Final Regulatory Assessment and Final Regulatory Flexibility Analysis Final Rule - Nondiscrimination on the Basis of Disability by Public Accommodations - Movie Theaters; Movie Captioning and Audio Description
1. Introduction
This chapter begins by providing an overview of the structure of this Final RA and explaining how information is organized and presented in subsequent chapters. The remainder of this chapter describes the purpose and need for this rule and the scope of this Final RA, provides a brief description of the notice of proposed rulemaking that was published in 2014, and includes summaries and responses to public comments received in response to our Initial Regulatory Assessment (Initial RA).
Chapter 2 presents an overview of the methodology for calculating the costs attributed to the final rule and how the methodology is applied for calculating the costs for all movie theaters impacted by this rule.
Chapter 3 describes the available data, estimates, and assumptions that are the basis for inputs used in the cost methodology described in Chapter 2 and that are applied to calculate costs in Chapter 4.
Chapter 4 presents the cost analysis and results.
Chapter 5 discusses the benefits of this rule, which are not quantified in the analysis.
Chapter 6 presents alternatives to the rulemaking that the Department considered.
Chapter 7 presents the impact of this rule on small entities within the movie exhibition industry.
1.1. Purpose and Need for Rule and Scope of Regulatory Assessment
Title III of the Americans with Disabilities Act (ADA) contains broad language prohibiting public accommodations and commercial facilities—including movie theaters—from discriminating against individuals with disabilities. The Department’s title III regulation implementing title III’s auxiliary aid provision reiterates the obligation of covered entities to ensure equally effective communication with individuals with disabilities and identifies, among other things, “open and closed captioning” and “audio recordings” as examples of auxiliary aids and services. 28 CFR 36.303(a)–(c). Recent technological advancements in the movie exhibition industry—including widespread conversion from analog film projection to digital cinema systems—make exhibition of captioned and audio-described movies easier and less costly than ever before. In addition, it is the Department’s understanding that at this time nearly all first-run motion pictures released by the major domestic movie studios include closed movie captioning (and to a lesser extent, audio description).
Going to the movies is a quintessential American experience. “Movie theaters continue to draw more people than all theme parks and major U.S. sports combined.”2 Movies are a part of our shared cultural experience, “water cooler” talk, and the subject of lunch-time conversations. The Supreme Court observed over 60 years ago that motion pictures “are a significant medium for the communication of ideas” and “may affect public attitudes and behavior in a variety of ways, ranging from direct espousal of a political or social doctrine to subtle shaping of thought which characterizes all artistic expression. The importance of motion pictures as an organ of public opinion is not lessened by the fact that they are designed to entertain as well as to inform.”3 When individuals who are deaf or hard of hearing, or blind or have low vision, have the opportunity to attend movies that they can actually understand because of the availability of captions or audio description, they are exposed to new ideas and gain knowledge that contributes to the development of their communication and literacy as well as their integration into society.
Until recent technological developments, the only captioning methodologies available required that the captions be displayed directly on the film, and thus visible to all patrons in an auditorium, to which movie theaters and some patrons without disabilities objected. Current technology allows for closed movie captioning, which consists of captions that are visible only to those who use a special device and not the rest of the theater. This advancement in technology, coupled with the recent conversion to digital cinema, has made exhibition of captioned and audio-described movies easier and less costly.
While there has been an increase in the number of movie theaters exhibiting movies with closed movie captioning (and, to a lesser extent, audio description) due in large part to successful disability rights litigation brought by private plaintiffs and State attorneys general during the past few years, the availability of movies exhibited with closed movie captioning and audio description varies significantly across the U.S. depending upon locality and movie theater ownership. The ADA requirements for effective communication apply to all public accommodations (including movie theaters) in every jurisdiction in the U.S and should be consistently applied using a uniform ADA standard. The right to access movies exhibited with closed movie captioning and audio description should not depend on whether the person with a disability resides in a jurisdiction where movie theaters, subject to a consent decree or settlement, exhibit movies with closed movie captioning or audio description. And, even in jurisdictions where theaters exhibit movies with captioning and audio description, many do not make captioning and audio description available at all movie showings. Thus, some persons who are deaf or hard of hearing, or blind or have low vision, still cannot fully take part in movie-going outings with family or friends, join in social conversations about recent movie releases, or otherwise participate in a meaningful way in an important aspect of American culture.
