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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

3.4.2. Audio Description Hardware Unit Costs

According to industry research, there are no additional audio description hardware costs for movie theaters purchasing USL or Sony’s captioning hardware.  As discussed in Section 3.4.1, these manufacturers’ captioning hardware units also have the capability to transmit audio description to movie patrons.  However, the Doremi Captiview audio description system (Fidelio) requires a programming station in addition to the bundled hardware. Generally, one programming station per movie theater complex is sufficient to provide audio description to patrons throughout the movie theater and costs $615.  The unit costs for all commercially-available audio description hardware systems are presented in Table 3-20.

Table 3-20 :  Additional Cost for Audio Description Hardware


Technology

Cost Per Theater for Audio Description Hardware

Doremi Captiview

$615 per Theater

USL

$0

Sony

$0

Average (Excluding Sony)

$308 per Theater

Average (All Technologies)

$205 per Theater

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).

The unit costs in the table have been averaged to develop an estimate of the average audio description hardware unit cost per movie theater based on all available technology.  Because there are no additional audio description hardware costs if a movie theater purchases the USL or Sony system, the average audio description hardware unit cost for Single-Auditorium movie theaters is $308, and it is $205 for all other venue types.

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