Persons With Disabilities: Reports on Costs of Accommodations

Published by the Government Accountability Office on 1990-01-04.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

               United   States   General   Accounting   Office
               Briefing Report to
GAO            Congressional Requesters

               Reports on Costs
               of Accommodations
             United States

GAO          General Accounting  office
             Washington, D.C. 20548

             Human Resources        Division


             January 4,1996

             The Honorable Bill McCollum
             House of Representatives

             The Honorable Larry E. Craig
             House of Representatives

             This briefing report responds to your requests for information on the
             potential cost of implementing the proposed Americans With Disabilities
             Act (ADA) of 1989 (El. 933 and H.R. 2273), particularly to the private
             sector. The ADA would prohibit discrimination based on disability
             against any qualified person in employment and in programs and activi-
             ties operated by state governments. It would also prohibit discrimina-
             tion based on disability in public accommodations and services, public
             transportation, and telecommunications relay services.’

             Federal law prohibits federal contractors and recipients of federal assis-
Background   tance from discriminating against persons with disabilities. The Rehabil-
             itation Act of 1973 (section 503) requires government contractors with
             contracts greater than $2,500 to take affirmative action to hire persons
             with disabilities.’ Section 504 of the act prohibits excluding persons
             with disabilities solely because of their disabilities from federal pro-
             grams or activities receiving federal financial assistance. The proposed
             AM would extend the prohibitions of discrimination to private sector
             employment, state and local governments not receiving federal assis-
             tance, public transit and telephone services, and many private busi-
             nesses or entities used by the general public. Also, the ADA would
             incorporate the enforcement provisions of the Rehabilitation Act of
              1973, the Civil Rights Act of 1964, and the Fair Housing Act of 1968.”

             ‘Telecommunicationsrelay serviceslet personswith hearingand speechimpairmentsusetelephones
             or radios in ways that are functionally equivalent to the ways unimpairedpeopleusethem.
             “Throughout this report, we usepersonswith disabilities to refer to thosewith mental or physlcal
             disabilities or handicapswithin the meanmgof the Rehabilitation Act of 1973.
             “The Cwil Right?,Act of 1964bansdiscrimination on the basisof race,color, religion, or national
             origin in public accommodationsand programsreceivingfederal assistance,and in employment,also
             on the basisof sex. The Fair HousingAct of 1968prohibits discrimination in the saleor rental of
             housingother than single family housessold or rented by owners,or in the caseof a small landlord
             (one who owns and residesin a property that is occupiedby not morethan three families).

             Page I                                GAO/IiRD-9044BR      Costa of Accommodations    for Disabled

on buildings, 1 on employment, 3 on transportation,                   and 1 on telecom-
munications (see app. II).

Only certain specific building types are covered in the seven reports on
building accessibility,” discussed in app. III. For example, they variously
estimate costs of making accessible vocational schools; colleges, elemen-
tary , and secondary schools; a mixture of residential buildings and
office buildings; and a library.

The impact of section 504 of the Rehabilitation Act of 1973, which is
limited to recipients of federal assistance, is the subject of the three
reports on school building accessibility. They provide no current infor-
mation on the extent to which modifications have been completed to
comply with section 504 nor on additional schools that may require
modifications to comply with the ADA. The three reports use different
methodologies to derive their cost estimates. In two reports, the assump-
tions differ on the amount of space needing modification and the type of
modifications needed. A third report does not fully discuss its assump-
tions. This latter report estimates the cost of making 45 percent and 100
percent of all buildings first-floor-accessible. However, it does not fully
explain its derivation of the cost estimates, and bases these estimates on
information from only four colleges. Such a small sample may not be
representative of the universe to which it is projected.

The other four reports on building accessibility differ widely in what
they examine. For example, one looks at a federal office building,
another at Pennsylvania vocational schools. A third examines apart-
ment buildings, a town hall, and a convention hall. Two of the reports
compare the costs of initially designing buildings to provide accessibility
for persons with disabilities with the costs of renovating already com-
pleted buildings. Not surprisingly, they conclude that the former is less

All four reports have limitations. One points out that its use of new con-
struction cost estimating manuals to determine renovation cost is ques-
tionable. A second does not give the date of the cost data it uses, and a
third does not state how it estimates costs. The last relies on information
from only one state government’s department of insurance, which may
or may not be representative.

“Ruldmg accessibilitymeanshow easyIt is for personswith disabilities to get to, enter, and we a
facility. This includes appropriateentrances,exits, doorways,rest rooms,and elevators.Making
buildings accessiblecan involve prwiding curb cuts, rampedentrances,braille markings,and the like.

Page 3                               GAO/BRD9044BR Costaof Accommodationsfor Disabled

Please call me on (202) 275-1655 if you or your staff have any questions
about it. Other major contributors to the report are listed in appendix

Linda G. Morra
Director, Intergovernmental     and
   Management Issues

Page 5                        GAO/HRB9044BR Costs of Accommodationsfor Disabled

Appendix V                                                                                               21
Costs of Making         Transportation Options for Persons With Disabilities
Transit Systems         Cost Impact of DOT Rule on Transportation Services for                           22
Accessible to Persons       the Disabled Calculated
With Disabilities:      Costs of Rail Transit Accessibility Evaluated                                    23

Brief Descriptions
of Three Reports
Appendix VI                                                                                              25
Costs of Making         Description of Cost Data
                        Cost Data for Relay System
Telecommunications      Cost Data for Amplified Handsets for Public Telephones                           25
Accessible to Persons   Comments                                                                         26
With Disabilities:
Brief Description
of One Report
Appendix VII                                                                                            27
Major Contributors
to This Report
Tables                  Table V.l: Annual Cost Estimates for Transportation
                            System Modifications in Seven Cities
                        Table V.2: Annual Costs of Transportation System                                23
                            Modifications in Average-Sized Cities


                        ADA        Americans With Disabilities Act
                        ANSI       American National Standards Institute
                        cl30       Congressional Budget Office
                        Dm         Department of Transportation
                        FCC        Federal Communications Commission
                        HEW        Department of Health, Education, and Welfare
                        IKTD       Department of Housing and Urban Development
                        TDD        Telecommunications Devices for the Deaf
                        LJFAS      Uniform Federal Accessibility Standards