The Department received numerous comments from individuals who are deaf or hard of hearing, or blind or have low vision, in response to its 2014 Notice of Proposed Rulemaking on Movie Captioning and Audio Description in Movie Theaters (2014 NPRM), 79 FR 44976 (Aug. 1, 2014), describing how they were unable to take part in the movie-going experience with their friends and family because of the unavailability of captioning or audio description. Many individuals felt that this not only affected their ability to socialize and fully take part in family outings, but also deprived them of the opportunity to meaningfully engage in the discourse that often surrounds movie attendance.
The Department is convinced that regulation is warranted at this time in order to achieve the goals and promise of the ADA and is explicitly requiring movie theaters to exhibit digital movies with closed movie captioning and audio description at all times and for all showings whenever movies are produced, distributed, or otherwise made available with such features unless to do so would result in an undue burden or a fundamental alteration.
2 Motion Picture Association of American (MPAA), Theatrical Market Statistics 2014 at 10 (2014), available at http://www.mpaa.org/wp-content/uploads/2015/03/MPAA-Theatrical-Market-Statistics-2014.pdf (last visited Sept. 12, 2016).
3 Joseph Burstyn, Inc. v. Wilson, 343 U.S. 495, 501 (1952).
1.2. 2014 Notice of Proposed Rulemaking
On August 1, 2014, the Department issued the 2014 NPRM proposing to require movie theaters to provide closed movie captioning and audio description at all scheduled showings of a movie that is produced, distributed, or otherwise made available with such features unless to do so would result in an undue burden or a fundamental alteration.4
In the 2014 NPRM, the Department proposed that movie theaters maintain a certain number of captioning and audio description devices based on movie theater size. The number of captioning devices required was based on the number of seats in a movie theater, and the number of audio description devices was based on the number of screens (auditoriums)5 in a movie theater. The Department further proposed that movie theaters give notice of the availability of captioning and audio description as well as train staff to operate the equipment and assist patrons in its use. The 2014 NPRM proposed a six-month compliance date for digital movie screens (auditoriums showing digital movies) and sought public comment on two options for analog movie theaters: Option 1, a four-year compliance date for analog movie screens (auditoriums), or Option 2, a deferral of rulemaking on analog screens (auditoriums) until a later date.
The Department sought comments on the 2014 NPRM and the Initial RA supporting it.
4 79 FR 44976.
5 In the 2014 NPRM and the Initial RA supporting it, the Department used the term “screens,” to describe the movie theater facilities subject to the captioning and audio description requirements of the proposed rule, but the Department has replaced the term “screens” with the term “auditoriums” in the final rule and the Final RA. Although the terms are synonymous in the movie theater context, the Department believes that “auditoriums” is more accurate.
1.3. Public Comments on Initial Regulatory Assessment and Department Responses
This section discusses public comments on the Initial RA that accompanied the 2014 NPRM, as well as changes made to the estimation of likely costs of this rule in response to those comments.
The Department received 436 comments during the 2014 NPRM comment period, and many directly addressed the assumptions, data, or methodology used in the Initial RA. The Department received comments from movie industry representatives, individuals with disabilities, advocacy groups representing individuals with disabilities, State and Federal entities, academic organizations, private companies, and other private individuals. The preamble to this rule provides the primary forum for substantive responses to these comments. This section discusses comments only to the extent that they implicated the Initial RA-related estimates, assumptions, or methodologies. A summary and discussion of comments as they relate to small entities can be found in Section 7.2.
General Comments Regarding the Initial RA’s Cost Estimation
The Department reviewed a number of comments suggesting that the Department underestimated the costs of complying with this rule. Commenters disagreed with a variety of cost estimates provided in the Initial RA. As a threshold matter, the Department agrees that in some instances, the estimates provided did not accurately capture a particular cost of compliance. For example, after reviewing the public comments, the Department determined that the staff training costs estimated in the Initial RA did not adequately capture the costs to comply with the operational requirements of the rule, and the equipment unit costs used in the Initial RA did not represent the most current market price of the available equipment. As a result, the Department has updated these estimates in response to the public comments received. However, the Department is confident that other estimates were reasonable and remain supported by the Department’s independent research. In consideration of all comments, the Department has made adjustments where appropriate. The comments at issue and related comments are specifically addressed below.
