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 unit costs for captioning devices are presented in Table 3-21. The price of the captioning devices varies depending on the manufacturer and the device type.  Some manufacturers offer units that fit into movie theater seat cup holders, and others offer glasses worn by the patron.  Because USL offers both devices, the captioning device unit cost for USL is an average of the two devices offered: a cup holder device ($443) and the captioning glasses ($514).  For the Sony system, each captioning device requires both a receiver ($300) and a pair of glasses ($950) in order for the captions to appear on the glasses.

Table 3-21 : Captioning Device 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).

Although Sony has less expensive hardware costs, Table 24 demonstrates that the cost of a single Sony captioning device is more than double that of the other manufacturers.  Because the final rule’s captioning device scoping requirements require a Single-Auditorium movie theater to maintain four captioning devices, the difference in price between installing the Sony captioning system and installing another captioning system is significant.  The average captioning device unit cost when excluding Sony’s captioning device is $466 per individual device, and the Department uses this estimate as the average captioning device unit cost for Single-Auditorium movie theaters in the primary analysis.  The primary analysis assumes an average captioning device unit cost of $727 for Megaplex, Multiplex, and Miniplex movie theaters.