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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

3.2.1. Overview of NATO’s 2015 Accessibility Survey

NATO is a trade association representing firms in the movie exhibition industry.  In 2015, NATO members in the United States operated approximately 32,499 of the 39,338 indoor movie auditoriums nationwide (82.6 percent).  In response to the 2014 NPRM, NATO conducted a survey (2015 survey) of its member companies regarding the number of auditoriums already equipped to provide closed movie captioning and audio description.19  NATO members responded via email during the spring and summer of 2015, providing information on the total number of auditoriums they operated and the proportion of those auditoriums that were equipped to provide closed movie captioning or audio description.

NATO received survey responses from 116 companies operating 24,739 auditoriums in the United States.  A quick overview of the 2015 survey results is provided in Table 3-7 below.  According to the 2015 survey, 22,836 auditoriums are equipped to provide closed movie captioning and 22,673 auditoriums are equipped to provide audio description.

Table 3-7 : 2015 NATO Accessibility Survey Overview

Auditoriums

Number of Auditoriums

Operated by 2015 NATO Survey Respondents

24,739

Equipped to Provide Closed Movie Captioning

22,836

Equipped to Provide Audio Description

22,673

Source: NATO, 2015 Accessibility Survey on RIN 1190-AA63, CRT Docket No. 126, Nondiscrimination on the Basis of Disability by Public Accommodations—Movie Theaters; Movie Captioning and Audio Description, available at http://www.regulations.gov/contentStreamer?documentId=DOJ-CRT-2014-0004-0426&attachmentNumber=2&disposition=attachment&contentType=pdf (last visited Sept. 12, 2016).

The member movie theaters responding to NATO’s 2015 survey represent 63 percent of all indoor auditoriums currently operating.  The next section explains the need for multiple baselines due to the uncertainty that exists in the number of auditoriums already equipped to provide closed movie captioning and audio description and operated by movie theaters that were not surveyed or that failed to respond to the 2015 survey.

19  Id.

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