Comments - Regional Airline Association

28. Should the Department require electroniccommunications generated by a carrier, such asreservation confirmation, flight status notifications, andspecial offer emails to be accessible?29. What are the costs and technical difficulties of ensuringthat such content is accessible?Costs and Benefits30. The estimated cost per site for making primary Web sitescompletely accessible is estimated at $225,000 for thelargest sites having an average of 900 pages (1,500hours), $105,000 for large sites having an average of 300pages (700 hours), $50,400 for small sites having anaverage of 120 pages (420 hours) and $31,200 for thesmallest sites have an average of 60 pages (260 hours).These costs for bringing the Web sites into initialcompliance, which are based on a review of carrier Websites using a collection of Web development tools, wouldbe incurred during the first 2 years of the 10-yearanalysis period. Thereafter, U.S. and foreign carrierswould incur an estimated $2.0 million annually andticket agents an estimated $2.6 million annually in coststo ensure that their primary Web sites remain fullycompliant. We are seeking comment on whether thesecost estimates for Web site compliance are reasonableand address the relevant cost components.31. We believe very few carriers, if any, would need up to6,000 hours to comply with the proposed accessibilitystandards, the vast majority would be able to achievefully accessible Web sites within the number of hoursaccessibility standard. Certain airline webpage content will requireextensive efforts to comply with WCAG 2.0 and we therefore stronglyrecommend that alternative methods of compliance are permitted, asWCAG 2.0 contemplates. See WCAG 2.0 “conforming alternate version.”29 No, the Department did not propose an electronic communication standardin the SNPRM or cost and benefits in the PRA. The Department wouldhave to issue another proposal that includes the specifics of an electroniccommunications standard to provide notice, receive input and make aninformed decision.29 Like the costs and technical difficulties in creating accessible carrierwebsites, electronic communications were built to maximize consumeroptions and utilize new technology. Requiring carriers to modify existingsystems will be difficult and drive costs.30 The estimated website accessibility costs are significantly underestimatedin the PRA. As described in more detail in Section 5 of our comments,based on a survey of A4A members the cost of converting the largestcarrier websites to WCAG 2.0 would be $1.1 million per carrier. The U.S.and foreign carrier annual website maintenance and upgrading costs arealso underestimated. Adjusting only the largest website maintenance costsin PRA Table 24, we estimate annual largest website maintenance costs of$12.28 million. The total annual website maintenance costs will likely bemuch higher if the “Large,” “Small,” and “Smallest” website costs are alsoadjusted in PRA Table 24.31 As discussed further in our cost/benefit comments, the Departments’estimates grossly underestimate the scope and impact of the proposal.Given the clarification that the proposal applies, at a minimum to allwebpages that contain the carrier’s name in the url, 900 pages for the