Chapter 4: Cost of the Guidelines

4.1 Overview

This chapter

  • Discusses the factors considered in establishing a baseline for the design of play areas against which the incremental costs of the guidelines are estimated;
  • Describes three model play areas chosen to represent the different sizes and costs of play areas;
  • Estimates the incremental equipment and ground surface costs for designing the model play areas to comply with the guidelines, compared to the baseline;
  • Estimates the incremental maintenance costs (savings) for two surfacing options for the model play areas;
  • Calculates the full incremental costs of the guidelines for the model play areas; and
  • Aggregates the social and direct costs of the guidelines to arrive at a total annual cost.

4.2 Baseline

To estimate the incremental costs of the guidelines, it is necessary to establish a baseline against which the cost of play areas designed in accordance with the guidelines can be compared. The baseline is a reasonable forecast of how play areas would be designed in the absence of the guidelines. The following factors were considered in establishing the baseline: evolution of industry standards; civil rights laws and regulations guaranteeing the rights of individuals with disabilities; and degree of compliance by covered entities with those civil rights laws and regulations.

Evolution of Industry Standards

Beginning in 1990, the American Society of Testing and Materials (ASTM) established several subcommittees to develop voluntary standards for play areas. The ASTM F 15.29 Public Playground Equipment Subcommittee issued the ASTM F 1487 Standard Consumer Safety Performance Specification for Playground Equipment for Public Use initially in 1993 and revised the standard in 1995 and 1998. Although the ASTM F 1487 standard is primarily concerned with safety, the ASTM subcommittee which developed the standard included technical provisions in the standard for accessible routes, ramps, transfer systems, and ground level play components based on the understanding that the Americans with Disabilities Act applied to play areas. The technical provisions of the play area accessibility guidelines are consistent with the ASTM F 1487 standard. The ASTM F 1487 standard does not include scoping provisions specifying how many ground level and elevated play components are to be accessible.

The ASTM F08.63 Playground Surfacing Systems Subcommittee issued the ASTM PS 83 Provisional Standard Specification for Determination of Accessibility of Surface Systems Under and Around Playground Equipment in 1997. A final standard, ASTM F 1951 Standard Specification for Determination of Accessibility of Surface System Under and Around Playground Equipment, was issued in 1999. The ASTM F 1951 standard provides an objective way to measure the accessibility of ground surface materials commonly used in play areas. The play area accessibility guidelines reference the ASTM F 1951 standard. Some engineered wood fiber surfaces if installed and maintained properly, and rubber surfaces meet the ASTM F 1951 standard. There may be other surfaces that meet the ASTM F 1951 standard.

The ASTM F 15.36 Soft Contained Play Equipment Subcommittee issued the ASTM F 1918 Standard Safety Performance Specification for Soft Contained Play Equipment in 1998. The ASTM F 1918 standard includes technical provisions for transfer platforms to entry points of soft contained play equipment, which are consistent with the play areas accessibility guidelines.

Although these ASTM standards are voluntary, many operators of play areas specify that the equipment meet the ASTM standards when purchasing the equipment for safety reasons and manufacturers tend to follow the ASTM standards. It is common today for play equipment manufacturers to incorporate as a standard feature a transfer system to at least one deck or level on composite play structures and to provide an activity panel or slide on that deck. Operators of play areas can provide more or less accessible features based on individual considerations.

Legal liability and insurance costs could cause operators of play areas to upgrade their play areas to comply with the ASTM standards sooner than they would have following an ordinary replacement schedule. The ATSM standards have not been in place long enough to ascertain the extent to which this has occurred.

Civil Rights Laws and Regulations

The Americans with Disabilities Act is the culmination of a series of civil rights laws guaranteeing the civil rights of individuals with disabilities. Section 504 of the Rehabilitation Act, which was initially enacted in 1973, prohibits discrimination on the basis of disability in programs, activities, and services receiving federal financial assistance. Regulations issued under section 504 generally require recipients of federal funds to provide for accessibility in new construction and alterations of facilities. Schools, parks, and other public entities are commonly recipients of federal funds and had to provide for accessibility in newly constructed and altered play areas since the 1970's. In addition, the Individuals with Disabilities Education Act, which was initially enacted in 1974, requires public schools to provide for accessibility in new construction and alterations of facilities. The Americans with Disabilities Act reinforces these requirements for public entities covered by title II of the Act and extends the requirements to private entities covered by title III of the Act. These civil rights laws and regulations are closely intertwined and it is not possible to separate their impacts.

The Department of Education and the Department of the Interior are responsible for administratively enforcing section 504 of the Rehabilitation Act and title II of the Americans with Disabilities Act in the case of schools and parks, respectively. The Department of Education also administratively enforces the Individuals with Disabilities Education Act. In a series of administrative complaints filed with these agencies, the Department of Education and Department of the Interior have required schools and parks to provide an accessible route through play areas to a range of play activities, including accessible ground surfaces and use of ramps and transfer systems. (16) The Department of Justice, which is responsible for enforcing titles II and III of the Americans with Disabilities Act, also has issued interpretative guidance that covered entities are required to provide an accessible route to the playground, some accessible equipment, and an accessible surface for the playground. (17)

Degree of Compliance

As noted above, schools, parks, and other public entities which commonly receive federal funds have been required since the 1970's to provide for accessibility in newly constructed and altered facilities. These public entities are required to have Section 504 coordinators who are responsible for ensuring among other thingsthat the accessibility requirements are met. These entities generally have complied with this requirement. With respect to play areas, compliance has been facilitated with the development of the ASTM standards, including the ASTM F 1951 standard, which provides an objective way to measure the accessibility of ground surface materials commonly used in play areas. It is common today for play equipment manufacturers and surface material suppliers to advertise and promote the accessibility of their products through their catalogues and web sites. With the increased availability of accessible play equipment and surface materials in the marketplace and long history of coverage by civil rights and regulations, a high degree of compliance is expected by public entities.