Comments Regarding the Cost of Captioning and Audio Description Equipment
In the Initial RA, the Department estimated the costs of compliance with the proposed rule by estimating the number of hardware units and device units the average movie theater within each venue type6 would need in order to comply with the scoping requirements, which determine the number of captioning devices and audio description devices a movie theater is required to have and maintain. Because the proposed scoping for captioning devices was based on the number of seats within a movie theater, the Department estimated the average seat count across each venue type. The Department also estimated the average number of auditoriums across each venue type to estimate the number of audio description devices and hardware units needed. One commenter noted that the Department’s estimates regarding the number of seats and auditoriums were too low, especially for Single-Auditorium and Miniplex movie theaters. Because of this underestimation, the commenter believed that small movie theater establishments would be required to purchase many more captioning devices than the Department assumed in its cost analysis. Based on industry survey information provided by the National Association of Theater Owners (NATO) in its individual comment, the Department has updated the Final RA cost estimation to reflect new data regarding average auditorium counts across venue types. Data concerning average seat count is no longer relevant because the final rule’s scoping for captioning devices is based on the number of auditoriums, rather than the number of seats, within a movie theater (Section 3.3).
The Department also received multiple comments concerning the unit costs for the hardware and individual devices as well as the Department’s methodology regarding these estimates. NATO provided the most recent unit cost data for all captioning and audio description equipment currently available on the market, and the Department has updated its cost estimates in the Final RA to reflect this updated information (Section 3.4).
In the Initial RA, the Department estimated the upfront costs for the captioning and audio description equipment by averaging the hardware and device unit costs of some equipment available on the market. One commenter stated that the Department’s methodology concerning the average hardware and device unit costs for captioning and audio description equipment was insufficient because it only averaged the costs of the less expensive equipment. According to the commenter, many movie theaters purchase the more expensive captioning glasses offered by Sony to satisfy audience demand, and as a result, the Initial RA substantially underestimated the cost of compliance by excluding the cost of Sony’s equipment from the average cost estimates. A second commenter pointed out that the intent of the RA is to estimate the minimum cost of compliance, indicating that the Department’s methodology and estimate regarding the upfront costs were reasonable.
Executive Order 12866 requires the Department to estimate the costs that movie theaters will incur as a result of this rulemaking. Currently, there is more than one manufacturer of the equipment necessary to provide captioning and audio description, and the cost for the equipment varies among the manufacturers. The Department has not specified the manufacturer from which movie theaters must purchase the equipment, and movie theaters retain the discretion to purchase the equipment of their choice. As a result, the Department has included the cost for all available equipment, including the Sony equipment, in its estimate of the captioning and audio description equipment unit costs for Miniplex, Multiplex, and Megaplex movie theaters. The Department has not added the cost of the Sony equipment to its estimate of hardware and device unit costs for Single-Auditorium movie theaters because the Department remains convinced that small movie theater establishments are highly unlikely to purchase the more expensive equipment. As the Department’s independent research indicates, the less expensive cup holder captioning devices account for the largest percentage of the captioning device market share, and NATO advised the Department that few movie theaters outside of the top movie theater chains actually use Sony’s captioning glasses. Therefore, while other large movie theater establishments may choose to use Sony’s technology, the Department has excluded this equipment from its estimate of the upfront costs for Single-Auditorium movie theaters (Section 3.4).
Comments Regarding Other Cost Estimates: Staff Training, Notice, Installation, Replacement, and Operation & Maintenance
In addition to the comments addressing the captioning and audio description equipment cost estimates, the Department received a number of comments addressing other cost estimates provided in the Initial RA. These comments addressed the Department’s estimate of staff training costs, notice costs, acquisition and installation costs, replacement costs, and operation and maintenance costs. Overall, commenters indicated that the Department either failed to include these costs in its estimates or that the Department’s estimate for these costs was too low.
The Department originally included staff training costs associated with the rule in its estimate of the annual operations and maintenance costs, but the Department sought public comment on the amount of additional time movie theaters would spend training their employees to operate the captioning and audio description devices and to assist patrons in their use. The Department received a single comment in response to this question. One movie theater anticipated that movie theaters would spend an additional fifteen minutes on employee training to ensure that their staff was knowledgeable about the equipment and in compliance with the rule’s operational requirements. In consideration of this comment, the Department has included a separate estimate for the staff training costs associated with the operational requirements of the final rule. The information provided by the movie theater commenter serves as the basis for the staff training costs estimate (Section 3.7).