                        Page 7                     GAO/HRD-9044BR   Costs of Accommodations   for Disabled
Appendix I
Private Industry end Interest Groups and
Government Agencies C!ontacted for Study

Department of Labor, Employment Standards Administration
Department of Transportation
Federal Communications Commission
Internal Revenue Service
Office of Technology Assessment
President’s Commission on Employment of the Handicapped
Small Business Administration

Page 9                             GAO/HRD-9944BR   Costa of Accommodations   for Disabled
Costs of Making Buildings Accessible
to Persons With Disabilities:
Brief Descriptions of Seven Reports
                           These reports on building accessibility costs, identified through our
                           literature search and contacts with various organizations, were pub-
                           lished between 1975 and 1979. Our comments on each report are

                           O’Neill, D. M., Discrimination Against Handicapped Persons; The Costs,
Transportation             Benefits and Economic Impact of Implementing Section 504 of the Reha-
Options Evaluated          bilitation Act of 1973 Covering Recipients of HEW Financial Assistance.
for Persons                Washington, DC.: Department of Health, Education, and Welfare (HEW),
                           May 4,1977.
With Disabilities
                           The report investigates employment practices, program accessibility,
                           and elementary and secondary education in terms of implementing sec-
                           tion 504 of the Rehabilitation Act of 1973 (p. i).’ HEW’S Office of Facili-
                           ties, Engineering, and Property Management recommends estimating the
                           cost of new barrier-free construction at one-half of 1 percent of total
                           project costs (pp. 18-19). The report is a revised version of an impact
                           statement published in the Federal Register on May 17, 1976.

Description of Cost Data   The report estimates the capital cost of altering existing higher educa-
                           tion, elementary, and secondary education facilities by multiplying the
                           estimated value of all buildings at the end of the school years 1974-75
                           (higher education) and 1973-74 (elementary and secondary education)
                           by estimated cost factors (pp. 24 and 28).

                           The report multiplies the cost factor of .0056 .by the estimated value of
                           higher education buildings to estimate the cost of achieving accessibil-
                           ity. Here, accessibility is achieved at least cost by using reasonable alter-
                           natives to expensive renovation where possible. 2 The report uses cost
                           factors of .0089 for renovation and .0018 and .0028 for making one-
                           third to one-half of elementary and secondary school buildings first-
                           floor-accessible (pp. 28-34).

                           ‘Numbersin parenthesisrefer to pagenumbersof the reports
                           ‘For example,the stacksin the libraries of someuniversities have narrow halls and aislesand are
                           locatedon upper floors of bulldings built many years ago.Elevatorsare either nonexistent or of such
                           tiny dimensionsas to makeaccessvia a wheelchair impossiblewithout extensiverenovation.In this
                           case,a reasonablealternative to renovation would bethe assignmentof personnelto supply individu-
                           alized “stack searchs”for personswith disabilities.

                           Page 11                               GAO/HR@90443R        tits   of Accommodations   for Disabled
                               Appendix III
                               Costs of Making Buildings    Accessible to
                               Persons With Disabilities:   Brief Desctiptions
                               of Seven Reports

                               These include providing auxiliary aids, relocating classes or services,
                               and maintaining structural modifications such as elevators (p. 5).

                               The study estimates costs for 3,083 colleges and universities (p. 15),
                               15,891 public school districts (p. 17), 4,755 postsecondary vocational
                               schools (pp. 20 and SS), 7,271 hospitals (p. ZO), 26,748 residential health
                               facilities (p. 22), 7,002 outpatient health and other social service pro-
                               grams (pp. 23 and 91) 8,930 libraries (pp. 24,98, and 99), and 76 wel-
                               fare agencies (p. 24).

Cost Data                      The cost estimates (in millions of dollars) are:

                           l Structural modifications - $1,200-1,500 (p. 5).
                           . One-time nonstructural costs - $173 (p. 5).
                           l Annual continuing costs - $152-198 (p. 5).
                           l Kew construction and renovation - $25-43 (p. 5).

Comments                       Chapter 5 (pp. 139-148) cites limitations on the cost data from noncol-
                               lege HEW recipients. These include: ignorance of section 504 require-
                               ments, overestimates of costs (pp. 139 and 140), incomplete plans for
                               modifications (p. 142), and incomplete lists of recipients used for the
                               survey (p. 147). The college and university questionnaire was based on
                               one that has been administered repeatedly since 1968.

                               Wulfsberg, R. M., and R. J. Petersen, The Impact of Section 504 of the
Collegesand                    Rehabilitation Act of 1973 on American Colleges and Universities.
Universities Surveyed          Washington,       DC.: National Center for Education Statistics,              HEW,    June
as to Impact                   1979.
of New Legislation             The report details the results of a 1978 survey that studied modifica-
                               tions required to make colleges and universities accessible to people
                               with mobility impairments (p. 3). Of 700 schools contacted, 607

Description of Cost Data       Costs given for accessibility include such changes to the buildings as
                               modified walkways, stairs, and entrances, but exclude costs for auxil-
                               iary aids and services, such as readers for the blind (p. 3). Costs
                               incurred before September 15, 1978 (p. 3) are excluded.

                               Page 13                                  GAO/RlUN&44BR   Casts of Accommodations     for Disabled
                           Appendix ID
                           Costs of Making Buildings    Accessible to
                           Persons With Disabilities:   Brief Descriptions
                           of seven Rqmts

Description of Cost Data   The study compares costs to remove architectural barriers by alteration
                           and initial construction (pp. 47 and 89). It says that the cost of accessi-
                           bility is negligible when it is incorporated in the design phase. Further-
                           more, the study concludes that the cost of altering existing buildings is
                           relatively small when compared to total construction cost (p. 87).