Private entities covered by title III of the Americans with Disabilities Act do not have as long a history of coverage by civil rights laws and regulations as do public entities. Large private entities that operate play areas are more likely to know about developments in the marketplace and the availability of accessible play equipment and surface materials. Smaller private entities that operate play areas may not be as knowledgeable about these matters as large private entities which may affect the level of compliance.

Comparison of Baseline and Guidelines

The primary difference between the baseline and the guidelines concerns the number of ground level and elevated play components that need to be located on an accessible route, which also effects how much ground surface material complying with the ASTM F 1951 standard must be provided and the extent to which transfer systems and ramps must be provided. As noted above, the ASTM F 1487 standard does not contain scoping provisions. The Department of Education, the Department of the Interior, and the Department of Justice have interpreted the civil rights laws and regulations as requiring a range or some number of ground level and elevated play components to be accessible.

Generally, the baseline assumes that a smaller number of ground level play components are located on an accessible route than required by the guidelines and that a transfer system is provided only to one deck of a composite play structure, making fewer elevated play components accessible than required by the guidelines. The specific differences between the baseline assumptions and the guidelines are discussed in more detail below.

4.3 Model Play Areas (18)

Three model play areas have been selected to represent the different sizes and costs of play areas. The first is a small play area, as may be found in a child care center. The second is a medium play area, as may be found at an elementary school. The third is a large play area, as may be found in a public park. The models are not intended to be representative of all play areas in child care centers, schools, and parks, and these establishments are not limited to the size models. The models were developed for purposes of determining the impact of the guidelines and estimating costs, and are not intended to provide design guidance.

Different ground surface materials were used for each model. For the small play area, the baseline design used a loose fill surface such as sand or wood chips for the entire play area; and the guidelines design used two options: an engineered wood fiber surface for the entire play area (option 1), and a combination of loose fill and a rubber surface along accessible routes, clear floor or ground spaces, and maneuvering spaces (option2). (19) A loose fill surface was used for the baseline design for the small play area based on comments from child care facilities, which have a large number of small play areas, stating that they would not use an engineered wood fiber surface, or a combination of loose fill and a rubber surface in the absence of the guidelines. For the medium and large play areas, both the baseline designs and the guidelines designs used two options: an engineered wood fiber surface for the entire play area (option 1) and a combination of loose fill and a rubber surface along accessible routes, clear floor or ground spaces, and maneuvering spaces (option 2) because public schools and parks represent a large number of medium and large play areas and it is assumed that these facilities would use surfaces complying with the ASTM F 1951standard in the absence of the guidelines based on the factors discussed above. Some operators, especially in urban areas, have chosen to use a rubber surface for the entire play area in the absence of the guidelines. This assessment overestimates the incremental surface costs for those play areas.

Soft contained play structures are not included in Chapter 5 because the guidelines only require an accessible route to the entry point, a requirement which is satisfied by currently available soft contained play structures without additional cost.

4.3.1 Unit Costs

Tables 4-1, 4-2, and 4-3 list the unit cost ranges used in calculating the costs of the model play areas. The costs are for year 2000 and reflect regional variations in material and labor costs.

Table 4-1. Unit Cost of Surfacing Materials

Surfacing
loose fill materials $0.30 - $1.30 per square foot, installed
engineered wood fiber $0.90 - $3.20 per square foot, installed
rubber mats/tiles $6.35 - $16.00 per square foot, installed, including underlayment
poured-in-place rubber $8.50 - $21.00 per square foot, installed, including underlayment
transitions between loose fill and rubber materials $5.30 - $11.00 per linear foot, installed
border materials $5.30 - $16.00 per linear foot, installed

Table 4-2. Unit Cost of Equipment Features

Accessible Equipment Features
12 inch rise of 1:12 ramp $1,484 - $2,756
ramp landing $2,120 - $5,512, including barriers
ramp and landing combined, per 12 inch rise $3,604 - $8,218
transfer platform $424 - $742
transfer platform with approach step $742 - $1,590
transfer steps $106 - $530 per foot of rise
earth berm to 24 inches $3,710 - $5,830

Table 4-3. Unit Cost of Other Items

Other Cost Elements
stairs $106 - $265 per foot of rise
ladders and climbers $32 - $159 per foot of rise
equipment installation 20% - 40% of equipment cost

4.3.2 Small Play Area

The play area on the following page is a small play area that may be found at a child care center. As is typical in child care centers, the play area is divided by age groups served by the facility. The portion on the left is for infants and toddlers under 2 years old. The portion on the right is for children 2 to 5 years old. The infant and toddler play area is not subject to the guidelines. The play area for children ages 2 to 5 contains 4 elevated play components listed in Table 4-4 and 4 ground level play components listed in Table 4-5.

During the comment period on the proposed rule, child care centers noted that many States establish minimum requirements for play space and that based on those requirements the play area model for the economic assessment should be larger. The Access Board has reviewed State child care licensing requirements and has found that they address play space and do not necessarily require playground equipment. The Access Board also contacted over 125 child care centers around the country and found that most of them have 4 to 7 play components in their play areas. Based on this information, no change has been made in the size of the play area model. However, a change has been made in the surfacing material for the baseline design based on the public comments. For the baseline design, all small play areas are assumed to use loose fill for the entire surface.

