To: Re: In considering whether to adopt the Proposed Rule’s fare-difference provision

• Second, DOT should apply the breakeven methodology that it used for the OBW provision to the currently unquantified benefits of avoided injuries and fatalities for the enhanced-training provision.43 • Third, DOT should explain whether the breakeven level of benefits for the OBW and enhanced-training provisions are plausible. [...] To estimate the OBW provision’s total lavatory-accessibility benefits, DOT must identify the population that would directly benefit from this provision—that is, the number or share of passengers to whom it can assign the WTP of $194 (assuming the Proposed Rule uses 2021 dollars, as in the Lavatories Rule RIA) as a proxy for the incremental costs of the inability to access a lavatory on an aircraft. [...] DOT Should Apply the Breakeven Methodology That It Uses for the OBW Provision to the Currently Unquantified Benefits of Avoided Injuries and Fatalities for the Enhanced-Training Provision DOT should apply the same breakeven methodology that it applies to the OBW provision’s avoided-injuries benefits to the Proposed Rule’s enhanced-training provision, which the agency similarly expects to reduce bo. [...] DOT estimates the value of a statistical life (VSL), which represents the social benefit of avoiding one expected fatality, to be $12.5 million for a fatality in 2022.70 The agency can use the VSL in combination with the same assumptions regarding growth in wheelchair enplanements to derive an estimate of the avoided fatalities required for the enhanced-training provision to break even. [...] For the OBW and Enhanced-Training Provisions, DOT Should Explain Whether It Finds the Breakeven Level of Benefits to Be Plausible DOT should expand its breakeven analysis of the OBW and enhanced-training provisions to explain whether it finds the breakeven level of benefits to be plausible.