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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

4.1.3. Ongoing Costs

The ongoing annual costs are costs that movie theaters incur in addition to the upfront costs.  The ongoing costs quantified in the cost estimation include equipment replacement, staff training, and maintenance and administrative costs. 

Table 4-6 shows the replacement costs associated with each type of equipment necessary to provide closed movie captioning and audio description.  Replacement costs are expected to be $36.1 million over the 15-year period of analysis when discounted at 7 percent.  As detailed in Section 3.6.2, a portion of the required captioning devices are replaced every year and make up the majority of the equipment replacement costs in the primary analysis ($26.6 million).  Audio description devices are also replaced every year, but because these devices are less expensive on average than the captioning devices (Section 3.4), the associated replacement costs are much lower ($4.2 million).  Captioning hardware has the second highest replacement cost at $5.2 million over the 15-year analysis period, and audio description hardware has the lowest replacement cost at $0.1 million.  As described in Section 3.3.2, generally one unit of audio description hardware is required per movie theater complex in order for a movie theater to provide audio description in all of its auditoriums.  Also, the additional cost for audio description hardware is substantially lower than the cost of captioning hardware (Section 3.4).

Table 4-6 : Replacement Costs by Equipment Type in Primary Analysis, Discounted at 7 Percent ($ millions)


Venue Type

Captioning Hardware Replacement Cost

 Audio Description Hardware Replacement Cost

 Captioning Device Replacement Cost 

Audio Description Device Replacement Cost

 Total Replacement Costs

Megaplex

$1.8

$0.0

$8.3

$1.4

$11.6

Multiplex

$2.9

$0.1

$13.2

$2.2

$18.4

Miniplex

$0.2

$0.0

$3.4

$0.4

$4.0

Single-Auditorium

$0.2

$0.1

$1.8

$0.2

$2.2

Total

$5.2

$0.1

$26.6

$4.2

$36.1

In addition to replacement costs, the analysis also accounts for the annual ongoing costs related to staff training and maintenance and administrative costs.  Table 4-7 shows the total ongoing costs by venue type.  Staff training is expected to cost approximately $9.9 million over the 15-year period of analysis, and maintenance and administrative costs account for $8.2 million.  Overall, the ongoing annual costs amount to $54.3 million over the 15-year period of analysis when discounted at 7 percent.

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


Venue Type

Replacement Costs

Training Costs 

Maintenance and Administrative Costs

Total Ongoing Costs

Megaplex

$11.6

$3.5

$2.7

$17.8

Multiplex

$18.4

$5.6

$4.3

$28.2

Miniplex

$4.0

$0.7

$0.8

$5.5

Single-Auditorium

$2.2

$0.1

$0.5

$2.8

Total

$36.1

$9.9

$8.2

$54.3

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