Table 4-4. Small Play Area: Elevated Play Components

Item Description Located on Accessible Route
1 Slide yes (transfer system)
2 Climber no (20)
3 Fine Motor Skill Activity yes (transfer system)
4 Fine Motor Skill Activity yes (transfer system)
Total 4 3 yes (transfer system)/ 1 no

Table 4-5. Small Play Area: Ground Level Play Components (21)

ItemDescriptionDifferent TypeLocated on Accessible Route
5 Imaginative Play Item yes yes
6 Imaginative Play Item   no
7 Imaginative Play Item   no
8 Sand & Water Play Table yes yes
Total 4 2 2 yes/ 2 no

4.3.2.1 Impact of the Guidelines on Small Play Area

For the baseline design, the small play area for children ages 2 to 5 has a loose fill surface. The composite structure has 4 elevated play components on a single deck and a transfer platform and transfer steps. There also are 4 ground level play components.

The guidelines require that at least 50 percent of the elevated play components, including entry and exit points, be located on an accessible route. This requirement can be satisfied by using an engineered wood fiber surface (option 1) or combination of loose fill and a rubber surface (option2) to provide an accessible route to and transfer space at the transfer platform. The combination ground level accessible route and transfer system allows children with disabilities to reach and use the slide and 2 fine motor skill activities on the composite structure. Although the top of the climber can be reached by the transfer system, the base of the climber is not located on an accessible route when a combination of loose fill and a rubber surface (option 2) is used. The surface in the play area for infants and toddlers under age 2 would not be affected by the guidelines and can use loose fill.

The guidelines require that at least one of each type of ground level play component provided be located on an accessible route and have clear floor or ground space and maneuvering space. This requirement can be satisfied by using an engineered wood fiber surface (option 1) or loose fill and a rubber surface that extends to one of the imaginative play items. The sand and water play table does not require a use zone and can be located along a paved walk. (22) The requirement that at least one ground level play component be provided on an accessible route based on the number of elevated play components provided would also be satisfied. See Table 15.6.2.2 of the guidelines.

The accessible route is 44 inches wide as permitted by the guidelines in play areas less than 1,000 square feet. Additionally, the accessible route is not longer than 30 feet and therefore does not require 60 inch turning space. Where the accessible route and surfaces are within use zones, the surface material must be impact attenuating. Surfacing options 1 and 2 satisfy this requirement.

4.3.2.2 Incremental Equipment and Surface Costs for Small Play Area

The incremental equipment and surface costs of the guidelines for the small play area are summarized in Table 4-6. Depending on the surfacing option chosen, the cost of the small play area increases by $300 to $2,215, and ranges from 2.5 percent to 14.4 percent over the baseline. The entire increase is due to the change in ground surfacing materials from loose fill (baseline) to an engineered wood fiber surface (option 1) or a combination of loose fill and a rubber surface (option2).

This estimate of increase in cost applies best to small play areas where there are few elevated components. In the model, it is relatively easy to provide access to 3 of 4 elevated play components with only one transfer system. Since so few ground based play components are required to be accessible and since child care centers often rely on nonpermanent play items and large toys, it is relatively easy to comply with the guidelines. Additionally, when items have no designated play surfaces that are elevated, such as the sand and water table, it does not need to be located over impact attenuating material and can be located along a paved walk.

Table 4-6. Summary of Costs for Small Play Area

ItemBaseline CostGuidelines CostChange
Equipment $ 9,304 $ 9,304 $0
Installation(23) $1,861 - $3,721 $1,861 - $3,721 $0
Loose Fill (24) $664 - $2,320 N/A N/A
Surfacing Option 1 - Engineered Wood Fiber (25) N/A $964 - $3,270 $300 - $950
Surfacing Option 2 - Loose Fill & Rubber (26) N/A $1,610 - $4,535 $946 - $2,215
Total Play Area With Loose Fill $11,828 - $15,345 N/A N/A
Total Play Area With Surfacing Option 1 N/A $12,128 - $16,295 $300 - $950
(2.5% - 6.2%)
Total Play Area With Surfacing Option 2 N/A $12,775 - $17,560 $947 - $2,215
(8.0% - 14.4%)

4.3.3 Medium Play Area

The play area on the following page is a medium play area that may be found at an elementary school. The play area contains 10 elevated play components listed in Table 4-7 and 4 ground level play components listed in Table 4-8.

Table 4-7. Medium Play Area: Elevated Play Components

ItemDescriptionLocated on Accessible Route
36 Inch Level
1 Slide yes (transfer system)
2 Bell Ringing Activity yes (transfer system)
3 Fine Motor Skill Activity yes (transfer system)
48 Inch Level
4 Fine Motor Skill Activity yes (transfer system)
5 Climber yes (transfer system)
60 Inch Level(27)
6 Fine Motor Skill Activity no
7 Crawl Tube no
8 Sliding Pole no
72 Inch Level
9 Climber no
10 Slide no
Total 10 5 yes (transfer system)/ 5 no

Table 4-8. Medium Play Area: Ground Level Play Components

Item Description Different Type Located on Accessible Route
11 Fine Motor Skill Activity yes yes
12 Spring Rocker yes yes
13 Spring Rocker   yes
14 Swings yes yes
Total 4 3 yes 4 yes

4.3.3.1 Impact of the Guidelines on Medium Play Area

For the baseline design, the medium play area has a composite structure with 10 elevated play components on 3 decks at 36 inch, 60 inch, and 72 inch heights. A transfer platform and transfer steps connect to the 36 inch high deck, where a slide, bell ringing activity, and fine motor skill activity are located. There are 2 spring rockers and a set of swings on the ground level. Where a combination of loose fill and a rubber surface (option 2) is used, the rubber surface only extends from the entrance of the play area to the composite structure and does not connect to any of the ground level play components.