Cost Data                  Estimates obtained from government contractors of the costs of remov-
                           ing barriers by alteration versus original design are listed for selected
                           buildings (p. 89), as follows:

                           Navy - Petty officers club - $10,800 vs. $2,880
                           Navy - Weapons engineering facility - $282,000 vs. $65,300
                           nnw - Horizon House, Philadelphia, PA - $11,130 vs. $5,315
                           HEW - Medical college - $39,138 vs. $10,853
                           nuo Germantown House. Philadelphia, PA - $3,000 vs. $500
                           HUD - Compton Towers, Wilmington, DE - $9,000 vs. $500
                           General Services Administration - Federal office building - $16,605 vs.

Comments                   The report does not state clearly how these cost estimates were
                           obtained. Although issued on July 15, 1975, the report does not clarify
                           the year of the cost data.

                           Schroeder, S., and E. Steinfeld, The Estimated Cost of Accessible Build-
Costs of Accessibility     ings. Syracuse University; sponsored by HUD. Washington, D.C.: U.S.
for Nine Buildings         Government Printing Office, Apr. 1979.
Estimated                   The report assesses construction costs for redesigning new buildings and
                            renovating existing buildings to make them accessible to persons with
                            physical disabilities. Nine buildings are analyzed. They include a high-
                            rise tower, garden apartments, a single-family house, a college dormi-
                            tory, a convention hall, a public branch library, a town hall, a college
                            classroom, and a retail shopping center. Eight of the buildings were
                            located in Syracuse, North Syracuse, Clarkstown, or Glen Falls, New
                            York; the ninth in Detroit, Michigan (pp. 141-142).

                            The authors conclude that it is much less expensive to design for acces-
                            sibility than to renovate existing structures. From the data, the authors
                            estimate that designing for accessibility generally adds from less than 1
                            to 15 percent to the cost of a new facility. Renovating existing buildings

                            Page 16                                  GAO/HRD4044BR   Costs of Accommodations   for Disabled
                           Appendix ID
                           Costs of Making Buildings    Accessible to
                           Persona With Disabilities:   Brief Descriptions
                           of seven Report.9

                           6. Divide the total cost of renovation and redesign for each building by
                           the construction cost to give the percentage increase in cost to meet
                           barrier-free design criteria.

                            Unit costs were obtained from reference estimating manuals, which pro-
                           ject costs for new construction (pp. 4-5). The report notes that “The
                            applicability of using [new construction cost] estimating manuals to
                           determine construction costs for renovation work is of questionable
                           validity ... [because] renovation costs may vary substantially from new
                            construction costs depending on the specific project conditions, the
                           quantities of materials required, and removal and demolition costs”
                            (P. 5).

                           Associated Educational Consultants, Inc., Physical Accessibility of Pub-
Costs of Modifying         lit Supported Vocational Schools for Handicapped Students. Sponsored
Vocational Schools for     b y HEW, National Institute of Education. Pittsburgh, PA.: 1978.

                           The report estimates costs of structural modifications to make Penn-
Projected                  sylvania vocational programs accessible to the disabled under standards
                           of the American National Standards Institute (pp. l-3).

Description of Cost Data   Costs are estimated for 78 area vocational technical schools, 12 high
                           schools in Pittsburgh that offer vocational programs, and 15 community
                           colleges that offer occupational education courses (pp. 2,3, and 10). The
                           year of the cost data is not clearly stated.

Cost Data                  Total estimated costs for structural modifications for vocational schools
                           are $1,228,903; for Pittsburgh high schools, $834,550; and for commu-
                           nity colleges, $499,468. Total for all categories is $2,562,921 (pp. 2, 3,
                           37, and 38).

                           The report summarizes costs for the following structural features: park-
                           ing lots, walks, ramps, entrances and exits, doors and doorways, stairs
                           and steps, rest rooms, water fountains, elevators, controls, identifica-
                           tion, and warning signals (pp. 37-38).

Comments                   Teams of architects and educational consultants obtained data through
                           on-site visits (p. 7). They pretested the data collection instrument at
                           three area vocational schools (p. 5). The report presents nonrecurring

                           Page 17                                  GAO/HRD9044BR   Costs of Accommodations   for Disabled
Appendix IV

Costs of Employment Accommodations
for PersonsWith Disabilities:
Brief Description of One Report
                 We located only one report on costs of employment accommodations for
                 persons with disabilities.

                 Berkeley Planning Associates, A Study of Accommodations Provided to
                 Handicapped Employees by Federal Contractors: Vol. I, Study Findings;
                 Vol. II, Ten Case Studies. Sponsored by the Employment Standards
                 Administration, Department of Labor. Berkeley, CA: June 17, 1982.

                 This is a study of job accommodations provided to employees with disa-
                 bilities by federal contractors covered by section 503 of the Rehabilita-
                 tion Act of 1973. The authors surveyed 2,000 contractors, of which 367
                 responded (pp. i and 7). They estimated that about 3.5 percent of the
                 workers employed by the respondents had disabilities (p. ii and 16). Of
                 the workers with disabilities, 22 percent received some form of accom-
                 modation, generally inexpensive (pp. 20 and 29).

                 Accommodations for individual workers included adapting the physical
                 environment, providing transportation, special equipment or aids, or
                 retraining or selective placement of the worker (pp. ii, 22, and 23). No
                 particular type of accommodation dominated (p. ii). Among the most
                 frequent accessibility modifications were parking, curb cuts, ramped
                 entrances, and wheelchair access to work areas (pp. 26 and 27). The
                 report does not state the year of cost data obtained.

                 The report does not show total costs or costs of individual accommoda-
Description of   tions. It provides tables showing the percentage distribution of total
Cost Data        costs of accommodations by accommodation and disability type (pp. 30
                 and 66).

                 Of the accommodations reported, 51 percent cost nothing and another
Cost Data        30 percent cost less than $500, the study concluded. Only 8 percent of
                 the workers received accommodations costing more than $2,000 (pp. ii
                 and 28).

                 The greatest costs incurred were on behalf of persons receiving audio-
                 visual aids. The lowest costs were associated with relocating worksites;
                 changing hours, work procedures, and task assignments; transferring
                 the workers to a new job; and orienting coworkers (p. 31).

                 Page 19                     GAO/HRD.9O44BR   Costs of Accommodations   for Disabled
Appendix V

Costs of Making Transit Systems Accessible
to PersonsWith Disabilities:
Brief Descriptions of Three Reports
                               We identified three reports on the cost of making transportation         services
                               accessible to persons with disabilities.