The Department received only a few comments regarding its position that any cost associated with the notice requirement would be de minimis. One commenter argued that requiring notice in all places where movie times are listed would cost the industry millions of dollars annually because theaters would be required to invest in software upgrades, the purchase of new signage on an ongoing basis, the purchase of digital display sets, and increased advertising space to accommodate more text. However, this commenter did not provide any information or data to support this position, and the only other commenter on this issue, a movie theater, agreed with the Department’s conclusion that notice costs would be de minimis. According to this movie theater, the notice costs associated with the rule would be minimal for most exhibitors considering that the industry has largely separated itself from print advertising in favor of online advertising and that adding icons for captioning and audio description would not be very difficult.
Based on the Department’s independent research and the comments received, the Department maintains its position that the costs associated with the notice requirement are de minimis. The notice requirement does not require a movie theater to implement a specific form of notice. Movie theaters routinely use “CC” and “AD” or “DV” to indicate the availability of closed movie captioning and audio description in their communications currently, including on their Web sites and mobile apps, and the Department’s research indicates that the inclusion of such symbols does not increase the cost of advertisements already placed or require software upgrades as one commenter indicated (Section 2.4.4.2).
The Department also disagrees with commenters who criticized the Department’s failure to include accurate equipment unit costs and installation costs in the Initial RA. As the Department indicated in the Initial RA, the unit cost estimates of the available equipment included the cost to install the equipment, and these unit cost estimates were based on the most up-to-date data available to the Department during the development of the Initial RA. The Department has updated the equipment unit cost estimates, now referred to as “acquisition costs” in the Final RA, to reflect the most recent data concerning the unit costs for all available hardware and devices. The Final RA also now calculates installation costs as a separate cost based on a movie theater’s upfront costs (Section 3.5).
A couple of comments addressed the replacement costs estimated in the Initial RA, specifically the replacement costs of the individual devices. One commenter estimated that the useful life of the captioning devices is about 5 years. According to NATO, industry data indicates that between 2.5 percent and 15 percent of individual devices must be replaced annually. The Department has updated the estimate of individual device replacement costs to reflect the industry data provided by NATO. To incorporate the individual devices’ estimated 4–7-year useful life, the Department estimates that 20 percent of all captioning and audio description devices purchased as a result of this rulemaking will be replaced annually (Section 3.6).
Several commenters also argued that the Department’s estimate regarding operation and maintenance costs was too low. According to these commenters, the maintenance costs include costs associated with replacement batteries, periodic system testing, and upgrading software, and because these costs are relative to the cost of the equipment, the Department should consider the high cost of the devices when estimating this cost. A few comments seemed to express confusion that the operations and maintenance cost estimate in the Initial RA encompassed the costs associated with installation, replacement, and staff training. The Department has considered these comments and has included separate cost estimates for the costs associated with installation, replacement, and staff training. However, the Department’s independent research confirms that 3 percent of total equipment acquisition costs represents an accurate estimate of the annual operation and maintenance costs associated with this rule, especially now that installation, replacement, and staff training costs are estimated separately (Section 3.8). The relevant cost category has been renamed “maintenance and administrative costs” in the Final RA.
Comments Regarding the Benefits Estimate
The Department qualitatively discussed the benefits associated with this rule in the Initial RA. Without reliable information about the number of individuals who would go to the movies as a result of this rule or the number of captioned and audio-described screenings already shown, the Department determined that the benefits of the rule were difficult to quantify. Nonetheless, the Department determined that many individuals, both those with and without disabilities, would benefit as a result of the rule, and that such benefits justified any associated costs. Furthermore, the Department fully expected that the guarantee of access to movies screened at movie theaters for individuals with hearing or vision impairments would spur some level of new demand for movie attendance and, therefore, lead to increased box office receipts.
A majority of commenters addressing the Department’s benefit analysis recognized the difficulty in quantifying the benefits of the rule but agreed with the Department’s conclusions concerning the direct and indirect beneficiaries that this rule would serve. Many comments focused on the number of individuals with hearing and vision disabilities, arguing that the U.S. Census vastly underestimates the number of individuals who are deaf or hard of hearing, or blind or have low vision. Commenters also stated that in addition to helping individuals who are deaf or hard of hearing, movie captioning has the potential to increase the access and enjoyment of movies for a wide variety of people, including individuals with cognitive-communication disorders, language-based learning disabilities, aphasia, central auditory processing disorders, or individuals who are learning English or may be working to improve their literacy skills. Organizations representing individuals with hearing and vision disabilities commented generally that captioning and audio description provide the keys to American culture to the extent that these services help individuals with hearing and vision disabilities to be more familiar with “everyday events,” thus allowing them to be more socially integrated into society.
