36 CFR Part 1192 Americans with Disabilities Act (ADA) Accessibility Guidelines for Transportation Vehicles (2016 Non-Rail Vehicle Guidelines) - Preamble

Annualized Costs of New Accessibility Requirements for OTRBs

The third set of cost results presented in the Final RA relates to the four new OTRB-related accessibility requirements in the 2016 Non-Rail Vehicle Guidelines. Because various transportation-related industry sectors use OTRBs for scheduled transportation services, charter services, sightseeing, and other services, these accessibility requirements (unlike the automated announcement systems requirement) do not affect a discrete a set of regulated entities. Consequently, reliable estimates of per-firm costs related to the new OTRB accessibility requirements cannot be made. Instead, the Final RA examines costs for these four requirements on a per-vehicle and per-requirement basis.

With respect to per-requirement costs, the Final RA evaluates the respective costs of each of the four new OTRB accessibility requirements under the three cost scenarios over the projected 12-year term of the 2016 Non-Rail Vehicle Guidelines. For each cost scenario, results are broken down separately (in nominal dollars) by requirement for each year, and then presented as rolled-up annualized values for all requirements at 3% and 7% discount rates. In sum, the annualized cost for these four new requirements collectively across all OTRBs is estimated to be $0.9 million under the primary scenario at a 7% discount rate, while the low and high scenarios respectively project $0.5 million and $1.4 million in annualized costs using the same discount rate. For a complete presentation of cost-per-requirement results, see Final RA, Section 7.1.3 & Appendices F-1 to F-3.

Second, in terms of per-vehicle costs, the Final RA examines likely costs related to the four new OTRB accessibility requirements. Annualized costs of these new requirements are examined under each of the three cost scenarios, with results presented on a per-vehicle basis using 3% and 7% discount rates. The results from these per-vehicle annualized cost analyses are presented below in Table 5.

Table 5 - Per-Vehicle Annualized Costs of New Accessibility Requirements for OTRBs

As this table demonstrates, the cost of the new OTRB accessibility requirements are expected to be quite modest, when viewed from a per-vehicle perspective, under all three cost scenarios. Indeed, annualized costs per vehicle are only expected to be about $1,100 or less (depending on the discount rate) under the primary scenario.