                               IJS. Congressional Budget Office, Urban Transportation for Handi-
Transportation                 capped Persons: Alternative Federal Approaches. Washington, DC.:
Options for Persons            Nov. 1979.
With Disabilities              CROevaluated three options for providing transportation services to dis-
Evaluated                      abled people living in urban areas of the United States (p. xii). A transit
                               plan includes adding wheelchair lifts to buses, elevators in rail stations,
                               and at least one wheelchair-adapted car per train. A taxi plan calls for
                               small modifications to existing cabs and door-to-door public transporta-
                               tion for the severely disabled. An auto plan offers disabled people
                               financial aid to buy modified cars, as well as door-to-door public trans-
                               portation for those unable to drive cars (p. xii).

Description of Cost Data       The report-gives total capital and operating costs over the years 1980 to
                               2010 in 1979 dollars for each of the three plans for providing transpor-
                               tation services to persons with disabilities in urban areas (pp. 70 and

                               The transit changes would serve about 7 percent of all persons with
                               severe disabilities living in 17,s. urban areas, the taxi plan 26 percent,
                               and the auto plan 30 percent (p. xv).

Cost Data                  l Transit plan - $6.8 billion
                           . Taxi plan - $4.4 billion
                           . Auto plan - $6.3 billion (p. 70)

Comments                       Each cost estimate is net of estimated fare revenue from passengers
                               with disabilities (note a, table 17, p. 70). The report does not clearly
                               explain the methodology used to generate these estimates. The corre-
                               sponding gross cost estimates (table 10, p. 46) appear to have been
                               obtained inappropriately by adding nonrecurring capital costs to recur-
                               ring operating costs. The correct method for obtaining each estimate
                               would have been to add each plan’s estimated nonrecurring costs to the
                               discounted present value of the stream of operating costs incurred
                               through the life of the plan. Computed in this manner, the estimated
                               total cost of each plan would be less than the amount reported (tables 10

                               Page 21                       GAO/~904BR      Costs of Accommodations   for Disabled
                                            Appendix V
                                            Costa of Making Transit Systems Accessible
                                            to Persons With Disabilities:  Brief
                                            Descriptions  of Three Reports

                                            did not, however, require a specific percentage of buses to be lift-

Table V.l: Annual Cost Estimates for
Transportation  System Modifications in     Flaures are in thousands
Seven Cities                                                                                      Current           Adjusted  cost to meet
                                                                                           total program                       section 504
                                            City                                                     costs             implementing    rules
                                            Cleveland                                               $3.900”                           $3.119”
                                            Pittsburgh                                                2,793”                           2,69ab
                                            Seattle                                                   1,218                            1,200
                                            Kansas City, MO                                           1,079”                             555b
                                            Akron, OH                                                 1,145                              242
                                            Hampton, VA                                                  93”                              103b
                                            Brockton, MA                                                585”                             245”
                                            '1982 dollars
                                            "1982.83 dollars

Table V.2: Annual Costs of
Transportation  System Modifications   in   Figures are in thousands of 1983 dollars
Average-Sized   Cities                      Population                               Paratransit        User-side    taxi      50% lift bus
                                            Fewer than 250,000                               $247                     $92                $35
                                            250,000-500.000                                   393                     126                160
                                            500 000-1.000.000                                 515                     155                300
                                            Over 1.OOO,OOO                                  1,016                     196                960

Comments                                    The report makes so many assumptions and adjustments (detailed in
                                            app. B) that extensive sensitivity analysis would be needed to assess the
                                            reported estimates. A consultant developed the second cost estimation
                                            method, an econometric model, which was not included in the report.

                                            U.S. Department of Transportation, An Evaluation of Making Rail
Costs of Rail Transit                       Transit Systems Accessible to Handicapped Persons. Washington, D.C.:
Accessibility                               Jan. 1981.
                                            Section 321 of the Surface Transportation Assistance Act of 1978
                                            required this report. It concluded that the cost of making rail mass
                                            transportation accessible to persons with disabilities could not be accu-
                                            rately estimated at that time (p. 2). Estimates of costs to comply with
                                            parts of DOT’S regulation under section 504 of the Rehabilitation Act of

                                            Page 23                              GAO/HRINO44BR      Costs of Accommodations     for Disabled
Costs of Making Telecommunications Accessible
to PersonsWith Disabilities:
Brief Description of One Report
                            We identified only one report on telecommunications accessibility cost in
                            our literature search and from contacts with various organizations.

                            Federal Communications Commission, Order Completing Inquiry and
                            Providing Further Notice of Proposed Rulemaking - FCC 89-242. Wash-
                            ington, DC.: released July 27, 1989.

                            In this document, the FCC solicited comments on two proposed plans
                            (pp. 3,4, 16, 20,21, and 47) presenting different options for the design,
                            organization, operation, and funding of an interstate telecommunica-
                            tions relay system (pp. 17 and 21). Additionally, the FCC requested com-
                            ments on cost estimates of different components (pp. 16 and 21).

                            FCC’S analysis uses the California intrastate relay system as a model
Description                 (p. 15). PCCestimates startup and annual operating costs for systems
of Cost Data                with one and two relay centers (pp. 16,21, and 23).

                            IJsing estimates provided by parties who commented on its earlier
                            notice, the FCC estimates the cost of requiring 25 percent of public tele-
                            phones to be equipped with amplified handsets (pp. 40 and 35).

