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

2.3.2. Device Acquisition

Similar to hardware acquisition, the methodology used for the device acquisition calculation is identical for both captioning and audio description devices.  These costs are also presented separately in the analysis.  Device acquisition costs are a function of:

• The number of auditoriums that are already equipped to provide closed movie captioning and audio description;

• The number of auditoriums that are not already equipped to provide closed movie captioning and audio description;

• The number of new auditoriums opening after the 18-month compliance date;

• The number of captioning or audio description devices required per auditorium; and

• The captioning or audio description device unit costs.  

The Final RA assumes that some movie theaters with auditoriums currently equipped to provide closed movie captioning and audio description may have to purchase additional captioning and audio description devices to comply with the scoping requirements outlined in Section 3.3.3 and 3.3.4.  The analysis assumes that movie theaters with auditoriums already equipped to provide closed movie captioning and audio description will need to purchase 50 percent of the devices required by the scoping requirements.

The device acquisition calculation is diagrammed in Figure 2-3. The first row shows how the number of devices purchased by movie theaters with auditoriums already equipped to provide closed movie captioning and audio description and the devices purchased by movie theaters with auditoriums that are not already equipped to provide such features are calculated.

The total number of captioning and audio description devices is monetized using the device unit costs for captioning and audio description devices (Section 3.4.3 and 3.4.4). The device acquisition costs calculated in the primary analysis are presented in Section 4.1.2.

Figure 2-3 : Calculation Diagram for Captioning and Audio Description Device Acquisition