Comments - Regional Airline Association

inaccessible Web site once the conversion is completed?40. What would be the cost and technical difficultyassociated with conforming mobile Web content to theWCAG 2.0 accessibility standard or any otheraccessibility standard?41. How much time is needed to make an existing mobileWeb site or primary Web site entirely accessible?42. What is the cost impact of disclosing Web-based farediscounts and other Web-based amenities to passengerswith disabilities who indicate they are unable to use acarrier’s Web site due to their disability and who inquireabout air transportation with the carrier using anothermeans?43. Are there any unintended impacts, positive or negative,that could result from requiring carrier and ticket agentWeb sites to be accessible?each of the WCAG 2.0 Level A & AA standards. Additional time fordevelopment and testing is required to ensure ongoing accessibility,especially if HTML is changing.32 Carrier websites were developed to maximize consumer options andexperiences. Most carrier websites include complex search and bookingengines and constantly updating applications, much of this content wouldrequire re-engineering to incorporate accessibility requirements. Airlinewebsites are some of the most complex and innovative publicly availablewebsites, regulatory alternatives would allow carriers to balance theinteractive applications consumers are used to while also providing anaccessible website. We provide cost information in our cost/benefitcomments.32 The Department should not require an accessible website standard toinclude all website content because doing so will take a significant amountof time and effort, where regulatory alternatives permitting several optionswould provide the same benefit with much less time and cost as describedin our cost/benefit comments. If the Department were to allow carriers tochoose one of several compliance options, we recommend a two-yearcompliance period for every option.32 No cost, because section 382.31(c) already requires this accommodationand all carriers already provide it.32 Yes, there will be several negative impacts. First, the Department shouldnot regulate ticket agent website through carriers because requiring carriersto enforce the Department’s regulations will unnecessarily complicate thecarrier ticket agent contractual relationship and provide a much lesseffective enforcement mechanism. Second, a prescriptive accessiblewebsite requirement will discourage and degrade advanced applicationfunctions for all passengers, when regulatory alternatives would achievethe same benefits. From a technical perspective, for example, if javascript would have to be disabled, the design and overall functionality of aweb purchase process would break and in some situations, customerswould not be able to complete a purchase.