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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

4.1.2. Upfront Costs

This section breaks down the upfront costs incurred by all movie theaters subject to the rulemaking.  Movie theaters incur the majority of the upfront costs during the first two years of the analysis (Table 4-5) leading up to the 18-month compliance date.  However, the cost estimation also includes the costs incurred by new auditoriums opening after the 18-month compliance date.  As a result, equipment acquisition and installation costs are incurred over the entire 15-year analysis period in the primary analysis.  Table 4-4 shows the total equipment acquisition and installation costs incurred over the 15-year period of analysis by venue type.  Overall, the upfront costs to movie theaters are expected to total $34.2 million when discounted at 7 percent.

Table 4-4 : Total Upfront Costs by Venue Type in Primary Analysis, Discounted at 7 Percent ($ millions)


Venue Type

Captioning Hardware Acquisition Costs 

Audio Hardware Acquisition Costs 

Captioning Device Acquisition Costs 

Audio Device Acquisition Costs 

Installation Costs 

 Total Upfront Costs

Megaplex

$5.0

$0.1

$4.8

$0.8

$0.3

$11.0

Multiplex

$7.9

$0.2

$7.6

$1.3

$0.5

$17.5

Miniplex

$0.9

$0.0

$2.0

$0.2

$0.1

$3.3

Single-Auditorium

$0.8

$0.2

$1.3

$0.1

$0.1

$2.5

Total

$14.6

$0.5

$15.7

$2.4

$1.0

$34.2

Table 4-5 shows the upfront costs incurred during the first two years of the analysis.  In the primary analysis, movie theaters with auditoriums subject to the rulemaking must comply with the rule’s requirements by the end of 2017.  As a result, movie theaters with auditoriums currently exhibiting digital movies will purchase and install the necessary equipment in 2016 and 2017.  As described in Section 2.1.2, the analysis assumes that 33 percent of these auditoriums will purchase equipment in 2016 and 67 percent will purchase equipment in 2017.  Overall, the upfront costs are expected to total $25.6 million over the first two years of the analysis, with $8.9 million incurred in 2016 and $16.6 million incurred in 2017 when discounted at 7 percent.

Table 4-5 : First Two Years of Upfront Costs in Primary Analysis, Discounted at 7 Percent ($ millions)


Venue Type

2016 Upfront Costs

2017 Upfront Costs

Total Upfront Costs (First Two Years)

Megaplex

$2.7

$5.0

$7.6

Multiplex

$4.2

$7.9

$12.1

Miniplex

$1.2

$2.2

$3.3

Single-Auditorium

$0.9

$1.6

$2.5

Total

$8.9

$16.6

$25.6

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