Assistive Listening Knowledge Base
  • Regulatory impact analysis (final, for the 2010 ADA rules)

Final Regulatory Impact Analysis of the Final Revised Regulations Implementing Titles II and III of the ADA, Including Revised ADA Standards for Accessible Design

  • HDR HLB Decision Economics Inc. (for the US Department of Justice)
  • US Department of Justice, Disability Rights Section of the Civil Rights Division (archived ADA website)

Government (US Department of Justice; prepared under contract by the economics consultancy HDR HLB Decision Economics Inc.)

Summary

The cost-benefit analysis behind the 2010 ADA rules, with its assumptions for the price, upkeep and replacement of hearing-aid-compatible receivers and the savings from requiring fewer receivers in large venues.

Key findings

  • Reports that advocacy groups and individuals with hearing loss said in comments that FM and infrared receivers typically cost $150 to $250 and neckloops no more than $50 each, and that loops work with hearing aids without extra receivers. After building a database of retail prices, the analysis lowered its incremental cost of making one receiver set-up hearing-aid compatible to $29.50 (low), $72 (medium) and $114.50 (high).
  • Assumes incremental operation and maintenance for these receivers of 4% to 6% of their unit cost a year and replacement every 10 years, over a 40-year building life.
  • Asked operators of assembly areas for their maintenance costs and replacement cycles. It states that the replies, from stadiums, arenas, convention centres and organisations with experience of lifecycle costs, were "too general in nature" to be used, so the earlier maintenance assumptions were kept.
  • Puts the net present value of the requirement for hearing-aid-compatible receivers at minus $25.77 million (costs to facilities of $28.05 million against $2.28 million of benefits to users), at a 7% discount rate in its primary scenario.
  • Puts the net present value of the revised receiver scoping, which requires fewer receivers in assembly areas over 500 seats and none where there is no audio amplification, at plus $273.95 million: $281.23 million saved by facilities against $7.29 million lost to users, in the same scenario.
  • Appendix 3I identifies operation and maintenance percentages as incremental costs and gives requirement 62 (assistive listening, technical) low, middle and high values of 4%, 5% and 6%; Appendix 3L gives a ten-year replacement interval. Chapter 5, Assistive Listening Systems, Maintenance costs, explains why the agency retained these assumptions after receiving comments too general to use.
  • Chapter 5, Updated Unit Costs (All Requirements), says general unit-cost estimates were raised by 3.6% from their 2007 estimates to 2009 dollars using the RSMeans construction cost index. The publication year 2010 is not a uniform price-base year for all figures or commenters' retail estimates.
  • Chapter 6, Table 7, reports the national effects in millions of dollars under safe harbor, 50% readily achievable barrier removal, the 1991 Standards baseline and a 7% discount rate. Requirement 62 has net present value -25.77, user impact +2.28 and facility impact -28.05; requirement 66 has net present value +273.95, user impact -7.29 and facility impact +281.23. Parentheses denote negative values, and the published figures are rounded.

Limits

A regulatory cost model, not measured costs: receiver prices come from a desk review of retail prices, and maintenance and replacement figures are assumptions. It models the receiver requirements only, not the cost of installing loop, FM or infrared systems. Monetary figures are US dollars; 2010 dates the analysis, while Chapter 5 identifies 2009 as the general unit-cost price base. The analysis is spread over several web pages and appendices of the Department's archived ADA site; the date is the one on its title page (23 July 2010).

Read the original

archive.ada.gov/regs2010/RIA_2010regs/ria.htm

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Cite this source

HDR HLB Decision Economics Inc. (for the US Department of Justice). Final Regulatory Impact Analysis of the Final Revised Regulations Implementing Titles II and III of the ADA, Including Revised ADA Standards for Accessible Design. US Department of Justice, Disability Rights Section of the Civil Rights Division (archived ADA website). 23 July 2010. https://archive.ada.gov/regs2010/RIA_2010regs/ria.htm (accessed 13 October 2026).

The accessed date is when this library last checked the link; use the date you read it. To point readers to this summary instead, link to https://assistivelisteningknowledgebase.org/evidence/doj-2010-ada-regulatory-impact-analysis/

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