One commenter, however, criticized the Department’s benefit analysis. This commenter asserted that the Department failed to justify the rule with relevant, evidence-based research to demonstrate that the proposed rule would advance the intended benefits. The commenter further recommended that the Department conduct an industry-wide survey of movie theaters and individuals with hearing and vision disabilities to determine the number of individuals currently seeking captioning and audio description and their willingness to pay for such services.
The Department maintains its position that the non-quantifiable benefits of this rule justify the costs of requiring captioning and audio description at movie theaters nationwide. The Department received a number of comments from individuals with hearing and vision disabilities, as well as advocacy groups, indicating that individuals with disabilities are currently seeking these accessibility services, but that these services are either consistently unavailable or insufficient to meet their needs. With the information received from such comments and the Department’s independent research, the Department does not believe that conducting a nationwide survey is necessary to confirm that this rulemaking will advance the intended benefits. As section 1(c) of Executive Order 13563 highlights, agencies would be remiss to overlook the benefits “that are difficult or impossible to quantify, including equity, human dignity, [and] fairness.” With respect to such benefits, this rulemaking will not only ensure that individuals who are deaf or hard of hearing, or blind or have low vision, are afforded equal access to movie theaters across the country, but it will also ensure that such individuals are afforded the opportunity to participate in the social experiences that accompany a new movie’s release. As a result, the Department remains convinced that this rulemaking will significantly advance the achievement of the intended benefits, and that such benefits justify the costs associated with this rulemaking. See Chapter 5 for a more detailed discussion of the benefits of this rulemaking.
6 In the Initial RA, the Department used the term “theater type” to describe the movie industry’s classification of movie theaters based on the number of auditoriums within a movie theater complex. In the Final RA, the Department has replaced “theater type” with “venue type” in order to avoid potential confusion with the classification of movie theaters based on projection system (i.e., digital vs. analog) and the distinction between indoor movie theaters and drive-in movie theaters. The Final RA divides movie theaters into four venue types: Megaplex, Multiplex, Miniplex, and Single-Auditorium.
1.4. Changes to Rulemaking
This section summarizes significant changes between the final rule and the 2014 NPRM and explains how these changes impact the Final RA.
1.4.1. Deferral of Coverage for Auditoriums Showing Analog Movies Exclusively
The Department has decided to defer until a later date the decision whether to engage in rulemaking with respect to movie theater auditoriums that exhibit analog movies exclusively. The Department’s research indicates that very few analog movie theaters remain, and that the number of such movie theaters has declined rapidly in recent years due, in large part, to the movie industry’s conversion to digital cinema. The Department believes that it is prudent to delay further rulemaking with regard to analog movie theaters until it is clear whether, for example, there will be any movie theaters in the future that continue to show analog movies exclusively, whether analog movies will continue to be produced, and, if so, whether they will be produced or distributed with captioning and audio description. As a result of this decision, the primary analysis of the Final RA does not assess the costs to provide captioning and audio description for analog auditoriums.
1.4.2. Minimum Scoping Requirements for Captioning and Audio Description Devices
The Department has lowered the minimum required scoping for captioning and audio description devices in order to ensure that the scoping requirements sufficiently provide access to individuals with hearing and vision disabilities who need and will use the devices without requiring movie theaters to purchase more equipment than is necessary. The Department has adopted the minimum captioning device scoping suggested in a joint comment submitted by the deaf and hard of hearing community in conjunction with the movie exhibition industry. The Final RA uses these scoping requirements to estimate the costs of the final rule, as presented in Section 3.3.3. Similarly, the Department has adopted the minimum audio description device scoping suggested by the movie exhibition industry. Section 3.3.4 shows the audio description device scoping requirements that the Department used in the Final RA’s cost estimation.