The guidelines require that at least 50 percent of the elevated play components, including entry and exit points, be located on an accessible route. This requirement can be satisfied by adding a 48 inch high deck, relocating a fine motor skill activity and climber from the 60 inch high deck to the 48 inch high deck, and connecting the 36 inch high deck and the 48 inch high deck with a transfer stair. No change to the surface is required where an engineered wood fiber surface (option 1) is used. Additional rubber surface is needed to extend the accessible route to the base of the climber where a combination of loose fill and a rubber surface (option 2) is used. This makes 5 elevated play components located on an accessible route, which includes a transfer system.

The guidelines require that at least one of each type of ground level play component provided be located on an accessible route and have clear floor space and maneuvering space. This requirement is met where an engineered wood fiber surface (option 1) is used. Additional rubber surface is needed to extend the accessible route to the spring rockers and the swings and to provide clear floor space and maneuvering space at those components, where a combination of loose fill and a rubber surface (option 2) is used. To meet the requirement that at least 3 different types of ground level play components be provided on an accessible route based on the number of elevated play components provided, a fine motor skill activity is added at the ground level. See Table 15.6.2.2 of the guidelines. This enlarges the use zone and requires additional surfacing material to extend the accessible route to the fine motor skill activity.

The accessible route is 60 inches wide. Where the accessible routes and surfaces are within use zones, the ground surface material must be impact attenuating. Surfacing options 1 and 2 satisfy this requirement.

4.3.3.2 Incremental Equipment and Surface Costs for Medium Play Area

The incremental equipment and surface costs of the guidelines for the medium play area are summarized in Tables 4-9 and 4-10. Depending on the surfacing option chosen, the equipment and surface cost of the medium play area increases by $1,896 to $7,853, and ranges from 10.1 percent to 30.2 percent over the baseline.

In reviewing the cost information in these tables, it is important to note that the baseline costs are different for surfacing option 1 and option 2. As discussed above, more than half of all medium play areas are expected to be operated by public entities such as schools or parks. These public entities have been subject to other civil rights laws and regulations requiring accessibility since the 1970's. Therefore, the model medium play area assumes that, in the baseline, a significant portion of the play area surface is accessible. The incremental effect of this rule is to increase the number of play components that are located on an accessible route.

To meet their existing obligation for accessibility, operators are assumed to have examined the full costs (capital and maintenance costs) of different surfacing options and have chosen the least costly option for their play area. Some operators will have chosen materials like engineered wood fiber that are cheaper to install but may require more frequent maintenance. Other operators may find it more economical to install a rubber surface along accessible routes, clear floor or ground spaces, and maneuvering spaces and use loose fill for the remaining area. To measure the incremental costs of the guidelines, we assume operators will choose the same surfacing approach. For example, an operator using an engineered wood fiber surface (option 1) in the baseline design, will use an engineered wood fiber surface (option1) in the guidelines design. The additional surfacing costs are the costs to create this new area. Based on which surfacing option is selected, the baseline costs are different.

Table 4-9. Summary of Costs For Medium Play Area

ItemBaseline CostGuidelines CostChange
Equipment $13,533 $14,933 $1,400
Installation(28) $2,707 - $5,413 $2,987 - $5,973 $280 - $560
Surfacing Option 1 -
Engineered Wood Fiber(29) $2,500 - $8,416 $2,716 - $9,126 $216 - $710
Surfacing Option 2 -
Loose Fill & Rubber Surface (30) $2,297 - $7,046 $4,749 - $12,939 $2,452 - $5,893
Total Play Area With Surfacing Option 1 $18,740 - $27,362 $20,636 - $30,032 $1,896 - $2,670
(10.1% - 9.8%)
Total Play Area With Surfacing Option 2 $18,537 - $25,992 $22,669 - $33,845 $4132 - $7,853
(22.3% - 30.2%)

Table 4-10. Sources of Increased Costs for Medium Play Area

Transfer System To Elevated Play Components
Equipment Cost: $1,005 (31) plus $201 - $402 installation(72%)
Surfacing Cost - Option 1: $0 (32) (0%)
Surfacing Cost - Option 2: $552 - $1,326 (33) (23%)
Ground Level Play Components
Equipment Cost: $395 (34) plus $79 - $158 installation (28%)
Surfacing Cost - Option 1: $216 - $710 (35) (100%)
Surfacing Cost - Option 2: $1,900 -$4,567 (36) (77%)
Total
Equipment Cost: $1,400 plus $280 - $560 installation (100%)
Surfacing Cost - Option 1: $216 - $710 (100%)
Surfacing Cost - Option 2: $2,452 - $5,893 (100%)

4.3.4 Large Play Area

The play area on the following page is a large play area that may be found at a park. The play area contains 20 elevated play components listed in Table 4-1 and 8 ground level play components listed in Table 4-11.

