Comments - Regional Airline Association

matter, many carriers would have to order new kiosks in lieu of a viable retrofit option ifretrofitting was required contrary to the current proposal.As described in section III(b)(4), there is a disconnect between the time period in the rule text,kiosk orders 60 days after the final rule effective date, and the PRA discussion on how long itwill take to develop a prototype kiosk that meets a new DOT accessible kiosk standard (one yearaccording to the PRA page 25). It is not clear how the Department estimated a $750 incrementalaccessible kiosk cost for orders 60 days after the final rule effective date, when the PRA states aprototype will not be available for one year. It will be impossible to place orders 60 days afterthe final rule effective date when a prototype will not be available for at least one year.In addition, supporting ongoing enhancements and maintenance of accessible kiosks will alsodrive additional costs. Carriers estimate a 15-20% overall increase in development costs tosupport and maintain an accessible kiosk solution. As each new enhancement is developed,additional effort will be required to create a new path for the text to speech process, and to unittest every screen, error, etc. Additional time will also be needed for functional testing this path.One major carrier estimates $300,000 to $700,000 in incremental ongoing costs on an annualbasis, depending on the specifics of the final rule.Reproduced Table 16 PRA 37KiosksTotal benefits (millions) $86.16Total costs (millions) $15.78Total Net Benefits $70.38Corrected Table 16KiosksTotal benefits (millions) $0Total costs (millions) $182.84Total Net Costs $182.84B. Websites1. BenefitsThe PRA assumes that the proposed accessible website requirements would save passengers withdisabilities an average of 1.3 hours per year in researching and booking air transportation. Thispassenger time savings would result in $171 million in benefits, discounted to $122 million overa ten-year period. 38This time savings assumption is incorrect and the Department provides only anecdotal evidenceto support this faulty assumption. The PRA states that this time savings is based onEconometrica, Inc staff reviewing carrier websites with a screen reader such as JAWS or37 PRA page 33.38 See PRA Table 21, page 45.19