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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

4.2.2. High Accessibility Baseline

The incremental cost impact of the rulemaking is also analyzed using the High Accessibility baseline, previously described in Section 3.2.2.3.  The High Accessibility baseline is the least conservative of the baselines derived from NATO’s 2015 Accessibility Survey.  The costs under the High Accessibility baseline are lower than in the primary analysis because more auditoriums are assumed to be equipped to provide closed movie captioning or audio description before the rule goes into effect.  Thus, fewer movie theaters are purchasing equipment as a result of the rulemaking.  The total costs over the 15-year analysis period under the High Accessibility baseline are $68.8 million when discounted at 7 percent, which is 22 percent lower than the total costs estimated in the primary analysis.  For further detail, the annual costs by cost category for the High Accessibility baseline are presented in Table 8-3 of Section 8.1 of the Appendices.

Table 4-11: High Accessibility Baseline Sensitivity Analysis, Discounted at 7 Percent, ($ millions)


Cost Category

High Accessibility Baseline

Primary Analysis

Percent Change

Captioning Hardware Acquisition Costs

$7.7

$14.6

-48%

Audio Hardware Acquisition Costs

$0.3

$0.5

-29%

Captioning Device Acquisition Costs

$13.6

$15.7

-13%

Audio Device Acquisition Costs

$2.1

$2.4

-13%

Installation Costs

$0.7

$1.0

-28%

Replacement Costs

$28.7

$36.1

-21%

Training Costs

$9.9

$9.9

0%

Maintenance and Administrative Costs

$5.6

$8.2

-31%

Total Costs

$68.8

$88.5

-22%

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