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
4.2.5. Device Replacement
As discussed in Section 3.6.2, captioning and audio description devices will likely need to be replaced on a regular basis because they will be under heavy use from patrons. However, uncertainty exists as to how many devices will need to be replaced each year. The primary analysis assumes that 20 percent of captioning and audio description devices will need to be replaced annually. Annual device replacement rates of 15 percent and 25 percent are analyzed as sensitivity analyses in this section.
Table 4-17 summarizes the impact on the total cost estimation if the captioning and audio description device replacement rate is lowered from 20 percent to 15 percent. Under an annual device replacement rate of 15 percent, the replacement costs decrease by 21 percent over the 15-year period of the analysis, and the total costs decrease to $80.8 million.
Table 4-17 : Device Replacement 15 Percent Sensitivity Analysis, Discounted at 7 Percent ($ millions)
Cost Category |
Device Replacement 15 Percent |
Primary Analysis |
Percent Change |
|
Captioning Hardware Acquisition Costs |
$14.6 |
$14.6 |
0% |
|
Audio Hardware Acquisition Costs |
$0.5 |
$0.5 |
0% |
|
Captioning Device Acquisition Costs |
$15.7 |
$15.7 |
0% |
|
Audio Device Acquisition Costs |
$2.4 |
$2.4 |
0% |
|
Installation Costs |
$1.0 |
$1.0 |
0% |
|
Replacement Costs |
$28.4 |
$36.1 |
-21% |
|
Training Costs |
$9.9 |
$9.9 |
0% |
|
Maintenance and Administrative Costs |
$8.2 |
$8.2 |
0% |
|
Total Costs |
$80.8 |
$88.5 |
-9% |
Table 4-18 summarizes the impact on the cost estimation if the captioning and audio description device replacement rate is raised from 20 percent to 25 percent. Under an annual device replacement rate of 25 percent, the replacement costs increase by 21 percent over the 15-year period of the analysis, and the total costs increase to $96.2 million.
Table 4-18 : Device Replacement 25 Percent Sensitivity Analysis, Discounted at 7 Percent ($ millions)
Cost Category |
Device Replacement 25 Percent |
Primary Analysis |
Percent Change |
|
Captioning Hardware Acquisition Costs |
$14.6 |
$14.6 |
0% |
|
Audio Hardware Acquisition Costs |
$0.5 |
$0.5 |
0% |
|
Captioning Device Acquisition Costs |
$15.7 |
$15.7 |
0% |
|
Audio Device Acquisition Costs |
$2.4 |
$2.4 |
0% |
|
Installation Costs |
$1.0 |
$1.0 |
0% |
|
Replacement Costs |
$43.8 |
$36.1 |
21% |
|
Training Costs |
$9.9 |
$9.9 |
0% |
|
Maintenance and Administrative Costs |
$8.2 |
$8.2 |
0% |
|
Total Costs |
$96.2 |
$88.5 |
9% |
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