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
3.2.2.1. Low Accessibility Baseline
The Low Accessibility baseline is the most conservative of the three baselines developed for the cost estimation. The Low Accessibility baseline assumes that:
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The auditoriums equipped to provide closed movie captioning or audio description as reported in the 2015 survey are the only indoor auditoriums exhibiting digital movies in the United States that are equipped to provide closed movie captioning or audio description.
The calculation for the Low Accessibility baseline is presented in Table 3-8. The Low Accessibility baseline is calculated by dividing the number of auditoriums equipped to provide closed movie captioning or audio description, as reported in the 2015 survey (Table 3-7), by the total number of indoor auditoriums operating in the United States (Table 3-1 in Section 3.1.1).
Table 3-8 : Low Accessibility Baseline for Captioning and Audio Description
|
Technology |
Audito-riums Equipped to Provide Captioning/ Audio Description* |
÷ |
Total Number of Indoor Audito-riums in 2015** |
= |
Low Access-ibility Baseline |
Number of Audito-riums Exhibiting Digital Movies Equipped to Provide Captioning/ Audio Description in Compliance Year |
|
Closed Movie Captioning |
22,836 |
÷ |
39,338 |
= |
58.1% |
22,836 |
|
Audio Description |
22,673 |
÷ |
39,338 |
= |
57.6% |
22,673 |
*Source: NATO, 2015 Accessibility Survey (2015) on RIN 1190-AA63, CRT Docket No. 126, Nondiscrimination on the Basis of Disability by Public Accommodations—Movie Theaters; Movie Captioning and Audio Description, available at
http://www.regulations.gov/contentStreamer?documentId=DOJ-CRT-2014-0004-0426&attachmentNumber=2&disposition=attachment&contentType=pdf (last visited Sept. 12, 2016).
**Source: NATO estimate from Deluxe Technicolor (Table 3-1)
***Based on estimated total number of indoor digital auditoriums (39,338) in compliance year (2017)
The Low Accessibility baseline assumes that approximately 58 percent of all indoor auditoriums are equipped to provide closed movie captioning and 58 percent are equipped to provide audio description. However, it is likely that the actual number of auditoriums equipped to provide closed movie captioning or audio description is higher than the figure calculated in the Low Accessibility baseline. This is because the Low Accessibility baseline does not include any auditoriums operated by NATO members who did not respond to the survey or any auditoriums operated by firms who are not NATO members. The estimated costs of the final rule under the Low Accessibility baseline are estimated as a sensitivity analysis in Section 4.2.1.
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