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 cost estimation also quantifies any additional maintenance and administrative costs associated with the rulemaking.  This cost differs from the installation costs outlined in Section 3.5.  It also differs from the equipment replacement and staff training costs outlined in Sections 3.6 and 3.7, respectively.  As explained in Section 2.4.3, the operation and maintenance costs include:

• Periodic ongoing maintenance, system testing, and cleaning of devices: Under heavy use from patrons, movie theaters explain that the maintenance of individual devices is necessary in between uses to ensure that the devices are clean and fully operational upon request.  Depending on the technology, movie theaters may need to periodically replace the batteries in the devices.  This also includes any additional costs associated with troubleshooting, system testing, and software upgrades.

• Other additional administrative costs: These administrative costs include time spent providing and collecting captioning and audio description devices and demonstrating their use, if needed.  This also includes any costs associated with researching available systems to implement, in addition to any other administrative costs.

The RA uses a value equivalent to 3 percent of the total captioning and audio description equipment acquisition costs incurred by the movie theater to capture the additional costs associated with these items.  These costs are ongoing and occur annually in the analysis.  Sensitivity analyses conducted using a factor of 5 and 10 percent are presented in Section 4.2.7.