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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

3.3.1. Captioning Hardware Scoping Requirements

According to industry research, a single unit of captioning hardware is required for each auditorium within a movie theater (Section 2.3). Therefore, the number of captioning hardware units a movie theater would need to purchase varies depending on the number of auditoriums operated in that movie theater.  For purposes of the cost estimation, the average number of auditoriums per venue type is used to calculate the number of hardware units required per movie theater.20  Table 3-15 presents the average number of auditoriums by venue type and estimates the relevant number of captioning hardware units required by the scoping requirements using the one unit per auditorium assumption.

Table 3-15 : Captioning Hardware Scoping Requirement Per Venue Type


Venue Type

Average Number of Auditoriums*

Captioning Hardware Units Required Per Venue Type

Megaplex (16+ auditoriums)

18

18

Multiplex (8–15 auditoriums)

12

12

Miniplex (2–7 auditoriums)

5

5

Single-Auditorium

1

1

*Source: NATO, Statement of Position on RIN 1190-AA63, CRT Docket No. 126, Nondiscrimination on the Basis of Disability by Public Accommodations—Movie Theaters; Movie Captioning and Audio Description 22 , available at http://www.regulations.gov/contentStreamer?documentId=DOJ-CRT-2014-0004-0401&attachmentNumber=4&disposition=attachment&contentType=pdf (last visited Sept. 12, 2016).

On average, a Megaplex movie theater would require 18 units of captioning hardware to provide closed movie captioning in each of the 18 auditoriums.  Similarly, the average Multiplex movie theater would require 12 captioning hardware units, the average Miniplex movie theater would require five captioning hardware units, and Single-Auditorium movie theaters would require one captioning hardware unit.

20  The average number of auditoriums by venue type was provided by NATO in its public comments on the 2014 NPRM.  See NATO, Statement of Position on RIN 1190-AA63, CRT Docket No. 126, Nondiscrimination on the Basis of Disability by Public Accommodations—Movie Theaters; Movie Captioning and Audio Description 22 , available at http://www.regulations.gov/contentStreamer?documentId=DOJ-CRT-2014-0004-0401&attachmentNumber=4&disposition=attachment&contentType=pdf (last visited Sept. 12, 2016).  

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