Comments - Regional Airline Association

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consequence of this prescriptive approach will be to constrain future innovation that wouldbenefit all passengers, including .passengers with disabilities. Adopting regulatory alternativeswill drastically eliminate unnecessary costs and focus on users and functionality.In adopting regulatory alternatives the Department should allow carriers to choose any of thefollowing options. Each option would provide all of the benefits included in the PRA, whilesignificantly reducing costs. Allowing this flexibility would permit each carrier to choose theoption that works best for its enterprise and its customers, while at the same time recognizingand promote airline investments already made in various web accessibility methodologies. Westress that a final rule mandating only one of the following options will not be in the passengers‟best interests because carriers have pursued a variety of approaches and invested in variousaccessibility technologies which encourages innovation and competition. Limited complianceoptions would inhibit innovation, and use of new technologies, ultimately limiting utility for allpassengers, and resulting in an undue burden for the industry.We also note, as the Department is aware, requiring WCAG 2.0 would set a very high bar thatexceeds federal government website accessibility requirements. No other government agency iscurrently required to meet the WCAG 2.0 Level A & AA standards. Only Section 508 currentlyimposes a website standard, which is WCAG 1.0 applying to the federal government. 20 Theairline industry should not be the “test case” or the first to implement WCAG 2.0, thegovernment should gain experience with this standard before imposing it on private industry.The U.S. Access Board asked in two Section 508 ANPRMs if a WCAG 2.0 standard would beappropriate to apply to the federal government. 21 The need for a second ANPRM indicates eventhe Federal government is concerned with proposing to adopt a WCAG 2.0 standard. 2220 36 CFR 1194.22 note.21 See ANPRM I, 75 Fed. Reg. 13457, March 22, 2010; ANPRM II, 76 Fed. Reg. 76640, December 8, 2011.22 For instance, there was confusion over whether strict compliance with WCAG 2.0 was proposed. See SocialSecurity Administration comments to the first ANPRM “We believe that The Board‟s solution is a good one—namely that WCAG AA equivalence, coupled with the additional requirement to meet provisions in the draft (e.g.sections 409, 413, etc.), will aid readability and understandability for many web developers. We do, however,suggest that the provision (or the advisory note) make explicit that the inverse is not true. Otherwise, members of thepublic can easily construe this to mean agency web sites should meet WCAG 2.0 (public misinterpretation on thisissue is evident today).(emphasis added). Docket ATBCB-2010-0001-0402; See also Department of HomelandSecurity comments, “The following language should be modified to ensure that the Section 508 Standards areapplicable, but that WCAG 2.0 conformance is acceptable, at the government’s discretion, as an equivalentStandard.Exception: Platforms, applications, and interactive content complying with the WCAG 2.0 Level AA SuccessCriteria and Conformance Requirements and, where applicable, 409 and 413 of this chapter shall not be required tocomply with other requirements of this chapter.Suggested replacement language:Platforms, applications, and interactive content, which meets the WCAG 2.0 definition of “Web page”, complyingwith the WCAG 2.0 Level AA Success Criteria and Conformance Requirements and, where applicable, 409 and 41312
In addition, DOJ does not have an explicit website accessibility standard under Title II (state andlocal governments) or Title III (places of public accommodation) of its ADA regulations. 23 Infact, DOJ did not impose a web accessibility standard in its recent 2010 update to Title II & IIIregulations, but instead chose to maintain a similar standard that currently exists for airlines, 24requiring state and local governments and places of public accommodation that do not have anaccessible website, to provide similar information to the public in a different format, e.g. over thetelephone. 25 The Department should strongly consider our alternative approaches and additionalcompliance time given the lack of experience in implementing WCAG 2.0 standards.Option 1One option should be a text alternative website that is one link away from the primary websiteand provides a passenger visiting the primary website using a screen reader direction at thebeginning of the primary website to the text alternative website. The text alternative websiteshould comply with any web accessibility standard, including WCAG 1.0, WCAG 2.0 Level A,existing Section 508 standards or Mobile Web Best Practices 1.0 (if applicable). The textalternative website should include all of the tier 2 functions but not include all of the contentfrom a primary carrier website. Providing all content in a text alternative website does not makesense because many applications do not easily translate into a text version and many webpagesare infrequently visited by all passengers. We note that all web accessibility standards, includingSection 508 applicable to the federal government permit a text-only page with equivalent orfunctionality. 26Option 2The second option should be a mobile website one link away from the primary website or thatautomatically loads on a smartphone or other mobile device that meets the Mobile Web BestPractices 1.0 standard. The accessible mobile website should include all of the tier 2 functionsbut should not have to include the entire carrier primary website because many functions orapplications do not easily translate to mobile technology. The Department recognized the utilityof mobile web pages by providing it as an option for phase 2. Moreover, the flexibility andpersonalization features of smart phone, as well as the rapid pace of associated applicationdevelopment, make this an attractive option that could more quickly render accessibilityimprovements that meet the actual needs of the disability community; this approach would alsoensure that accessibility features would more quickly align with available technology and enableof this chapter shall be considered to conform with the corresponding provisions from this Chapter.” [emphasisadded], page 6, Docket ATBCB-2010-0001-0320.23 See Title II see 75 Fed. Reg. 56235-56236; For Title III see 75 Fed. Reg. 56316.24 See 14 CFR 382.31.25 See Title II see 75 Fed. Reg. 56235-56236; For Title III see 75 Fed. Reg. 56316.26 See 36 CFR 1194.22(k), “A text-only page, with equivalent information or functionality, shall be provided tomake a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way.The content of the text-only page shall be updated whenever the primary page changes.”13
Page 3 and 4: BEFORE THE DEPARTMENT OF TRANSPORTA
Page 5 and 6: In sum, this proposal does not meet
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Page 9 and 10: In addition to the 12-month develop
Page 11: IV.WebsitesA. ProposalThe Departmen
Page 15 and 16: D. Additional Time is NeededThe Dep
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Page 19 and 20: matter, many carriers would have to
Page 21 and 22: visitors. However, Table 21 inexpli
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Page 39 and 40: market and sell covered air transpo
Page 41 and 42: 23. Should the accessibility requir
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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

Comments - Regional Airline Association

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