Table 4-11. Large Play Area: Elevated Play Components

ItemDescriptionLocated on Accessible Route
36 Inch Level
1 Fine Motor Skill Activity yes (ramp)
2 Slide yes (ramp)
3 Fine Motor Skill Activity yes (ramp)
4 Bubble Window yes (ramp)
5 Crawl Tube yes (ramp and transfer system)
6 Ladder Climber yes (transfer system)
7 Fine Motor Skill Activity yes (transfer system)
8 Swinging Bridge yes (transfer system)
9 Bubble Window yes (transfer system)
10 Fine Motor Skill Activity yes (transfer system)
48 Inch Level
11 Slide no
12 Fine Motor Skill Activity no
13 Bubble Window no
60 Inch Level
14 Slide no
15 Climber no
72 Inch Level
16 Fine Motor Skill Activity no
17 Slide no
18 Climber no
19 Slide no
20 Slide no
Total 20 10 yes (4 ramp, 1 ramp and transfer system, 5 transfer system)
10 no

Table 4-12. Large Play Area: Ground Level Play Components

Item Description Different Type Located on Accessible Route
21 Fine Motor Skill Activity yes yes
22 Fine Motor Skill Activity   yes
23 Gross Motor Skill Activity yes yes
24 Sand Play Area yes yes
25 Swings yes yes
26 Spring Rocker yes yes
27 Spring Rocker   no
28 Slide yes yes
Total 8 6 7 yes/ 1 no

4.3.4.1 Impact of the Guidelines on Large Play Area

For the baseline design, the large play area has a composite structure with 20 elevated components on multiple decks ranging from 36 inches to 72 inches. A transfer platform and transfer steps connect to the deck at one of the 36 inch high decks, where a crawl tube, a ladder climber, a fine motor skill activity, and a swinging bridge are located. The swinging bridge connects the 36 inch high deck to another deck at the same height, where a bubble window and another fine motor skill activity are located. The transfer system and accessible route at the ground level allows children with disabilities to reach and use these 6 elevated play components. There are 6 ground level play components, which include 5 different types: a fine motor skill activity, a sand play area, swings, 2 spring rockers, and a slide. Where a combination of loose fill and a rubber surface (option 2) is used, the rubber material only connects an entrance to the play area next to the sand play area and the composite structure, the sand play area, the transfer system at the 36 inch high deck, and a fine motor skill activity at ground level adjacent to the composite structure.

The guidelines require that at least 50 percent of the elevated play components, including entry and exit points, be located on an accessible route. Since there are 20 elevated play components, no more than 25 percent of the elevated components are permitted to be connected by a transfer system. Ramp access must be provided to the other 25 percent of the elevated play components. This requirement can be satisfied by constructing an earthen berm to a 24 inch elevation near the composite play structure, extending a 36 inch high deck, and connecting the deck to the berm with a ramp. There are 2 fine motor skill activities, a slide, a bubble window, and a crawl tube on the other 36 inch high deck. The crawl tube also connects the 36 inch high deck that is reached by the transfer system. By adding the berm and ramp, a total of 10 elevated play components are located on an accessible route: 25 percent are reached by transfer system and 25 percent are accessed by the berm and ramp. Additional surfacing is needed at the ground level along the accessible route due to the use zones being enlarged by the extension of the deck and addition of the ramp.

The guidelines require that at least one of each type of ground level play component provided be located on an accessible route and have clear floor space and maneuvering space. This requirement is met where an engineered wood fiber surface (option 1) is used. Additional rubber surface is needed to extend the accessible route to the swings, a spring rocker, and the slide and to provide clear floor spaces and maneuvering spaces at those play components, where a combination of loose fill and a rubber surface (option 2) is used. To meet the requirement that at least 7 ground level play components be provided on an accessible route based on the number of elevated play components provided, an additional fine motor skill activity and a gross motor skill activity is added at the ground level. See Table 15.6.2.2 of the guidelines. Additional rubber surface is needed to extend the accessible route to these additional ground level play components where a combination of loose fill and a rubber surface (option 2) is used. The requirement that at least 4 different types of ground level play components be provided on an accessible route is met by the baseline design.

The accessible route is 60 inches wide. Where the accessible routes and surfaces are within use zones, the ground surface material must be impact attenuating. Surfacing options 1 and 2 satisfy this requirement.

4.3.4.2 Incremental Equipment and Surface Costs for Large Play Area

The incremental equipment and surface costs of the guidelines for the large play area are summarized in Tables 4-13 and 4-14. Depending on the surfacing option chosen, the equipment and surface cost of the large play area increases by $9,229 to $16,511, and ranges from 21.6 percent to 28.6 percent over the baseline. The increase is due to both additional equipment and additional surfacing material being required. As discussed in the medium play area, the baseline cost for surfacing options 1 and option 2 differ and assume that operators made a decision as to which surfacing option has the lowest overall cost.

An earthen berm was used as part of an accessible route in this model. The purpose of this topographic feature is to gain some elevation along the accessible route outside of the equipment use zone before reaching the ramp. (37) If the berm were not used, 2 additional ramp runs and 2 additional ramp landings would have been required in its place. Each ramp run and landing would each require a full 6 feet use zone of impact attenuating surfacing.

Even though an earthen berm makes a less direct elevation gain (1:20 maximum) than a ramp (1:12 maximum), it may offer some cost savings in certain play sites, depending on availability and cost of local materials and labor. In this example, the berm added approximately $4,346 to the overall play area cost (including retaining wall, paving, fill, lowest-cost landscaping materials, and installation). Ramps and landings to reach the same elevation (24 inches) would cost anywhere from $3,584 to $8,268 depending on type of equipment used, plus $717 to $3,308 for installation, depending on type of equipment and labor rates used. Approximately 500 square feet of impact attenuating surfacing would be required around this amount of ramping at a cost of $150 to $8,000, depending on type of surfacing chosen.

