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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

4.2.6. Staff Training Frequency

According to public comments on the 2014 NPRM, the additional time necessary to train staff as a result of this rulemaking is approximately 15 minutes.  The methodology used to quantify the costs of additional staff training is presented in Section 3.7.  The primary analysis assumes that the training would be conducted biannually over the period of analysis.  This sensitivity analysis observes the impact on the total cost estimation if the training were instead conducted four times per year as presented in Table 4-19 below.  Training costs over the 15-year analysis period increase to $19.9 million, increasing the total costs of the rulemaking to $98.5 million.  This is an increase of 11 percent compared to the primary analysis.

Table 4-19 : Increased Staff Training Sensitivity Analysis, Discounted at 7 Percent ($ millions)


Cost Category

Staff Training 4x Per Year

Primary Analysis

Percent Change

Captioning Hardware Acquisition Costs

$14.6

$14.6

0%

Audio Hardware Acquisition Costs

$0.5

$0.5

0%

Captioning Device Acquisition Costs

$15.7

$15.7

0%

Audio Device Acquisition Costs

$2.4

$2.4

0%

Installation Costs

$1.0

$1.0

0%

Replacement Costs

$36.1

$36.1

0%

Training Costs

$19.9

$9.9

100%

Maintenance and Administrative Costs

$8.2

$8.2

0%

Total Costs

$98.5

$88.5

11%

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