36 CFR Part 1191 ADA and ABA Accessibility Guidelines for Emergency Transportable Housing Units

Summary of Costs and Benefits

The Federal Emergency Management Agency (FEMA) is the only entity we have identified that has recently provided emergency transportable housing units to disaster survivors. FEMA is subject to the ABA. We estimated the additional costs for FEMA to provide emergency transportable housing units that comply with the final rule compared to units complying with the Uniform Federal Accessibility Standards (UFAS). UFAS is the accessibility standard adopted by HUD for residential facilities covered by the ABA. We estimated the additional costs under three scenarios. The scenarios do not represent actual costs that FEMA will incur each year since the number of UFAS compliant units deployed by FEMA varies from year to year. The first scenario is based on the average number of UFAS compliant units deployed per year by FEMA in response to major disasters and emergencies declared by the President during the period from calendar year 2008 to 2013, which were 165 UFAS compliant units. Under the first scenario, we estimated the additional costs to range from $28,425 to $104,775. The second scenario is based on FEMA’s current baseline target inventory of 298 UFAS compliant units. Under the second scenario, we estimated the additional costs to range from $51,480 to $189,230. The third scenario is based on the approximately 145,000 emergency transportable housing units that FEMA deployed in response Hurricanes Katrina and Rita. Under the third scenario, we estimated the additional costs to range from $2.5 million to $18.4 million depending on whether 10, 15, or 20 percent of the units are UFAS compliant. The additional costs estimated under the second and third scenarios may be incurred over more than one year.

The final rule would benefit disaster survivors with disabilities who need temporary housing. The benefits are difficult to quantify, but include important national values recognized in Executive Order 13563 such as equity, human dignity, and fairness.