In this model, the berm is a more economical choice to accomplish elevation gain than the full use of ramps and landings. However, berms do require more land area and may require more maintenance. Berms may be more economical to reach heights of 24 inches or less. Above this height there are considerably larger structural and fill issues to solve. However, if natural topographic changes exist on a site and can be incorporated into the play area with ramps, this approach may be an effective way of reducing the cost of accessibility.

Table 4-13. Summary of Costs for Large Play Area

Item Baseline Cost Guidelines Cost Change
Equipment and Berm $32,454 $40,711 $8,257
Installation(38) $6,491 - $12,982 $7,273 - $14,456 $782 - $1,564
Surfacing Option 1 - Engineered Wood Fiber (39)
  $3,689 - $12,496 $3,879 - $13,117 $190 - $621
Surfacing Option 2 - Loose Fill & Rubber Surface (40)
  $4,566 - $12,252 $6,985 - $18,942 $2,419 - $6,690
Total Play Area With Surfacing Option 1
  $42,634 - $57,932 $51,863 - $68,284 $9,229 - $10,352
(21.6% - 17.9%)
Total Play Area With Surfacing Option 2
  $43,511 - $57, 688 $54,969 - $74,109 $11,458 - $16,421
(26.3% - 27.5%)

Table 4-14. Sources of Increased Costs for Large Play Area

Earth Berm and Ramp to Elevated Play Components
Equipment Cost: $7,098 (41) plus $550 -$1,100 installation (84%)
Surfacing Cost - Option 1: $190 - $621 (42) (100%)
Surfacing Cost - Option 2:
$106 - $320 (43) (5%)
Transfer System to Elevated Play Components
Equipment Cost: $0 (44) (0%)
Surfacing Cost - Option 1: $0 (0%)
Surfacing Cost - Option 2:
$0 (0%)
Ground Level Play Components
Equipment Cost: $1,159 (45) plus $232 - $464 installation (16%)
Surfacing Cost - Option 1: $0 (0%)
Surfacing Cost - Option 2:
$2,313 - $6,370 (46) (95%)
Total
Equipment Cost: $8,257 plus $782 - $1,564 installation (100%)
Surfacing Cost - Option 1: $190 - $621 (100%)
Surfacing Cost - Option 2:
$2,419 - $6,690 (100%)

4.3.5 Summary of Incremental Equipment and Surface Costs

Table 4-15 summarizes the incremental equipment and surface costs for the model play areas used in this assessment. Some operators, especially in urban areas, have chosen to use a rubber surface for the entire play area in the absence of the guidelines. Table 4-15 overestimates the incremental surface costs for those play areas.

Table 4-15. Summary of
Incremental Equipment and Installation Costs for Play Areas

SizeBaseline (low/ high)Final Rule (low/ high)Percent Change
Surfacing Option 1: Engineered Wood Fiber
(Baseline for Small is Loose Fill)
Small $11,828 / $15,345 $12,128/ $16,295 2.5% - 6.2%
Medium $18,740/ $27,362 $20,636/ $30,032 10.1% - 9.8%
Large $42,634/ $57,932 $51,863/ $68,284 21.6% - 17.9%
Surfacing Option 2: Loose Fill & Rubber Surface
Small $11,828/ $15,345 $12,775/ $17,560 8.0% - 14.4%
Medium $18,537/ $25,992 $22,669/ $33,845 22.3% - 30.2%
Large $43,511/ $57,688 $54,969/ $74,109 26.3% - 28.5%

4.4 Maintenance Costs

In addition to the equipment and surface costs, the guidelines will affect the maintenance costs of a play area. The guidelines provide that ground surfaces along accessible routes, clear floor or ground spaces, and maneuvering spaces must be inspected and maintained regularly and frequently to ensure continued compliance with the ASTM F 1951 standard. This section describes the impact of this provision and estimates the incremental maintenance costs.

4.4.1 Unit Costs

Operators generally have three types of maintenance activities: inspecting the surface, raking and leveling the surface as material is displaced from use or climate, and replacing or "topping-off" material as the original material deteriorates. The rate and frequency of each of these maintenance activities varies depending on the type of surface. Table 4-16 summarizes the typical frequency of maintenance activities for various surfaces.

Table 4-16. Typical Maintenance Frequencies

Maintenance Activity Loose Fill Engineered Wood Fiber Rubber
Inspection Daily to Weekly Daily to Weekly Weekly
Rake & Level Daily to Weekly Weekly to as required Not Required
Top Off 1 to 3 years 3 years Not Required

Source: Henderson, Walter. Catching Kids When They Fall: Guidelines to Choosing a Playground Surface, Parks & Recreation, April 1997, pp. 84-92.

To quantify the maintenance costs, we examined product manufacturer literature. (47), (48) A recent article reports on maintenance costs for different regional parks and play area surfaces. (49) Although the goal of the maintenance is to preserve safety standards, the results can be applied to the guidelines. We developed unit costs to estimate the incremental maintenance costs due to the guidelines. For example, the annual inspection cost is the product of the area of play surface, the inspection rate, the inspection frequency, and the hourly labor rate. The annual maintenance cost is the sum of the annual inspection cost, the annual rake and level cost, and the annual "top-off" cost, if applicable. The maintenance cost components, the values used, and the source of the values are listed in Table 4-17.

