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

The Initial RA estimated the costs of captioning and audio description hardware separately.  However, industry research indicates that if a movie theater is required to provide both closed movie captioning and audio description, it would likely purchase a hardware bundle currently offered by manufacturers. These hardware bundles provide hardware with the capability to provide both closed movie captioning and audio description at a lower cost than when purchasing the hardware separately.  The unit costs for all commercially-available captioning hardware systems are presented in Table 3-19.

Table 3-19 :  Captioning Hardware Unit Costs

Source: NATO, Statement of Position on RIN 1190-AA63, CRT Docket No. 126, Nondiscrimination on the Basis of Disability by Public Accommodations—Movie Theaters; Movie Captioning and Audio Description 23, available at http://www.regulations.gov/contentStreamer?documentId=DOJ-CRT-2014-0004-0401&attachmentNumber=4&disposition=attachment&contentType=pdf (last visited Sept. 12, 2016).

*This figure represents an average of the cost for movie theaters with Doremi servers ($822) and the cost for movie theaters without Doremi servers ($906).

The captioning hardware offered by Sony and USL also includes audio description functionality. Although Doremi Captiview hardware does not include this dual capability, it offers hardware transmitters for captioning and audio description in a bundled set at a discounted price.  Doremi offers the bundled hardware at two different prices depending on whether the movie theater uses Doremi servers for their projection system.  The $864 unit cost displayed in Table 3-19 is an average of the bundled hardware cost for movie theaters with Doremi servers ($822) and the bundled hardware cost for movie theaters without Doremi servers ($906).

As previously mentioned, it is unlikely that Single-Auditorium movie theaters with limited budgets would opt to purchase the Sony Entertainment Access system given the availability of cheaper alternatives.  Although the captioning hardware offered by Sony is less expensive than the other available hardware units, the captioning devices (Sony Entertainment Access Glasses) cost more than the captioning devices offered by other manufacturers (Section 3.4.3).  Therefore, the cost estimation assumes that the average captioning hardware unit cost is $1,118 for Single-Auditorium movie theaters and $912 for all other venue types (Section 3.4.5).