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

Information provided by manufacturers and other industry sources suggests that repair costs for captioning and audio description equipment will be relatively modest.  Captioning and audio description hardware is typically mounted high on a wall in a movie theater auditorium or otherwise placed in the projection booth.  As a result, it is unlikely to be tampered with or accidently broken by patrons or movie theater staff.  Captioning and audio description devices, on the other hand, are more prone to potential wear and tear by virtue of their use by movie patrons.  Thus, it is expected that captioning devices will require occasional cleaning or minor maintenance by movie theater staff, but these costs are captured by the ongoing maintenance and administrative costs.  Manufacturers also noted that repair of such equipment is rare.  For the most part, if equipment breaks down, the answer is replacement rather than repair.  Such costs are captured by the hardware and device replacement costs (Section 3.6).  Any additional repair costs for captioning and audio description equipment are thus expected to be de minimis.