Total User Impact (millions of $) | Top 3 drivers of impact to users | Total Facility Impact (millions of $) | Top 3 drivers of impact to facilities |
|---|---|---|---|---|---|
| Inns | 499.53 | 519.19 | Bathrooms with vanities and water closet clearance out-swinging doors Operable Windows Side Reach | (19.65) | Bathrooms with vanities and water closet clearance out-swinging doors Side Reach Operable Windows |
| Hotels | 753.47 | 1,232.08 | Bathrooms with vanities and water closet clearance out-swinging doors Accessible Machines and Equipment Primary Accessible Means of Entry to Pools (NC/ALT) | (478.61) | Primary Accessible Means of Entry to Pools (NC/ALT) Bathrooms with vanities and water closet clearance out-swinging doors Stairs (ALT/BR) |
| Motels | 1,403.08 | 1,834.48 | Bathrooms with vanities and water closet clearance out-swinging doors Accessible Machines and Equipment Primary Accessible Means of Entry to Pools (NC/ALT) | (431.40) | Primary Accessible Means of Entry to Pools (NC/ALT) Bathrooms with vanities and water closet clearance out-swinging doors Side Reach |
| Restaurants | 1,413.77 | 1,742.54 | Passenger Loading Zones Parking Spaces Accessible Play Components (ALT) | (328.77) | Water closet clearance in single-user toilet rooms -in swinging door Side Reach Accessible Route to Play Components (BR) |
| Motion Picture House | (169.43) | 8.84 | Wheelchair Space Overlap in Assembly Areas Passenger Loading Zones Parking Spaces | (178.26) | Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments Water closet clearance in single-user toilet rooms -in swinging door |
| Theatre / Concert Hall | (145.52) | 25.37 | Water closet clearance in single-user toilet rooms -out swinging door Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments | (170.90) | Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments Location of Accessible Route to Stages |
| Stadiums | (10.90) | 18.85 | Passenger Loading Zones Wheelchair Space Overlap in Assembly Areas Van Accessible Parking Spaces | (29.75) | Wheelchair Space Overlap in Assembly Areas Water closet clearance in single-user toilet rooms -out swinging door Accessible Saunas and Steam Rooms (ALT/BR) |
| Auditoriums | (9.63) | 15.83 | Passenger Loading Zones Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments | (25.46) | Wheelchair Space Overlap in Assembly Areas Location of Accessible Route to Stages Ambulatory Accessible Toilet Compartments |
| Convention centers | 20.11 | 19.26 | Passenger Loading Zones Ambulatory Accessible Toilet Compartments Direct Access Entrances from Parking Structures | 0.85 | Assistive Listening Systems (scoping) Detectable Warnings (scoping) Handrails |
| Single level stores | (354.54) | 61.78 | Side Reach Water closet clearance in single-user toilet rooms -in swinging door Door and Gate Surfaces | (416.32) | Water closet clearance in single-user toilet rooms -in swinging door Side Reach Door and Gate Surfaces |
| Shopping malls | 280.14 | 328.01 | Passenger Loading Zones Ambulatory Accessible Toilet Compartments Accessible Play Components (ALT) | (47.87) | Stairs (ALT/BR) Ambulatory Accessible Toilet Compartments Water closet clearance in single-user toilet rooms -in swinging door |
| Indoor Service Establishments | (1,758.39) | 410.84 | Water closet clearance in single-user toilet rooms -out swinging door Side Reach ATMs and Fare Machines | (2,169.22) | Water closet clearance in single-user toilet rooms -out swinging door Side Reach ATMs and Fare Machines |
| Offices of health care providers | (228.77) | 76.99 | Water closet clearance in single-user toilet rooms -out swinging door Side Reach Stairs (NC) | (305.76) | Water closet clearance in single-user toilet rooms -out swinging door Stairs (ALT/BR) Side Reach |
