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

Captioning and audio description hardware acquisition is calculated and presented separately in the Final RA. However, the methodology for calculating hardware acquisition is identical for both captioning and audio description hardware.  Hardware acquisition costs are a function of:

• The number of auditoriums that are already equipped to provide closed movie captioning or audio description;

• The number of auditoriums that are not already equipped to provide closed movie captioning or audio description;

• The number of new auditoriums opening after the 18-month compliance date;

• The number of captioning or audio description hardware units required per auditorium; and

• The captioning or audio description hardware unit costs.  

The primary analysis uses the Medium Accessibility baseline presented in Section 3.2.2.2 to determine the number of auditoriums already equipped to provide closed movie captioning and audio description.  For the hardware acquisition calculation, the analysis assumes that movie theaters with auditoriums already equipped to provide closed movie captioning or audio description will purchase no additional hardware as a result of this rulemaking; however, all movie theaters with auditoriums not already equipped to provide closed movie captioning or audio description and all new auditoriums opening after the 18-month compliance date will purchase the hardware outlined by the scoping requirements presented in Section 3.3.1 and Section 3.3.2.

The calculation used for hardware acquisition is diagrammed in Figure 2-2.  In the first row, the number of auditoriums that are not already equipped to provide closed movie captioning or audio description (Section 3.2.2) and the new auditoriums opening after the 18-month compliance date are added together to determine the number of auditoriums purchasing hardware units throughout the analysis period.  In the second row, the number of auditoriums requiring hardware and the units required per auditorium (Section 3.3.1 and 3.3.2) determine the total number of hardware units purchased as a result of the rulemaking.  In the third row, hardware units are monetized using the unit costs for captioning and audio description hardware (Section 3.4.1 and 3.4.2).  The hardware acquisition costs calculated in the primary analysis are presented in Section 4.1.2.