                            The report presumably expresses costs in 1989 dollars, but does not
                            explicitly state this,

                            Startup cost (in millions of dollars):
Cost Data for
Relay System            n   1 center - $1.5
                        l   2 centers - $3

                            Annual operating cost (in millions of dollars):

                        l 1 center - $15
                        . 2 centers - $30 (pp. 16,21, and 23)

                            FCCreports that the cost to install amplified handsets to 25 percent of
Cost Data for               the phones of the companies commenting on this proposal exceeds $16
Amplified Handsets          million (pp. 40 and 35). Individual companies/users estimate costs (in
for Public Telephones       millions of dollars) as follows:

                        l   Ameritech Operating Companies - $4.3

                            Page 25                       GAO/HRD-9044BR   Costs of Accommodations   for Disabled
Appendix VII

Major Contributors to This Report

                        William J. Kruvant, Assistant Director, (202) 275-5186
Human Resources         Catherine V. Pardee, Evaluator-in-Charge
Division, Washington,   Veronica Scott, Evaluator
D.C.            -

(118280)                Page 27                     GAO/HRD9044BR   Cmta of Accommodations   for Disabled
               Appendix VI
               Costs of Making Telecommunicatioxw
               Accessible to Persons With Disabilities:     Brief
               Description  of One Report

           l Bell Atlantic Telephone Companies - $2.0
           . New York Telephone - $2.0
           l New England Telephone - $1 .O(p. 37)
           l Pacific Bell - $3.7 (p. 38)
           l Southwestern Bell Telephone Company - $4.86 (p. 38)

               Ameritech estimates a cost of $2.9 to convert its remaining convertible
               stations to be wheelchair-accessible (p. 42).

               The FCC estimates the operating cost of a relay system to permit the deaf
Comments       to use telephones by extrapolating the experience of California, which
               operates an intrastate network, the California relay system. Such appa-
               ratus is called “telecommunications devices for the deaf” (TDDS). The FCC
               assumes that the California TDD user population is, in terms of its calling
               habits, representative of the nation’s TDD user population. Given this
               assumption, the FCC estimates the average monthly number of intrastate
               and interstate TDD calls to be 2,265,OOOand the interstate component of
               this to be 271,800 (p. 16). In California, the average TDD call costs $7.00
               (p. 13). If this cost is applied to the estimated monthly number of inter-
               state TDD calls, the estimated total operating cost of a national TDD relay
               system would be $1,902,600 ($7.00 X 271,800) per month or
               $22,831,200 annually. FCC estimates the annual cost to be $15 to
               $30 million.

                Page 26                                   GAO/HRD9644BR   Costs of Accommodations   for Disabled
                               Appendix V
                               Casts of Making Transit Systems Accessible
                               to Persons With Disabilities:  Brief
                               Descriptions  of Three Reports

                               1973 are included but not costs of interim and connector services, acces-
                               sible bus systems, and other nonrail requirements (p. 6).

Description of Cost Data       The study presents transit authority cost estimates to make urban rail
                               transit systems in 10 areas accessible to persons with disabilities. The
                               study estimates are in constant 1979 dollars over a 30-year period for
                               rapid and commuter rail and 20 years for light rail (p. 9 and 10). They
                               include cumulative sums of capital and operating costs incurred to make
                               the systems accessible.

Cost Data                      The total cost estimates (in millions of dollars) for the 10 areas are:

                           .   Boston - $ 96.3
                           .   Chicago - $ 828.6
                           .   Cleveland - $ 40.6
                           .   Detroit - $7.1
                           .   New Jersey - $24.1
                           .   New York - $2,710.0
                           .   Philadelphia - $251.2
                           .   Pittsburgh - $15.3
                           .   San Francisco - $18.3
                           .   Washington/Baltimore - $10.3
                           .   Total - $4,201.8 (p. 11)

                               DOT’Searlier estimate, developed at the time its section 504 regulation
                               was issued, was $1.1 billion (p. 2).

Comments                       The $4.2 billion cost estimate is misleading. Instead of summing the pro-
                               jected annual costs, the study should have discounted each stream of
                                annual costs back to a present value, in accordance with Office of Man-
                               agement and Budget Circular A-94. If computed according to the guide-
                               lines laid out in A-94, the estimated total cost would be less than $4.2
                               billion. Aside from the issue of how to compute the estimated total cost,
                               the accuracy of the estimates provided by the transit operators is ques-
                               tionable. Groups representing persons with disabilities and a group of
                               extramural reviewers claimed that these estimates were, for a variety of
                               reasons, overstated (pp. 14-19).

                               Page 24                              GAO/HFKHO44BR   Costs of Accommodations   for Disabled
                               Appendix V
                               Costs of Making Transit Systems Accessible
                               to Persons With Disabilities:  Brief
                               Descriptions  of Three Reports

                               and 17). Despite the report’s assertion (n. 1, p. 47), costs of alternative
                               options must be discounted to select the least costly option. Simply add-
                               ing up each option’s future annual costs assumes that the discount rate
                               is zero. If one option has relatively near-term costs and low out-year
                               costs, assuming a zero discount rate will bias the choice in favor of that

                               U.S. Department of Transportation (nor), Final Regulatory Impact Anal-
Cost Impact                    ysis - The Department of Transportation’s Regulation Implementing
of DOI’ Rule on                Section 504 of the Rehabilitation Act of 1973 in the Urban Mass Transit
Transportation                 Program. Washington, DC.: Dec. 1985. (Rev. May 13, 1986.)
Services for the               This report presents national and local cost estimates of compliance
Disabled Calculated            with the rules implementing section 504, in two ways. DOTestimates

                           l the cost to adjust existing services for disabled persons in seven selected
                             cities to comply with the rule, and
                           . the annual costs of meeting the rule for transit systems in average-sized
                             cities, using a computer model. The model is based on data from
                             53 Urban Mass Transit Administration funding recipients that provide
                             special services to persons with disabilities.

Description of Cost Data       Costs cited for seven selected cities include all capital costs incurred
                               since DOT’S1979 rule implementing section 504. The computer model
                               estimates costs for averaged-sized cities for transit authority-operated
                               transportation and taxi subsidies. Included in the taxi subsidy are costs
                               for supplementary lift-equipped vehicle service for persons unable to
                               use taxis (p. vii).