| Hospitals | (26.42) | (1.70) | Passenger Loading Zones (Medical / Long-Term Care) Patient Toilet Rooms Multiple Single-User Toilet Rooms | (24.72) | Accessible Means of Entry to Spas Water closet clearance in single-user toilet rooms -out swinging door Water closet clearance in single-user toilet rooms -in swinging door |
| Nursing homes | (192.94) | (61.48) | Passenger Loading Zones (Medical / Long-Term Care) Detectable Warnings (scoping) Accessible Routes from Site Arrival Points and Within Sites | (131.46) | Water closet clearance in single-user toilet rooms -out swinging door Accessible Means of Entry to Spas Side Reach |
| Terminal (private airports) | 1.84 | 0.10 | Direct Access Entrances from Parking Structures Passenger Loading Zones Water closet clearance in single-user toilet rooms -out swinging door | 1.74 | Accessible Routes from Site Arrival Points and Within Sites Detectable Warnings (scoping) Sales and Service Counters (NC) |
| Depots | 0.10 | 0.08 | Passenger Loading Zones Water closet clearance in single-user toilet rooms -in swinging door Door and Gate Surfaces | 0.01 | Detectable Warnings (scoping) Handrails Sales and Service Counters (NC) |
| Museums, historical sites & libraries | 68.81 | 74.82 | Wheelchair Space Overlap in Assembly Areas Passenger Loading Zones Side Reach | (6.01) | Water closet clearance in single-user toilet rooms -in swinging door Wheelchair Space Overlap in Assembly Areas Stairs (ALT/BR) |
| Parks or zoos | 42.28 | 45.73 | Water closet clearance in single-user toilet rooms -out swinging door Passenger Loading Zones Ambulatory Accessible Toilet Compartments | (3.45) | Accessible Route to Play Components (BR) Water closet clearance in single-user toilet rooms -in swinging door Accessible Fishing Piers and Platforms |
| Amusement parks | 734.55 | 826.86 | Accessible Route to Rides Water closet clearance in single-user toilet rooms -out swinging door Ambulatory Accessible Toilet Compartments | (92.30) | Accessible Route to Rides Maneuvering Space in Load and Unload Area Signs at Amusement Park rides |
| Nursery schools -Daycare | (7.47) | 121.85 | Water closet clearance in single-user toilet rooms -out swinging door Accessible Play Components (NC) Accessible Route to Play Components (NC) | (129.32) | Accessible Route to Play Components (NC) Water closet clearance in single-user toilet rooms -out swinging door Side Reach |
| Elementary private schools | (29.65) | 67.44 | Accessible Play Components (BR) Accessible Route to Play Components (BR) Water closet clearance in single-user toilet rooms -out swinging door | (97.09) | Accessible Route to Play Components (BR) Accessible Route to Play Components (NC) Water closet clearance in single-user toilet rooms -in swinging door |
| Secondary Private Schools | (10.64) | 9.23 | Water closet clearance in single-user toilet rooms -out swinging door Wheelchair Space Overlap in Assembly Areas Accessible Machines and Equipment | (19.87) | Location of Accessible Route to Stages Accessible Lockers Side Reach |
| Undergraduate and postgraduate private schools | 1,475.53 | 1,628.02 | Accessible Machines and Equipment Water closet clearance in single-user toilet rooms -out swinging door Accessible Dressing Rooms, Fitting Rooms, or Locker Rooms | (152.49) | Primary Accessible Means of Entry to Pools (NC/ALT) Location of Accessible Route to Stages Accessible Machines and Equipment |
| Ski facilities | 45.94 | 46.03 | Water closet clearance in single-user toilet rooms -out swinging door Passenger Loading Zones Door and Gate Surfaces | (0.09) | Water closet clearance in single-user toilet rooms -out swinging door Door and Gate Surfaces Passenger Loading Zones |
| Homeless Shelter | 138.48 | 141.08 | Social Service Establishments – Clear Floor Space around Beds Water closet clearance in single-user toilet rooms -out swinging door Side Reach | (2.59) | Social Service Establishments – Clear Floor Space around Beds Water closet clearance in single-user toilet rooms -out swinging door Shower Spray Controls |
