Comments - Regional Airline Association

The Department projects a 10-year monetized benefit of $86 million for kiosks and $122 millionfor websites. Ten-year monetized costs include $15.8 million for kiosks and $66.8 million forwebsites. The monetized ten-year net benefits include $70.4 million for kiosks and $55.3 millionfor websites. As our comments show, the PRA grossly overestimates the benefits and grosslyunderestimates the costs. Therefore this proposal does not meet EO 12866 and 13563 directivesand must be substantially revised before proceeding.Reproduction of Table ES1 31 Kiosks WebsitesMonetized Benefits $86.2 $122.1Monetized Costs $15.8 $66.8Monetized NetBenefits$70.4 $55.3A. Kiosks1. The Benefits Are Vastly OverstatedThe PRA assumes that the proposed requirements would make it possible for passengers withdisabilities to check in more easily and quickly, saving 13 minutes. This passenger check in timesavings would, according to the government‟s analysis, result in $122 million in benefits,discounted to $86 million.The Department offers no evidence or relevant analysis to support this assertion that accessiblekiosks will save disabled passengers 13 minutes in the check in process. One cannot concludethis time savings without comparing it to current airline practices. Part 382 requires and currentairline practices mandate that ticket agents provide personal assistance to disabled passengers,including moving them to the front of any check-in line. It defies logic to argue that accessiblekiosks will save disabled passengers any time over the current protocol, much less 13 minutes.While it is conceivable that disabled passengers would save some time using accessible kioskscompared to inaccessible kiosks, that is not the procedure currently followed by carriers orrequired under Part 382. The Department offers no evidence that disabled passengers currentlywait 13 minutes or more for access to an agent.Further, the PRA states:“For this analysis, we assumed that the time saved by the average passenger with adisability using an accessible kiosk would be similar to the time savings (13 minutes onaverage, relative to waiting in line for an agent) enjoyed when an inaccessible ATM orticketing machine is replaced by an accessible machine.” 3231 PRA page 2.32 PRA page 28.16