1.4.3. Notice Requirements
In the final rule, the Department has identified the specific types of communications that are subject to the notice requirement. Movie theaters must provide notice of the availability of captioning and audio description on all communications and advertisements listing movie showings and times that are provided at or on any of the following: the box office and other ticketing locations, Web sites, mobile apps, newspapers, and the telephone. This list is exhaustive. Despite this change, the Department maintains its position that any costs associated with the notice requirement are de minimis because indicating the availability of captioning and audio description should not increase the cost of advertisements. (See Section 2.4.4.2 for more detailed discussion regarding why these costs are likely de minimis, which includes a discussion of the existing practice among many movie theaters of using abbreviations to indicate the availability of closed movie captioning, e.g., “CC”, and audio description, e.g., “AD”). Therefore, the Final RA’s cost estimation with regards to the notice requirement remains unchanged.
1.4.4. Operational Requirements
Because movie theaters may comply with the requirement to provide captioning at all screenings of a digital movie produced or distributed with such features through the provision of open movie captions, the Department has added a requirement that movie theater staff know how to turn on the open movie captions. This requirement applies to the extent that a movie theater intends to comply with this rulemaking by providing open movie captioning at all showings or on-demand whenever requested by or for a movie patron with a hearing disability. Since the Initial RA, the Department has changed its methodology for estimating the training costs associated with this rulemaking, and the Department’s training costs estimate in the Final RA includes the associated costs to train movie theater staff on how to turn on the open movie captions (Section 3.7).
1.5. Major Provisions of Final Rule
The major provisions of this rule can be summarized as follows.
First, the captioning and audio description requirements of this rule apply only to movie theaters with auditoriums that exhibit digital movies. The Department defers to a later date the decision whether to engage in rulemaking addressing the application of this rule to movie theater auditoriums that exhibit analog movies exclusively.
Second, within 18 months of the rule’s publication in the Federal Register, movie theaters must ensure that their auditoriums exhibiting digital movies provide captioning and audio description to patrons with hearing and vision disabilities at all showings whenever the movie is produced or distributed with these features. In no case does the rule require movie theaters to add captions or audio description for movies that are not produced or distributed with these features. Nor does the rule prohibit movie theaters from showing digital movies that are not produced with captions or audio description or from choosing to show the analog version of a particular movie, even if that movie is also produced in digital format with captions and audio description. The rule also specifies that movie theaters that convert from analog projection systems to digital cinema projection systems after the rule’s publication in the Federal Register must comply with the requirements of the rule either six months from the date of conversion or 24 months from the publication date, whichever is later.
Third, movie theaters must maintain a minimum number of fully operational captioning devices and provide them to patrons upon request. This requirement is based on the number of auditoriums at each movie theater that exhibit digital movies and is designed to ensure the availability of a sufficient number of devices for use at peak attendance times by individuals who are deaf or hard of hearing. An overview of these requirements by venue type is presented in more detail in Table 3-17 in Section 3.3.
Fourth, movie theaters must maintain a minimum number of fully operational audio description devices and provide them to patrons upon request. The rule permits movie theaters to use the assistive listening receivers that they are already required to provide to patrons pursuant to sections 219 and 706 of the 2010 ADA Standards for Accessible Design (2010 Standards)7 to meet this requirement if those assistive listening receivers have a second channel available to deliver audio description. An overview of these requirements by venue type is presented in more detail in Table 3-18 in Section 3.3.
Fifth, movie theaters may meet their obligation to provide captioning and audio description to patrons with hearing and vision disabilities through the use of alternative technologies, including open movie captioning, so long as that technology provides communication as effective as that provided to movie patrons without disabilities.
Sixth, movie theaters that exhibit digital movies must provide the public with notice as to the availability of captioning and audio description. This provision is necessary so that movie patrons who are deaf or hard of hearing, or blind or have low vision, can find out which movies are accessible to them.
Finally, movie theaters that exhibit digital movies must have staff available to operate and respond to problems with all equipment necessary to deliver captioning and audio description and to show patrons how to use the individual devices whenever digital movies with such features are shown.
As with other effective communication obligations under the ADA, movie theaters do not have to comply with these requirements to the extent that they constitute an undue burden or a fundamental alteration.
7 28 CFR 36.104 (title III) (defining the “2010 Standards” as the requirements set forth in Appendices B and D to 36 CFR part 1191 and in subpart D of 28 CFR part 36). The 2010 Standards are available at http://www.ada.gov/2010ADAstandards_index.htm.
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