Table 4-17. Unit Maintenance Costs

Activity/ Item Value Source/Assumption
Inspection Rate 22 min/5000 ft2 Parks & Recreation Article
Inspection Frequency 156 times/year Parks & Recreation Article; mid-point of 3 times/week used
Engineered Wood Fiber Rake & Level
Rate 2.0 hrs/2000 ft2 Manufacturer's recommendation, 1 to 2 hrs. per 2000 ft2; upper bound used
Frequency 52 times per year Manufacturer's recommendation; Parks & Recreation Article
Loose Fill Rake & Level
Rate 0.75 hrs/2000 ft2 Assume half of mid-point of range for engineered wood fiber
Frequency 156 times/year Parks & Recreation Article; mid-point of 3 times/week used
Engineered Wood Fiber Top-Off
Rate 2.5 hrs/5000 ft2 Parks & Recreation Article; value for wood chips; assume comparable rate for engineered wood fiber
Frequency 3 yrs Manufacturer's recommendation; Parks & Recreation Article
Material Cost $0.11 per ft2 Replace 3 in depth at $12 cub. yd
Loose Fill Top-Off
Rate 1.25 hrs/5000 ft2 Assume ½ of engineered wood fiber rate
Frequency 1.5 yrs Parks & Recreation Article; mid-point used
Material Cost $0.037 per ft2 Assume 1/3 of engineered wood fiber
Labor Rate $16 per hour Parks & Recreation Article

4.4.2 Impact of Guidelines on Play Area Use Zones and Accessible Surfaces

Table 4-18 shows how the guidelines affect the size of the use zones and surfaces along accessible routes, clear floor or ground surfaces, and maneuvering spacesfor the model play areas.

Table 4-18. Change in Model Play Areas
(square feet)

Model Play Area Use Zones Accessible Surfaces
Baseline Guidelines Increase Baseline Guidelines Change
Small 500 500 0 0 117 117
Medium 1800 1922 122 108 397 289
Large 2815 2909 94 242 609 467

For the small play area, loose fill is used for the 500 square feet of use zone space in the baseline design. If an engineered wood surface (option 1) is used in the guidelines design, that material would cover the entire 500 square feet of use zone space. Compared to the baseline design, maintenance costs will be lower since engineered wood fiber (option 1) is raked and leveled and topped-off less frequently than loose fill. If a combination of loose fill and a rubber surface (option2) is used in the guidelines design, the rubber surface would cover 117 square feet of accessible surfaces along the accessible routes, clear floor or ground spaces, and maneuvering spaces. Compared to the baseline design, the maintenance costs will be lower for 23 percent of the play area since the rubber surface does not have to be raked and leveled or topped-off.

For the medium and large play areas, either an engineered wood fiber surface (option 1) or a combination of loose fill and a rubber surface (option 2) is used in the baseline design. If engineered wood fiber (option 1) is used in the guidelines design, an additional 122 square feet of that material would be needed for the expanded use zones in the medium play area, and additional 94 square feet of that material would be needed for the expanded use zones in the large play area. Compared to the baseline design, the maintenance costs would increase due to the need to maintain the additional engineered wood fiber surface. If a combination of loose fill and a rubber surface (option 2) is used in the guidelines design, the rubber surface would cover an additional 289 square feet of the medium play area and an additional 467 square feet of the large play area along the accessible routes, clear floor or ground space, and maneuvering space. Compared to the baseline designs, the maintenance costs would be lower for 16 percent of the medium and large play areas since the rubber surface does not need to raked and leveled or topped-off.

4.4.3 Incremental Maintenance Costs (Savings)

To aggregate routine maintenance costs with the one-time capital and installation costs, the maintenance costs are expressed as the present value of the annual maintenance costs for 15 years, discounted at a 7 percent rate of return. Table 4-19 shows the incremental maintenance costs (savings). Although some of the values are listed as savings, these savings are relative to the baseline maintenance costs. In other words, although the guidelines may reduce maintenance costs for small play areas using a loose fill surface, or medium and large play areas using a combination of loose fill and a rubber surface, the total costs of these play areas (i.e., capital plus the maintenance costs) will increase for most play areas.

Table 4-19. Incremental Maintenance Costs (Savings)
(present value, 7% over 15 yrs)

Model Play Area Option 1 Option 2
Small $(490) $(1,200)
Medium $1,170 $(2,980)
Large $900 $(4,810)

Table 4-19 gives fixed values, rather than a range of values shown for the equipment and surface costs. The maintenance costs are based on the change in the use zone and the accessible surface areas in Table 4-17, which are presented as single values. Therefore, the cost estimates are also presented as single values. There is uncertainty surrounding the maintenance cost estimates; the values in Table 4-19 are the best estimates of the change in maintenance costs.

4.5 Aggregate Costs

4.5.1 Full Incremental Costs (Savings)

Table 4-20 combines the incremental equipment and surfacing costs from Table 4-15 and the incremental maintenance costs (savings) from Table 4-19 to yield the full incremental costs (savings) of the guidelines.

Table 4-20. Full Incremental Costs (Savings)

SizeLowHigh
Surfacing Option 1: Engineered Wood Fiber
Small $(190) $460
Medium $3,100 $3,800
Large $10,100 $11,300
Surfacing Option 2: Loose Fill & Rubber
Small $(260) $1,000
Medium $1,200 $4,900
Large $6,600 $11,600

The estimates in Table 4-20 are derived by taking the mid-point of the range of the incremental equipment and surface costs and then adding in the present value of the incremental maintenance costs. Collapsing the range to a single value is not meant to understate the uncertainty in these estimates. The simplification eases the aggregation to estimate nationwide costs of the final rule.