Cost Data                      Current cost figures shown in table V. 1 are the total costs supporting
                               existing service for elderly persons and persons with disabilities in the
                               seven cities. Whether or not the service fully meets the criteria and eligi-
                               bility of rules implementing section 504 is not a factor. The adjusted
                               costs shown in the table are nor’s estimate of what it would cost each
                               system to comply with all service criteria and the eligibility

                               The lift-bus costs shown in table V.2 assume 50-percent accessibility
                               over a 6-year phase-in period and a 20-percent spare ratio. The DOTrule

                               Page 22                              GAO/HRB9044BR   Costs of Acaxnmodations   for Disabled
           Appendix IV
           Costs of Employment      Accommodations      for
           Persons With Disabilities:   Brief Description
           of one Beport

           The survey included only employed persons with disabilities. Persons
Comments   with disabilities not in the labor force may require more or less costly
           accommodations. Employers may tend not to hire persons with disabili-
           ties who require more costly accommodations.

            Page 20
                               Appendix III
                               Costs of Making Buildings    Accessible to
                               Persons With Disabilities:   Brief Descriptions
                               of Seven Reports

                               cost estimates for “... the most practical method resulting in the least
                               cost ... The advice of the architects and printed information by the
                               North Carolina Department of Insurance, Special Office for the Handi-
                               capped, were used as sources for determining costs of needed structural
                               changes” (p. 8).

                               William Cochran Associates, PC., The Cost of Accessibility : A Report
Making Workplaces              on the Costs of Making Places of Employment Accessible for Handi-
Accessible to the              capped People. Prepared for Mainstream, Inc. Washington, DC.: Mar.
Handicapped:                   1976.
Cost Estimates                 After surveying         the cost of making a wide assortment of 34 different
                               commercial and         industrial workplaces accessible, the authors conclude
                               that workplaces         can be made accessible without spending large sums of
                               money. Surveys         were done in the 6 months prior to March 1976 (pp. 2
                               and 6).

Description of Cost Data       The average cost of making all 34 facilities accessible was less than $.Ol
                               per square foot. To make the 29 smaller facilities (less than 1 million
                               square feet) accessible, the average cost was less than $.05 per square
                               foot (p. 6).

Cost Data                      The total cost of accessibility for 28,190,OOOsquare feet of facilities sur-
                               veyed is $264,865 (p. 5). Some specific examples of accessibility costs

                           . l,OOO-square-foot office - $1,655
                           l 100,000 square feet of 10 retail stores - $5,000
                           . 131,000 square feet of offices - $23,970
                           l 257,000-square-foot warehouse - $7,745
                           l 600,000-square-foot hospital - $11,125
                           l 11,261 ,OOO-square-foot petrochemical complex - $10,750 (p. 5)

Comments                       The contractor generated the cost estimates by making on-site inspec-
                               tions of potential barriers, The report does not explain how the contrac-
                               tor derived the estimates to remove barriers.

                                Page 18                                 GAO/HRD-9044BR   Costs of Accommodations   for Disabled
                Appendix lII
                Costs of Making Buildings Accessible to
                Persone With Disabilities: Brief Descriptions
                of Seven Report8

                increases costs over original construction costs up to 21 percent (pp. 141
                and 142).

                Costs were estimated to conform to a 1978 proposed standard (Al 17.1)
                of the American National Standards Institute (p. 141 and forward).

Cost Data       The report estimates renovation versus redesign costs, as follows:

            l High-rise multifamily tower - $60,894 vs. $14,639”
            l Garden apartments - $42,385 vs. $5,269”
            l Single-family house - $3,085 vs. $436
            l College dormitory - $17,641 vs. $4,562:’
            l Convention hall - $108,810 vs. $14,116
            . Public library - $8,338 vs. $777 (no elevator)
            l Town hall - $2,304 vs. $774”
            . College classroom - $10,690 vs. $2,70gd
            l Shopping center - $4,068 vs. $127 (p. 142 and 150)

Comments        The study’s estimates for original design and renovation are in 1975 dol-
                lars. The methodology involved the following steps (pp. 3 and 4):

                 1. Select and review building plans and specifications;

                 2. Obtain data on construction cost and adjust to 1975 costs based on a
                 20-city average;

                 3. Identify architectural barriers in existing plans;

                 4. Develop design solutions to identified barriers;

                 5. Use the in-place unit cost method” to estimate the cost of renovation
                 versus changed original design, and then select the least expensive
                 design alternative for both design and renovation; and

                 “Foiadapting 10 percentof structures’ units.
                 “With certain waivers For rxample, requirementsfor specificnumbersof plumbing fixtures basedon
                 occupanciesmight be waived sothat two nonaccessibletoilet seatscan becombinedto makeone
                 ‘In the in-placeunit methodof costestimating,unit costsare the total costof all materialsand labor,
                 including allowancesfor location,time, overhead,and profit.

                 Page 16                                GA0/HRD9044BR       Costs of Accommodations    for Disabled
                         Appendix J.U
                         Costs of Making Buildings    Accessible to
                         Persona With Disabilities:   Brief Descriptions
                         of Seven Report6

                         The authors used standard costs based on average labor and material
                         costs as of January 1, 1979, unless an institution had a firm cost esti-
                         mate for a required modification (p. 42).

                         Cost estimates are based on the survey’s finding that about 40 percent
                         of college and university space was then accessible to the disabled, but
                         75 percent was needed for compliance (p. xi).

Cost Data                Costs of achieving accessibility are estimated at $0.47 per usable square
                         foot for private institutions in the United States, and $0.34 for public
                         institutions in the United States. Usable area excludes custodial, circula-
                         tion, mechanical, and structural areas (p. 5). These costs average
                         $151,100 for private institutions and $216,200 for public ones (p. 5).

                         Costs of renovation increase with building age and campus size (p. xi).
                         The total cost estimates are $245 million for 1,620 private institutions _
                         and $316 million for 1,463 public institutions (p. 5).

Comments                 The study derived nonrecurring costs by (p. 41) constructing a stratified
                         random sample of 700 schools and conducting a mail survey through a
                         network of state agencies. In a second stage, specially trained state per-
                         sonnel made on-site audits of 138 of the 607 (p. 61) responding institu-
                         tions The audit data supplemented the data obtained in the mail survey.
                         The mail survey instrument used first was based on another instrument
                         that had been administered repeatedly since 1968. That fact, plus the
                         use of a sound sample design (p. 43), lends credence to the report’s cost

                             Further Action Needed To Make All Public Buildings Accessible To
Costs of Remedying       GAO,
                         The Physically Handicapped (GAO/FED-75-166, July 15, 1975).
Architectural Barriers
in Federally Financed    The report reviewed implementation of the Architectural Barriers Act of
                         1968 to ensure that federally financed public buildings were designed
Buildings Reviewed       and constructed to be accessible to persons with disabilities (letter and
                         pp. 2-5).