| Food banks | 15.70 | 16.92 | Water closet clearance in single-user toilet rooms -out swinging door Parking Spaces Side Reach | (1.22) | Water closet clearance in single-user toilet rooms -out swinging door Side Reach Parking Spaces |
| Social service establishments | (33.20) | 1.51 | Side Reach Water closet clearance in single-user toilet rooms -in swinging door Door and Gate Surfaces | (34.70) | Water closet clearance in single-user toilet rooms -in swinging door Side Reach Door and Gate Surfaces |
| Exercise facilities | 1,777.80 | 2,461.53 | Accessible Machines and Equipment Accessible Route to Exercise Machines and Equipment Accessible Saunas and Steam Rooms (ALT/BR) | (683.72) | Accessible Machines and Equipment Accessible Saunas and Steam Rooms (ALT/BR) Accessible Lockers |
| Swimming pools / Aquatic centers | 1,380.45 | 2,771.53 | Accessible Means of Entry to Wading Pools Primary Accessible Means of Entry to Pools (NC/ALT) Accessible Means of Entry to Spas | (1,391.08) | Accessible Means of Entry to Wading Pools Primary Accessible Means of Entry to Pools (NC/ALT) Primary Accessible Means of Entry to Pools (BR) |
| Bowling alleys | 133.35 | 134.73 | Accessible Route to Bowling Lanes Side Reach Door and Gate Surfaces | (1.37) | Accessible Route to Bowling Lanes Side Reach Door and Gate Surfaces |
| Golf courses (private with public access) | 805.36 | 842.80 | Accessible Practice Grounds at Driving Ranges Accessible Route to Golf Courses Accessible Teeing Grounds, Putting Greens, and Weather Stations (Alt/BR) | (37.44) | Accessible Teeing Grounds, Putting Greens, and Weather Stations (Alt/BR) Accessible Route to Golf Courses Accessible Practice Grounds at Driving Ranges |
| Golf courses (private only) | 178.37 | 199.05 | Accessible Practice Grounds at Driving Ranges Accessible Route to Golf Courses Accessible Teeing Grounds, Putting Greens, and Weather Stations (Alt/BR) | (20.69) | Accessible Teeing Grounds, Putting Greens, and Weather Stations (Alt/BR) Accessible Route to Golf Courses Water closet clearance in single-user toilet rooms -in swinging door |
| Miniature golf courses | 951.40 | 1,045.72 | Accessible Route to Minigolf Holes Accessible Minigolf Holes Side Reach | (94.33) | Accessible Minigolf Holes Accessible Route to Minigolf Holes Water closet clearance in single-user toilet rooms -in swinging door |
| Recreational boating facilities | (1.42) | 16.18 | Accessible Route for Boating Facilities Accessible Boat Slips (NC) Accessible Boarding Piers (NC) | (17.60) | Accessible Boat Slips (NC) Accessible Route for Boating Facilities Water closet clearance in single-user toilet rooms -in swinging door |
| Fishing piers and platforms | 41.40 | 44.95 | Accessible Route to Fishing Piers Accessible Fishing Piers and Platforms | (3.56) | Accessible Fishing Piers and Platforms Accessible Route to Fishing Piers |
| Shooting facilities | 256.76 | 256.22 | Shooting Facilities with Firing Positions Door and Gate Surfaces | 0.54 | Accessible Routes from Site Arrival Points and Within Sites Detectable Warnings (scoping) |
| Office buildings (new) | 0.00 | 0.00 | 0.00 | ||
| Office buildings | (1,036.49) | 3.55 | Passenger Loading Zones Parking Spaces Side Reach | (1,040.03) | Stairs (ALT/BR) Alterations to Existing Elevators Side Reach |
| Elementary public schools | 34.55 | 282.89 | Water closet clearance in single-user toilet rooms -out swinging door Accessible Play Components (BR) Accessible Route to Play Components (BR) | (248.34) | Accessible Route to Play Components (BR) Water closet clearance in single-user toilet rooms -in swinging door Side Reach |
