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

The primary analysis estimates the costs to movie theaters using the Medium Accessibility baseline.  As described in Section 3.2.2.1, one of the alternative baselines is the Low Accessibility baseline, which is the most conservative option.  This baseline assumes that the auditoriums already equipped to provide closed movie captioning and audio description, as reported in NATO’s 2015 Accessibility Survey, are the only auditoriums with such capabilities in the United States.  Because fewer auditoriums are assumed to be equipped to provide closed movie captioning or audio description in the Low Accessibility baseline, the overall costs are higher than in the primary analysis.

Table 4-10 summarizes the cost impact of using the Low Accessibility baseline in the analysis.  The total costs over the 15-year analysis period increase by 12 percent to $99.5 million when discounted by 7 percent.  Under the Low Accessibility baseline, the analysis assumes that there are fewer auditoriums already equipped to provide closed movie captioning or audio description before the rulemaking.  As a result, the incremental cost impact is higher than in the primary analysis, which uses the Medium Accessibility baseline.  However, even when using the Low Accessibility baseline—the most conservative baseline analyzed—costs still do not exceed $100 million in any given year.  For further detail, the annual costs by cost category for the Low Accessibility baseline are presented in Table 8-2 of Section 8.1 of the Appendices.