                         Page 14                                  GAO/HRD9@44BR   Costs of Accommodations   for Disabled
                               Appendix III
                               Costa of Malting Building8   Accessible to
                               Persons With Disabilities:   Brief Descriptions
                               of seven Reports

Cost Data                      Using reasonable alternatives to renovation, the specific cost estimates

                           l For making 45 percent of higher education buildings first-floor-
                             accessible, $117.4 million (p. 31), and for one-third of existing elemen-
                             tary and secondary school buildings, $182 million (p. 34);
                           . For making 100 percent of higher education buildings first-floor-
                             accessible, $261 million, and for one-half of existing elementary and
                             secondary school facilities, $238 million (p. 34).

Comments                       The report does not discuss why the cost factors .0056 and .0089 were
                               chosen, other than to say that they ‘I... were built up from information
                               we obtained from four colleges that had done surveys to determine the
                               cost of making their buildings accessible” (p. 24). The report’s cost esti-
                               mates depend critically upon the choice of the cost factor. The reason-
                               ableness of these cost estimates is not clear without knowing if the four
                               colleges are representative of all higher education facilities.

                               Lawrence Johnson & Associates, Inc., Preliminary Exploratory Eco-
Costs for HEW-Funded           nomic Analysis of the Impact of Section 504 Program Accessibility
Schools,Health and             Requirements, an Interim Evaluation of Section 504 Implementation.
Social Services,               Prepared for HEW. Washington, D.C.: Aug. 15, 1979.
Libraries Projected            The report estimates costs to institutions receiving HEW funds for com-
                               plying with regulations for implementing section 504. It uses data from
                               a postcard survey of 7,662 recipient schools, health, and social service
                               institutions other than colleges and universities, and a questionnaire
                               survey of 700 colleges and universities. Usable responses to the post-
                               card survey came from 2,619 institutions and to the questionnaire sur-
                               vey from 570 colleges and universities (pp. 113 and 116). The survey
                               results form the basis for national cost estimates (pp. 111, 113, and
                                117). The study team obtained additional cost data mostly by telephone
                               (p. 120) from a subsample of 360 of these respondents (pp. 111 and
                                137). HEWsupplied lists of recipient institutions other than colleges and
                               universities (p. 112) and the National Center for Education Statistics
                               supplied the data on colleges and universities (p. 117).

Description of Cost Data        Structural modification costs use 1978 prices for modifications. The
                                report gives estimates in 1979 dollars of annual continuing costs (p. 3).

                                Page 12                                  GAO/BRD4&44BR   Costs of Accommodations   for Disabled
Appendix II

Scopeof Reports on Costs of Accommodating
PersonsWith Disabilities

Type of accommodation    Facility or service atfected                                        Report source’                                   Year
Burldrng accessrbrlrty   Higher education, elementary, and secondary schools                 O’Neill                                          1977
                         HEW-funded educational, medrcal, and socral service                 Johnson and associates                           1979
                         institutions (includes costs of aids, relocation of servrces,
                         and marntenance)
                         Colleges and unrversities                                           Wulfsbergand _____
                                                                                                             Petersen                         1979
                         Federal office building, medical college, two apartments,           GAO                                              1975
                         engmeenng facility, and officers’ club
                         High-rise and garden apartments, single house, college           Schroederand       Seinfreld                        1979
                         dormrtory, public Irbrary, town hall, shoppmg center, and
                         classroom                                               _____-
                         Institutions in Pennsylvanra offering vocational educatron          Assocrated Educational                           1978
                         .~_             __-~-____~                      ~-                  Consultants
                         Workplaces (34)                                                     Cochrane Associates                              1976
Employment                Federal contractors (367)                                           Berkeley Plannrng Associates                    1982
Transportatron systems    Urban rail, bus, auto, and taxi                                     Con ressional Budget Office                     1979
                                                                                       .____ (CBh
                         Mass, paratransrtb and tax!                                          Department of Transportation                    1985
                          __-__.-                                                        __~- (DOT)
                          Urban rail transrt in 10 areas                                      DOT
                                                                         -__-                                                          __-. 1981
Telecommunrcatrons        Interstate telecommunication relay system, Including servic=F-                                                    1989
                         characteristics, user charges, amplified handsets, and
                         wheelchair access to public telephones
                                          ‘Vefer to apps IIIthrough VI at the end of this report for complete sources.
                                          bParatranSltgenerally refers to special transportatron services provided for people unable to use public
                                          systems Examples would be door-to-door, dral-a-nde bus, and van servrce for elderly persons and per.
                                          sons wth disabrlrtres

                                          Page 10                                  GAO/HRD-9044BR       Costs of Accommodations       for Dimbled
Appendix I

Private Industry and Interest Groups and
Government Agencies Contacted for Study

Private Industry       American Hotel/Motel Association
                       American Institute of Architects
                       American Retail Federation
                       American Society for Personnel Administration
                       American Telephone and Telegraph Company
                       Barrier Free Environments
                       Bell South Corporation
                       Building Owners and Managers Association International
                       Chamber of Commerce
                       Champion International
                       J.C. Penney
                       McGuiness & Williams
                       MCI Communications Corporation
                       National Association of Broadcasters
                       National Association of Manufacturers
                       National Association of Theater Owners
                       National Federation of Independent Business
                       National Restaurant Association
                       Parks/Recreation Association
                       Washington Business Group on Health

                       American Foundation for the Blind
Disability Interest    Association for Retarded Citizens, National Disability Council
Groups                 Disability Rights Education and Defense Fund
                       Eastern Paralyzed Veterans
                       National Alliance of the Mentally Ill
                       National Center for Law and the Deaf
                       National Disability Action Center
                       National Foundation for the Study of Employment Policy
                       Paralyzed Veterans of America
                       The Easter Seal Society for Disabled Children and Adults, Inc.
                       Trace Center, University of Wisconsin
                       IJnited Cerebral Palsy