| Secondary public schools | 181.74 | 297.85 | Water closet clearance in single-user toilet rooms -out swinging door Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments | (116.11) | Location of Accessible Route to Stages Water closet clearance in single-user toilet rooms -in swinging door Side Reach |
| Undergraduate, postgraduate public schools | (190.52) | 20.93 | Water closet clearance in single-user toilet rooms -out swinging door Accessible Machines and Equipment Accessible Means of Entry to Spas | (211.45) | Post Secondary School Multi-Story Dorm Facility Location of Accessible Route to Stages Stairs (ALT/BR) |
| Public housing | (25.45) | 147.21 | Water closet clearance in single-user toilet rooms -out swinging door Accessible Play Components (BR) Accessible Route to Play Components (BR) | (172.66) | Stairs (ALT/BR) Operable Windows Accessible Route to Play Components (BR) |
| State and local judicial facilities (courthouses) | (156.86) | 0.81 | Water closet clearance in single-user toilet rooms -out swinging door Side Reach Passenger Loading Zones | (157.67) | Accessible Attorney Areas and Witness Stands Water closet clearance in single-user toilet rooms -out swinging door Standby Power for Platform Lifts |
| State and local detention facilities (jails) | (0.20) | 0.02 | Shower Spray Controls Side Reach Passenger Loading Zones | (0.22) | Shower Spray Controls Side Reach Door and Gate Surfaces |
| State and local correctional facilities (prisons) | 39.98 | (7.26) | Mobility Accessible Prison Cell Detectable Warnings (scoping) Accessible Routes from Site Arrival Points and Within Sites | 47.24 | Mobility Accessible Prison Cell Shower Compartments with Mobility Features Accessible Routes from Site Arrival Points and Within Sites |
| Parking garages | 203.25 | 208.40 | Mechanical Access Parking Garages Stairs (NC) Stairs (ALT/BR) | (5.15) | Stairs (ALT/BR) Mechanical Access Parking Garages |
| Self service storage facilities | 23.03 | 29.32 | Self-Service Storage Access Side Reach Stairs (NC) | (6.30) | Self-Service Storage Access Stairs (ALT/BR) Side Reach |
| Theatre / Concert Halls (public) | (0.09) | 0.03 | Water closet clearance in single-user toilet rooms -out swinging door Ambulatory Accessible Toilet Compartments Wheelchair Space Overlap in Assembly Areas | (0.11) | Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments Location of Accessible Route to Stages |
| Stadiums (public) | (35.72) | 48.49 | Passenger Loading Zones Wheelchair Space Overlap in Assembly Areas Van Accessible Parking Spaces | (84.22) | Wheelchair Space Overlap in Assembly Areas Water closet clearance in single-user toilet rooms -out swinging door Assistive Listening Systems (technical) |
| Auditoriums (public) | (0.64) | 0.73 | Passenger Loading Zones Wheelchair Space Overlap in Assembly Areas Ambulatory Accessible Toilet Compartments | (1.37) | Wheelchair Space Overlap in Assembly Areas Location of Accessible Route to Stages Ambulatory Accessible Toilet Compartments |
| Convention centers (public) | 30.17 | 28.89 | Passenger Loading Zones Ambulatory Accessible Toilet Compartments Direct Access Entrances from Parking Structures | 1.28 | Assistive Listening Systems (scoping) Detectable Warnings (scoping) Handrails |
| Offices of health care providers (public) | 0.00 | 0.00 | 0.00 | ||
| Hospitals (public) | (2.69) | (1.35) | Passenger Loading Zones (Medical / Long-Term Care) Patient Toilet Rooms Multiple Single-User Toilet Rooms | (1.34) | Accessible Means of Entry to Spas Water closet clearance in single-user toilet rooms -out swinging door Water closet clearance in single-user toilet rooms -in swinging door |
| Nursing homes (public) | (19.52) | (13.47) | Passenger Loading Zones (Medical / Long-Term Care) Detectable Warnings (scoping) Accessible Routes from Site Arrival Points and Within Sites | (6.05) | Water closet clearance in single-user toilet rooms -out swinging door Accessible Means of Entry to Spas Side Reach |
