Comments - Regional Airline Association

The PRA assumption that the incremental cost for an accessible kiosk is $750 is underestimated.Based on a survey of airlines, the actual incremental cost ranges from $1,000 per kiosk to$20,000, with a median of $9,250. We note the kiosk enhancements, listed in the IATACommon Use Working Group paper attached to these comments, as well as additional detailsbelow, indicate incorporating accessibility features into airline kiosks will be a lengthy andcostly process:If the standards require audio, we would need to provide a plug-in option or speakerswhich might lead to network bandwidth issues.In addition to the new hardware, the application would probably need to be modified toutilize the new features. For example, if a tactile response is available on the newhardware, the application would probably need to be rewritten/modified to provide atactile response to a button push.Incorporating the new hardware would increase the development cycle/costs. Allsubsequent releases would need to be developed in a manner to support the existinghardware as well as the new hardware. Testing effort would likewise be increased.Additional training would be required for agents at the airports, call center support lines,help desk, and field technicians. (Whether you have one kiosk at a station or all kiosksat that station, additional training is still required for all personnel at that stations orsupporting that station.)Spare parts for the kiosks would need to be increased to account for the new hardwareWhen the PRA cost assumptions for kiosks are corrected, the total cost jumps from a discounted$15.78 million to $182.84 million. 35 This cost estimate significantly exceeds the estimated kioskbenefit by over $50 million. 36Retrofit costs are more difficult to estimate because there are several types of kiosks at airportsand each type has varying levels of functionality and spacing requirements. Based on a surveyof members, we estimate kiosk retrofit costs range from $2,000 per kiosk to $11,400 per kiosk,with a median cost of $7,000. As discussed above in comments, this retrofit could not take placefor at least 18 months after the effective date of the final rule because carriers and vendors wouldhave to analyze the final standards and develop retrofit solutions for each type of kiosk. We alsoreceived information that as many as 50% of all existing airline kiosks will be ending their lifecycle in the next 2 years (for example the TP2 kiosk), which means the manufacturer will nolonger support repair functions and will no longer produce replacement parts. As a practicalincorrect assumption because the proposed compliance standard is, kiosk orders 60 days after the final rule effectivedate. The department should adjust the “more than 6 months” and associated costs to “more than 60 days.”35 This $182.845 million is reached by multiplying the $9,250 median cost derived from our airline survey by thePRA 28,500 estimated “Total accessible kiosks required” in PRA Table 15 page 32. In other words, replace thePRA $750 estimated “Incremental cost of accessible kiosk” in PRA Table 15 with $9,250.36 This $50 million figure does not include a correction to the benefits, as we describe above.18