As shown in the above table, the guidelines could yield savings in certain instances. The expense of installing higher priced surfacing that needs less maintenance could be less than the expense of installing a lower priced surfacing that needs more maintenance. This situation is most likely to occur in regions with relatively high labor rates. While there are some situations where the guidelines could produce savings, the majority of play areas will face increased costs because of the guidelines.

4.5.2 Social Cost of Guidelines

The guidelines will increase the cost of new and replacement play areas built in the United States. The cost increase will affect the number of new and replacement play areas built in the future. Operators that would have built a play area at a lower cost may choose not to build one at the higher cost, or may build a smaller play area. Operators of existing play areas may defer replacing their existing play areas rather than make the replaced play area subject to the guidelines. Operators may even remove play areas once they reach the end of their useful life. This loss of play opportunities is the social cost of the guidelines.

To calculate the social cost of the guidelines, we assume that the pre-existing demand for play areas represented society's value of play area opportunities. The provision of play areas occurs in a free market. Operators such as restaurants or motels weigh how much value they will receive if they add a play area versus other amenities and choose accordingly. Similarly, non-profit groups such as parent-teacher organizations and other civic groups trade off the relative costs and benefits of donating play areas or of donating other equipment (e.g., computers) to schools and the community. If individual consumers are free to make these trade-offs, society's annual demand for new and replacement play areas is the total value they give to society. This value is measured by the price and the total quantity purchased by all individual consumers.

Figure 4-1 illustrates this social demand curve for play areas. The annual demand for play areas prior to the guidelines is measured at P1 and Q1. Figure 4-1 also shows the effect of the guidelines. As the price increases from P1 to P2, consumers demand less play areas in the future. Since the demand curve (D) measures society's demand for play areas, the new number of play areas society is willing to pay for is Q2. Society gives up the value measured by the triangle ABC. This triangle represents the social cost of the guidelines.

As shown in Figure 4-1, the slope of the society's demand curve partially determines the size of the social cost, measured by triangle ABC. The slope of the consumer demand curve is measured by the elasticity of demand. Researchers calculate the elasticity of demand for a specific good or service by observing consumer behavior (i.e., how much of a good is bought when the price of the good fluctuates). The elasticity (e) of demand is calculated as the ratio of the percentage change in quantity demanded divided by the percentage change in price.

e = Q1 - Q2
Q1
P1 - P2
P1

Figure 4.1 as described in the two preceding paragraphs

Measuring the elasticity of demand for new or replacement play areas is beyond the scope of this assessment. We did not find measured elasticities of demand for play areas in the economic literature. Therefore, as an alternative approach, we used an elasticity of demand for a good comparable to the provision of play areas: charitable donations. We assume that consumers will react to the change in price of play areas as they would to a change in the price of charitable donations. Empirical studies have measured that if the price of donating to charity increases, the amount donated falls off significantly. The specific elasticity of demand for charitable donations is -1.5.

There are several reasons why consumer behavior for charitable donations is a good surrogate for the provision of play areas. First, schools constitute one of the largest providers of play areas. Most school play areas are not funded by the school districts, but by charitable donations from non-profit associations such as booster clubs and parent-teachers organizations. These organizations are charities that must weigh the benefits and costs of donating play areas as compared to other means of making a donation to the school system. Second, charitable, non-profit organizations such as civic associations provide play areas at their establishments.

Based on the assumed elasticity of demand, it is possible to estimate the social cost of the guidelines by calculating the estimated future quantity of play areas (Q2) based on the known values for the price and quantity of play areas demanded by society before the rulemaking (P1 and Q1), and the new price of providing play areas after the guidelines are adopted as standards by the Department of Justice (P2). The calculation of Q2 is based on the formula for elasticity, which is given as:

Q2 = Q1 - eQ1(P1 - P2 /P1)

The calculation of Q2 is essential in estimating the social cost of the guidelines because it determines the size of the triangle ABC. The area of triangle ABC is equivalent to the social cost of the guidelines. It represents the loss of play area opportunities provided prior to the guidelines as a result of the incremental cost increase of the guidelines. This calculation was performed for surfacing options 1 and 2 for each size play area for both new and replaced play areas. Based on these calculations the lower and upper bound estimates of the social cost of the guidelines is presented in Table 4-21.

Table 4-21. Social Cost of Guidelines
($ in millions)

All Play AreasSurfacing Option 1: Engineered
Wood Fiber
Surfacing Option 2:
Loose Fill & Rubber
Low $8 $3
High $12 $15

4.5.3 Total Annual Costs

The total annual costs of the guidelines are the sum of the social costs and the direct costs. The direct costs are the aggregate increase in the annual cost of new and replacement play areas built after the guidelines are adopted as standards by the Department of Justice, which is represented by one through Q2 in Figure 4-1. The lower and upper bound estimates of the total annual costs are presented in Table 4-22.

Table 4-22. Total Annual Costs of Guidelines
($ in millions)

All Play AreasSurface Option 1: Engineered Wood FiberSurface Option 2: Loose Fill & Rubber
Social Costs
Low $8 $3
High $12 $15
Direct Costs
Low $29 $18
High $61 $69
Total Annual Costs
Low $37 $21
High $73 $84