| Museums, historical sites & libraries (public) | 99.05 | 111.24 | Wheelchair Space Overlap in Assembly Areas Passenger Loading Zones Side Reach | (12.20) | Water closet clearance in single-user toilet rooms -in swinging door Wheelchair Space Overlap in Assembly Areas Stairs (ALT/BR) |
| Parks or zoos (public) | 418.88 | 601.92 | Water closet clearance in single-user toilet rooms -out swinging door Passenger Loading Zones Ambulatory Accessible Toilet Compartments | (183.04) | Accessible Route to Play Components (BR) Water closet clearance in single-user toilet rooms -in swinging door Side Reach |
| Homeless Shelter (public) | 20.28 | 20.68 | Social Service Establishments – Clear Floor Space around Beds Water closet clearance in single-user toilet rooms -out swinging door Side Reach | (0.40) | Social Service Establishments – Clear Floor Space around Beds Water closet clearance in single-user toilet rooms -out swinging door Shower Spray Controls |
| Exercise facilities (public) | 25.83 | 35.20 | Accessible Machines and Equipment Ambulatory Accessible Toilet Compartments Accessible Lockers | (9.36) | Accessible Machines and Equipment Wheelchair Space Overlap in Assembly Areas Accessible Lockers |
| Social service establishments (public) | (13.65) | 0.57 | Side Reach Water closet clearance in single-user toilet rooms -in swinging door Door and Gate Surfaces | (14.22) | Water closet clearance in single-user toilet rooms -in swinging door Side Reach Door and Gate Surfaces |
| Swimming pools / Aquatic centers (public) | 125.53 | 215.22 | Accessible Means of Entry to Wading Pools Primary Accessible Means of Entry to Pools (NC/ALT) Accessible Means of Entry to Spas | (89.69) | Accessible Means of Entry to Wading Pools Primary Accessible Means of Entry to Pools (NC/ALT) Primary Accessible Means of Entry to Pools (BR) |
| Miniature golf courses (public) | 27.21 | 29.94 | Accessible Route to Minigolf Holes Accessible Minigolf Holes Side Reach | (2.73) | Accessible Minigolf Holes Water closet clearance in single-user toilet rooms -in swinging door Accessible Route to Minigolf Holes |
| Recreational boating facilities (public) | 4.59 | 18.33 | Accessible Route for Boating Facilities Accessible Boat Slips (NC) Accessible Boarding Piers (NC) | (13.74) | Accessible Route for Boating Facilities Water closet clearance in single-user toilet rooms -in swinging door Accessible Boat Slips (NC) |
| Fishing piers and platforms (public) | 26.24 | 26.95 | Accessible Route to Fishing Piers Accessible Fishing Piers and Platforms | (0.71) | Accessible Fishing Piers and Platforms Accessible Route to Fishing Piers |
| Office buildings (public) | (93.39) | 9.70 | Passenger Loading Zones Parking Spaces Side Reach | (103.09) | Stairs (ALT/BR) Alterations to Existing Elevators Side Reach |
| Parking garages (public) | 1.63 | 1.68 | Mechanical Access Parking Garages Stairs (NC) Stairs (ALT/BR) | (0.05) | Stairs (ALT/BR) Mechanical Access Parking Garages |
| Golf courses (public) | 85.05 | 89.49 | Water closet clearance in single-user toilet rooms -out swinging door Accessible Practice Grounds at Driving Ranges Accessible Route to Golf Courses | (4.43) | Water closet clearance in single-user toilet rooms -in swinging door Water closet clearance in single-user toilet rooms -out swinging door Side Reach |
| Restaurants (public) | 0.04 | 0.04 | Passenger Loading Zones Parking Spaces Side Reach | (0.00) | Water closet clearance in single-user toilet rooms -in swinging door Side Reach Valet Parking Garages |
| Amusement parks (public) | 38.83 | 39.68 | Accessible Route to Rides Water closet clearance in single-user toilet rooms -out swinging door Ambulatory Accessible Toilet Compartments | (0.85) | Accessible Route to Rides Location of Accessible Route to Stages Wheelchair Space or Transfer Seat or Transfer Device |
RIA Supplemental Table of Contents
March 11, 2011