Comments - Regional Airline Association

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incremental kiosk cost estimate is deficient and must be corrected. More importantly, theinformation we received on developing an accessible kiosk to the SNPRM proposed standardsindicates it would not be possible to create a prototype in less than one year. Portions of thePRA validate this development period, as described above. Therefore, there is a disconnectbetween the PRA and the SNPRM; how can the PRA include a $750 incremental cost for aproposed rule that would require accessible kiosk orders 60 days after the final rule when theprototype and cost of an accessible kiosk will not be known for at least one year after the finalrule publication? The Department should compare the accessible kiosk development timeperiods in the PRA (page 25) to the kiosk standard (orders 60 days after the final rule effectivedate) in proposed 382.57(a) and revisit the incremental cost estimate. It will be impossible toplace orders 60 days after the final rule effective date when a prototype will not be available forat least one year.The Department should also consider delaying a final rule until the U.S. Access Board finalizesits Americans with Disabilities Act (“ADA”) Accessibility Guidelines (“ADAAG”) to addressaccessibility of self-service machines such as kiosks used for ticketing, check-in or check-out,seat selection or boarding passes or until the DOJ finalizes its proposal on revisions to its ADAregulations for the accessibility of electronic and information technology equipment andfurniture such as kiosks, interactive transaction machines, point of sale devices and ATMs. Wenote that the Access Board specifically asked in its latest ANPRM whether tactilely discerniblekeys should be the only input method for modern touch screen devices:Question 8: Some modern touch screen devices, such as versions of some smartphonesand tablets, have proved popular with people who are blind, despite not having keyswhich are tactilely discernible. Should the provision requiring that input controls betactilely discernible (407.3) be revised to allow for such novel input methods? Should theBoard add an exception to 407.3 to allow for input controls which are not tactilelydiscernible when access is provided in another way? If so, how should access beaddressed when the controls are not tactilely discernible? Should a particular technologyor method of approach be specified? 17This is another example of technological advances that should be considered before adopting afinal rule and another reason to delay this rulemaking to benefit from information received inother ongoing rulemaking proceedings. 1817 76 Fed. Reg. 76646.18 Even though this question is asked in the context of Information and Communication Technology Standards andGuidelines, the information received on tactilely discernible input methods will be relevant to the part 382 kioskstandards. The Department should not adopt a prescriptive standard that prohibits use of the latest technology.10
IV.WebsitesA. ProposalThe Department proposed that carriers meet certain web accessibility standards in a 3 phase or“tier” approach. The first phase or tier requires that any new or redesigned website placed onlinewithin 180 days of the final rule must conform to WCAG 2.0 Levels A and AA. The secondphase or tier would require a carrier to provide seven core functions that conform to WCAG 2.0Levels A and AA on the carrier‟s primary website or on the carrier‟s mobile website within oneyear of the final rule effective date. Phase or tier 3 would require a carrier to conform allwebpages on its primary website (any website that includes the carrier name in the url) toWCAG 2.0 Levels A and AA within 2 years of the final rule effective date. Finally, theDepartment proposed that carriers ensure that the website of ticket agents on which the carriermarkets its airline tickets also conform to WCAG 2.0 Levels A and AA within two years of thefinal rule effective date. 19B. The Department Should Adopt Regulatory AlternativesWe support taking incremental steps to provide increase access to information and functions oncarrier websites that market air transportation. However, we believe that any regulatory mandatein this area take into account and recognize the substantial efforts by carriers to date to increasepassenger access to information on carrier websites. At the same time, as in the case with thekiosks, we believe it is incumbent of DOT to offer carriers a more flexible approach to meet thisshared goal of increased access. Carriers have already made substantial efforts to increasepassenger access to information on carrier websites, without a regulatory mandate to do so.These efforts have included incorporating accessible website features in newly developedapplications such as mobile websites or creating text alternative websites to better servepassengers with disabilities. The primary goal of these efforts has been to adopt usabilityfeatures, instead of limiting website development to strict standards. The result of these effortshas been to make the core and most important features of a carrier website accessible topassengers with disabilities. Many carriers use accessible website experts to maximize usabilityof carrier websites.The best way for the Department to meet its goals in this area is to change its proposedprescriptive website standard and provide additional flexibility. The Department should permitcarriers and ticket agents to meet any existing or future web accessibility standard. Adopting astrict “one size fits all” standard will unnecessarily divert carrier resources to comply withtechnical standards, when many of the estimated benefits have already been achieved or could beachieved in a much more efficient manner. Increased accessibility should embrace theinnovation, improvements, and features all passengers enjoy, such as carrier mobile websites orapplications downloaded onto a computer or smart device. Otherwise the unintended19 We note that proposed 382.57(c)(6)(iii) inadvertently refers to paragraphs (c)(6)(ii)(A) and (B) of this section,which do not exist. The intended reference was most likely (c)(6)(iii)(A) and (B) 76 Fed. Reg. 59327.11
Page 3 and 4: BEFORE THE DEPARTMENT OF TRANSPORTA
Page 5 and 6: In sum, this proposal does not meet
Page 7 and 8: processes will take at least 1 addi
Page 9: In addition to the 12-month develop
Page 13 and 14: In addition, DOJ does not have an e
Page 15 and 16: D. Additional Time is NeededThe Dep
Page 17 and 18: This assumption is faulty because t
Page 19 and 20: matter, many carriers would have to
Page 21 and 22: visitors. However, Table 21 inexpli
Page 23 and 24: Corrected Table 25WebsitesTotal ben
Page 25 and 26: Attachment 1
Page 27: IATA Common Use Kiosk Working Group
Page 30 and 31: IATA Common Use Kiosk Working Group
Page 36: Attachment 2
Page 39 and 40: market and sell covered air transpo
Page 41 and 42: 23. Should the accessibility requir
Page 43 and 44: we’ve estimated above. largest si
Page 46 and 47: 50. Should the time frames for impl
Page 50 and 51: on the accuracy of our assumption a
Page 52 and 53: 78. Is it reasonable to require tha
Page 54 and 55: equirements are not expected to acc
Page 56 and 57: 112. How many manufacturers current
Page 58 and 59: automated kiosks generally falls to
Page 60 and 61:
151. If both volume control and the
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Comments - Regional Airline Association

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