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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

4.1.4. Per Movie Theater Costs

The total costs estimated in Section 4.1.1, 4.1.2, and 4.1.3 represent the costs to all movie theater auditoriums exhibiting digital movies.  This section presents the estimated total costs that the average movie theater within each venue type will incur over the 15-year period of analysis.  The cost estimation in this section assumes that the average movie theater will purchase captioning and audio description equipment in 2016 and will maintain operations throughout the period of analysis.  For the purposes of this section, the average movie theater is not a theater already equipped to provide closed movie captioning or audio description before the rule goes into effect.

Table 4-8 presents the undiscounted upfront costs incurred by the average movie theater within each venue type.  The average upfront costs to a Megaplex movie theater that is not already equipped to provide closed movie captioning or audio description are approximately $27,358.  The largest expense associated with this rulemaking for a Megaplex movie theater is purchasing the captioning hardware for each auditorium.  The upfront costs for the average Single-Auditorium movie theater are $3,562, with the largest expense being the acquisition of captioning devices.  The upfront costs for the average Multiplex and Miniplex movie theaters are $18,309 and $9,834, respectively.

Table 4-8 : Average Per Movie Theater Upfront Costs by Venue Type in Primary Analysis, Undiscounted ($)


Venue Type

Captioning Hardware Acquisition

Audio Description Hardware Acquisition

Captioning Device Acquisition

Audio Description Device Acquisition

Installation Costs

Total Upfront Costs

Megaplex

$16,158

$205

$8,728

$1,470

$797

$27,358

Multiplex

$10,772

$205

$5,819

$980

$533

$18,309

Miniplex

$4,488

$205

$4,364

$490

$286

$9,834

Single-Auditorium

$1,097

$308

$1,864

$190

$104

$3,562

Table 4-9 shows the undiscounted ongoing costs throughout the period of analysis.  The costs associated with replacing captioning and audio description equipment are the most significant ongoing costs over the 15-year analysis period.  However, as detailed in Section 3.6, captioning and audio description hardware is expected to be replaced approximately every ten years while a portion of the required devices are expected to be replaced every year.  The rightmost column presents the average annual ongoing costs for the average movie theater within each venue type.  The average undiscounted, ongoing costs incurred in a single year range from $634 for a Single-Auditorium movie theater to $4,398 for a Megaplex movie theater.

Table 4-9 : Per Movie Theater Ongoing Costs by Venue Type in Primary Analysis, Undiscounted ($)


Venue Type

Total Replacement  Costs

Total Staff Training Costs

Total Maintenance and Administrative Costs

Total Ongoing Costs

Ongoing Costs Per Year

Megaplex

$46,957

$7,058

$11,952

$65,968

$4,398

Multiplex

$31,373

$4,705

$7,999

$44,077

$2,938

Miniplex

$19,255

$1,961

$4,296

$25,512

$1,701

Single-Auditorium

$7,566

$392

$1,556

$9,514

$634

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