Comments - Regional Airline Association

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Applicability Questions4. Is there is any reason to limit the applicability of thisrequirement to the largest U.S. and foreign air carriers,such as those that operate at least one aircraft with morethan 60 seats for example?5. Should carriers that only provide charter service besubject to different Web site accessibility requirementsthan carriers that provide scheduled service?6. Should we exclude from Web site accessibilityrequirements carriers that advertise air transportation butdo not sell airline tickets?7. Should carriers not be required to ensure that the Webpages on which online ticket agencies market and selltheir airline tickets are accessible?8. Should carriers only be required to ensure Web pageaccessibility of online ticket agencies that market andsell more than a certain percentage (e.g.10%) of thecarrier’s total ticket sales annually?9. Should this rule apply to ticket agents directly withrespect to ensuring that their Web pages on which they25 RAA believes the costs of requiring smaller air carriers operating aircraftwith fewer than 60 seats to comply with website accessibility requirementswould be higher than those estimated by DOT and would far outweigh thebenefits of doing so. DOT offers no support for the conclusion in theInitial Regulatory Analysis that “it is reasonable to expect that [smaller]carriers have staff members or contractors with the professional skills tomeet the proposed requirements.” Indeed, the IRA concedes “it is notclear that [small carrier] employees or contractors have the specificexpertise and professional skills that may be required to ensure that airtravel Web sites would comply with the proposed accessibilityrequirements.” 125 No comment.25 Yes; DOT should exclude from Web Site accessibility requirementscarriers that “advertise” air transportation but do not sell airline tickets.The use of different terms and standards for coverage will confusecompliance obligations without increasing consumer benefits. The term“marketing” should apply only to carriers that both offer and sell airtransportation. Carriers with websites that provide only flight schedules orservice information, especially those without fare information, should notbe subject to accessibility requirements.25-26 If DOT has the authority to regulate accessible ticket agent websites, DOTshould regulate ticket agent websites directly. There is no need to furthercomplicate enforcement of these regulations by forcing carriers into themiddle of a DOT/ticket agent relationship.26 No, carriers should not be held accountable for 3 rd party websites.26 Yes, direct regulation of ticket agent websites is the most efficient andpractical method of enforcement.1 DOT Initial Regulatory Flexibility Analysis, ACAA SNPRM Accessible Kiosks and Web Sites at p. 9, Submitted by Econometrica, Inc. in Docket DOT-OST-2011-0177, August 30, 2011
market and sell covered air transportation to the generalpublic in the U.S. are accessible?10. Should DOT wait for the Department of Justice to moveforward with its rulemaking under Title III of theAmericans with Disabilities Act before promulgatingregulations that require ticket agent Web sites to beaccessible?Technical Accessibility Standard11. Should the Department consider requiring a set oftechnical or performance accessibility standards otherthan WCAG 2.0?12. Besides the Section 508 standards, what other acceptedWeb site accessibility standards are available?13. In the final rule, should the Department permit carriers tocomply with Web site accessibility requirements bymeeting any accepted Web site accessibility standard?14. Does WCAG 2.0 Level AA conformance provide asufficient level of accessibility?15. Are there sufficient technical assistance resourcesavailable to support companies in implementing thestandard?16. As an alternative, should Level A conformance or LevelA plus conformance with some number of selected LevelAA success criteria be required as long as the result is atleast as strong as the current Section 508 Webaccessibility standard?26 No comment.26 Yes, the Department should adopt regulatory alternatives that allow arange of options and is not prescriptive. It should allow WCAG 2.0 LevelA or Level AA, Section 508, a full text conforming alternative website, anaccessible mobile website, and other options as detailed in our comments.26 Other standards include WCAG 1.0, WCAG 2.0 Level A, an alternativeconforming webpage as permitted by WCAG Level AA, Mobile Web BestPractices (MWBP) 1.0, Basic Guidelines (seehttp://www.w3.org/TR/mobile-bp/), and an all text version of the primarycarrier website.26 Yes, a flexible approach is the best method of regulating this issue and islikely the only scheme where benefits may outweigh the costs, aftercorrecting the PRA cost estimates.26 WCAG Level AA exceeds Section 508 and Title II & Title III webaccessibility standards, the Department should consider and allow othercompliance options.26 It is not clear if there are enough resources available because we do notknow the final website standard. If DOT requires a very prescriptivesingle standard it is likely there will not be enough resources and weexpect DOT would research and factor-in availability of resources before itproceeds with a prescriptive standard. Regulatory alternatives permittingseveral options and additional time is not likely to place a demand onresources.26 The Department should adopt regulatory alternatives and allow carriers toconform to Section 508, WCAG 1.0, 2.0 Level A, WCAG Level AA, a textalternative website or a mobile website that includes tier 2 accessibilityfeatures.17. The Department seeks comment on whether it should 27 No. The Department should not restrict alternative compliance options,
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 and 10: In addition to the 12-month develop
Page 11 and 12: IV.WebsitesA. ProposalThe Departmen
Page 13 and 14: In addition, DOJ does not have an e
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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 27: IATA Common Use Kiosk Working Group
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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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