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

Annualized Costs to Large Transit Entities for Automated Announcement Systems

Second, the Final RA also examines likely annualized costs related to the requirement that large transit entities provide automated announcement systems for stop and route identification on their large vehicles operating in fixed route bus service. Large transit agencies, in turn, are defined in the 2016 Non-Rail Vehicle Guidelines as public transportation providers operating 100 or more buses in annual maximum service in fixed route bus modes, through either direct operation or contract, based on annual data required to be reported to the National Transportation Database [hereafter, “VOMS 100 threshold”]. See T104.4 (defining “large transit entity”); see also 49 CFR pt. 37 (regulations governing the DOT-administered National Transportation Database). While the scope of the automated announcement systems requirement is thus necessarily limited to larger transit entities, there are still—relatively speaking—a wide range of “sizes” within the community of covered transit agencies, which can range in fleet size from just over 100 buses operating in fixed route bus service to hundreds.

Accordingly, to provide a more refined picture of estimated costs to large transit entities for automated announcement systems, the Final RA separately models costs for this requirement based on three prototypical size-based “tiers”—Tiers I, II & III—with Tier I being on the smaller end of the size spectrum and Tier III on the larger end. These three size-based tiers are intended to represent the typical range of “sizes” of large transit agencies covered by the automated announcement system requirement. Assumptions about relevant cost-modeling characteristics for each of these three tiers of large transit agencies—namely, the number of large buses in annual maximum service in fixed route bus modes, fixed routes, garages, vehicle operators, and mechanics—along with estimates concerning the status and nature of current ITS deployments (if any) by these transit entities, serve as the framework for modeling costs.¹⁹ As detailed in the Final RA, assumptions about the number of transit agencies per tier, as well as their respective fixed route bus fleets and current state of ITS deployments, were developed from research by Access Board staff and data reported in the 2014 National Transportation Database. See Final RA, Section 5.1.1.

It also bears noting that the Final RA’s cost model for the automated announcement systems requirement accounts for potential growth by public transit agencies over time. That is, it is assumed that, every third year during the 12-year regulatory timeframe, one transit agency will “cross” the VOMS 100 threshold, and, thereby, become newly subject to the requirement for automated announcement systems. These “new” large transit agencies are assumed to have characteristics similar to—though slightly smaller than—large transit agencies in “Tier I,” based on the assumption that transit entities crossing the VOMS threshold will do so in an incremental fashion. See Final RA, Section 5.1.1.

Presented in Table 4 below are per-agency annualized costs for the automated announcement systems requirement under each of the Final RA’s three cost scenarios. These annualized costs range from about $44,000 (for a Tier I agency under the low scenario) to about $430,000 (for a Tier III agency under the high scenario). Under the primary scenario, which models the most likely set of cost assumptions, per-agency costs for announcement systems are estimated to be as follows: Tier I - $80,659; Tier II - $154,985; and, Tier III: $264,968.

Table 4 - Annualized Per Agency Costs of Automated Announcement Systems Requirement for Large Transit Agencies (Tiers I, II & III)

These annualized cost figures underscore the logical cost corollary that per-agency costs directly relate to agency size, with the “smallest” large transit agencies (Tier I) experiencing the lowest annualized costs under all scenarios, and, conversely, the “largest” large transit agencies (Tier III) having the highest annualized costs. Nonetheless, even for Tier III agencies, costs are not estimated to exceed $450,000 annually under even the high scenario.