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
3.2.2.3. High Accessibility Baseline
The High Accessibility baseline is the least conservative of the three baselines. The High Accessibility baseline assumes that:
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The percentage of auditoriums equipped to provide closed movie captioning or audio description amongst auditoriums operated by surveyed NATO members is true for all indoor auditoriums exhibiting digital movies in the United States.
As shown in Table 3-7, the NATO members responding to the survey operated 24,739 auditoriums. The High Accessibility baseline assumes that the percentage of auditoriums equipped to provide closed movie captioning or audio description amongst the total number of auditoriums operated by firms responding to the 2015 survey is true for the entire industry. The High Accessibility baseline is calculated by dividing the total number of auditoriums equipped to provide closed movie captioning or audio description, as reported in the 2015 survey, by the total number of auditoriums operated by the 2015 survey respondents, as shown in Table 3-10.
Table 3-10 : High Accessibility Baseline for Captioning and Audio Description
|
Technology |
Audito-riums Equipped to Provide Captioning/ Audio Description* |
÷ |
Total |
= |
High Access-ibility Baseline |
Number of Audito-riums Exhibiting Digital Movies Equipped to Provide Captioning/ Audio Description in Compliance Year |
|
Closed Movie Captioning |
22,836 |
÷ |
24,739 |
= |
92.3% |
36,312 |
|
Audio Description |
22,673 |
÷ |
24,739 |
= |
91.6% |
36,053 |
* 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).
**Based on estimated total number of indoor digital auditoriums (39,338) in compliance year (2017)
The High Accessibility baseline assumes that 92 percent of auditoriums are equipped to provide closed movie captioning and 92 percent are equipped to provide audio description. However, it is possible that the High Accessibility baseline overestimates the current percentage of auditoriums equipped to provide closed movie captioning or audio description. NATO members operating auditoriums that are not equipped to provide closed movie captioning or audio description may have been less likely to respond to the survey. Additionally, firms that are not NATO members may not have the same percentage of auditoriums equipped to provide closed movie captioning or audio description as do NATO members. The estimated costs of the final rule under the High Accessibility baseline are estimated as a sensitivity analysis presented in Section 4.2.2.
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