                       Architectural and Transportation Barriers Compliance Board
 Government Agencies   Congressional Research Service
                       Council of Economic Advisors
                       Department of Commerce
                       Department of Education
                       Department of Housing and Urban Development (HUD)

                        Page 8                     GAO/HRD-!?04BR   Costs of Accommodations   for Disabled

Letter                                                                                               1

Appendix I                                                                                           8
Private Industry and     Private Industry                                                            8
                         Disability Interest Groups                                                  8
Interest Groups and      Government Agencies                                                         8
Government Agencies
Contacted for Study
Appendix II                                                                                         10
Scopeof Reports
on Costs of
Persons With
Appendix III                                                                                        11
Costs of Making          Transportation Options Evaluated for Persons With
Buildings Accessible     Costs for HEW-Funded Schools, Health and Social                             12
to Persons With               Services, Libraries Projected
 Disabilities: Brief     Colleges and Universities Surveyed as to Impact of New                      13
Descriptions             Costs of Remedying Architectural Barriers in Federally                      14
 of Seven Reports             Financed Buildings Reviewed
                         Costs of Accessibility for Nine Buildings Estimated                         15
                         Costs of Modifying Vocational Schools for Handicapped                       17
                         Making Workplaces Accessible to the Handicapped: Cost                       18

Appendix IV                                                                                          19
Costs    of Employment   Description of Cost Data                                                    19
                         Cost Data                                                                   19
Accommodations           Comments                                                                    20
for Persons With
Brief Description
of One Report

                         Page 6                       GAO/HRD-9044BRCosts of Accommodations for Disabled

Only one report addresses the cost of making accommodations to facili-
tate employment of persons with disabilities. It is limited to accommoda-
tions made by 367 federal contractors to comply with section 503 of the
Rehabilitation Act of 1973. Employment accommodations possible or
required today may differ due to changes in technology. The report esti-
mated that 51 percent of the accommodations made cost nothing, 30 per-
cent cost less than $500, and only 8 percent cost more than $2,000. (See
app. IV for a brief description of this report.)

We identified three reports on transportation system accessibility. One
covers 10 geographic areas and includes transit operators’ cost esti-
mates, which were disputed by groups representing persons with disa-
bilities and a group of extramural reviewers.” Another does not fully
explain its methodology and appears to inappropriately combine non-
recurring capital costs with recurring operating costs in its computation
of gross costs over 30 years. The third report on transportation accessi-
bility makes so many adjustments and assumptions that assessing the
reported estimates would take extensive sensitivity analysis. (See app. V
for brief descriptions of these three reports.)

The single report on telecommunications (described in app. VI) is a
notice of proposed rulemaking by the Federal Communications Commis-
sion (FCC) pursuant to the Telecommunications Accessibility Enhance-
ment Act of 1988. It concerns telephone and other telecommunications
accessibility by persons with hearing and speech impairments. The
notice requests comment on cost estimates to establish a nationwide
interstate telephone relay system based on California’s intrastate relay

We are sending copies of this briefing report to other congressional com-
mittees, federal agencies and commissions, and other interested parties.

“The report concludedthat accuratelyestimatingthe costof malangrail system accessiblewas not
possibleat that time

Page 4

                     As agreed with your respective offices, we concentrated our work on
Objectives, Scope,   identifiing,and reviewing published reports on the costs of removing or
and Methodology      avoiding architectural, transportation, employment, and communication
                     barriers to persons with disabilities and did not develop our own esti-
                     mates of the cost of implementing the proposed law.

                     We reviewed literature published from 1975 to the present to identify
                     pertinent reports. In addition, we contacted organizations representing
                     the general business community and construction, transportation, and
                     communication industries; groups representing persons with disabilities;
                     and cognizant federal agencies and commissions. Our purpose was to
                     determine whether they had studied the proposed ADA and/or knew of
                     earlier studies on the costs of removing or avoiding architectural, trans-
                     portation, employment, and communication barriers to disabled people.
                     (App. I lists our contacts.) In reviewing t,he reports we identified, we
                     evaluated the soundness of the assumptions and procedures they used
                     to estimate costs. We did not contact the authors of the reports for addi-
                     tional information. Our work was performed between July and October
                      1989. This report elaborates on information we discussed with your
                     offices in a briefing on August 28, 1989.

                     We identified 12 reports that estimate costs of accommodating persons
Results              with disabilities by removing or avoiding architectural, employment,
                     transportation. or communication barriers. But these reports are only
                     marginally useful in evaluating the costs of implementing the .~DA. In
                     addition to being outdated, the reports apply only to the cost of avoiding
                     or removing selected barriers to accessibility by persons with disabilities
                     in selected situations. In some cases, the studies use questionable or
                     unexplained methodologies.

                     The accommodations the reports deal with were seen as needed by the
                     reports’ authors at the time the studies were done and under the accessi-
                     bility standards and with technology then available.” Dating mostly
                     from the 1970s or r,arly 198Os, the reports contain cost data from those
                     years or earlier. None of the reports estimate the cost impacts of imple-
                     menting the .4DA or any of its major provisions. Of the 12 reports, 7 focus

                     “Many of the reports ~~st~mate
                                                  the nnpact of lmplemenrmgregulationsunder section 603 and 504 of
                     The RehabilitationAct of 197:)and the useof Amwican SaWmaStandardsInstitute (ANSI) stan-
                     dardsproposedor in effect then. Thesestandxds WWPANSI standardAl 17.1,“Amencan National
                     Standardfor Bmldm@and Farllitirs-Provtding Ac(.cs~~hd~ty  and I’sablhty for Physically Handi-
                     cappedPeople,”and the Ilnifonn FederalAccrss~bd~ty  Standards(I JFAS).which we gwwrally consis-
                     tent with the A&S1st;mdard.ANSI Al 17 1 wits publishedonginnlly in 1961and revisedm 1%) and
                           IJFASwas rmbhshedin I9R4.

                      Page 2                             GAO/HRD9044BR Costs of Accommodationsfor Disabled