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

Any additional maintenance and administrative costs are also included in the analysis.  These costs include other potential costs not explicitly covered by the other cost components already included in the analysis (i.e., acquisition, installation, replacement, and training).  The maintenance and administrative costs include, but are not limited to:

• Periodic ongoing maintenance, system testing, and cleaning of devices – Under heavy use from patrons, movie theaters explain that the maintenance of individual devices is necessary in between uses to ensure that the devices are clean and fully operational upon request.  Depending on the technology, movie theaters may need to periodically replace the batteries in the devices.  This also includes any additional costs associated with troubleshooting, system testing, and software upgrades.

• Other additional administrative costs – These administrative costs include time spent providing and collecting captioning and audio description devices and demonstrating their use, if needed.  This also includes any costs associated with researching available systems to implement in addition to any other administrative costs.

To account for these costs, an annual cost factor is applied as a percentage of the total upfront costs.  The assumptions used to calculate maintenance and administrative costs throughout the analysis are presented in Section 3.8.