Comments - Regional Airline Association

50. Should the time frames for implementing the phasedWeb site accessibility requirements be expanded (e.g., 12months for the first phase, 18 months for the secondphase and 30 months for the third phase)?Identifying Accessible Web Pages on PartiallyAccessible Web Sites51. Should the Department require carriers to ensure thataccessible Web pages can be readily identified as suchby people with disabilities (e.g., contain a tag readableby screen reader software)?52. If flight-related functions that must be accessible 180days or one year after the rule’s effective date cannot beaccessed from a carrier’s inaccessible home page, arealternative means for accessing those functions (e.g.,through a Google search) acceptable until the carrier’sentire Web site is accessible?Compliance Verification and Web Site Usability53. Can the available protocols and procedures for testingWeb content conformance with WCAG 2.0 beimplemented cost effectively by carriers?54. We are seeking comment on alternative means to readilyidentify a Web site’s conformance with applicableaccessibility requirements. What methods might DOTuse to ensure/verify compliance with the applicablestandards?55. Should the Department initiate random “spot”investigations of carrier and online ticket agency Websites to monitor compliance after the rule becomeseffective?56. Are there any specific technical barriers to maintainingair carrier Web site accessibility after full Web sitecompliance is initially achieved?34 The Department should not adopt the SNPRM as proposed. If theDepartment moves forward despite our recommendation, more time willbe essential. The second phase should be at least 36 months and the thirdphase should be at least 48 months. More time benefits passengers, givingindustry time to better adapt complex applications.34 Yes, this is a standard accessible website practice and should be adopted.34 Yes, the Department should consider any option that provides increasedflexibility.35 No, WCAG 2.0 standards cannot be implemented cost effectively bycarriers as explained in our cost/benefit comments. Therefore, we ask theDepartment to adopt regulatory alternatives allowing carriers to meet oneof several options.35 There are online tools and accessibility experts that can determine if awebsite meets accessibility standards. More important than determiningcompliance with strict accessibility standards, the Department should adoptregulatory alternatives that give carriers flexibility to continue the currentefforts to provide a usable accessible website.35 We suggest any initial “spot” investigations are used to provideconstructive feedback to carries on website areas that do not appear tomeet the adopted standards. This feedback can be used to resolve anyperceived glitches that will no doubt exist after this major reprogrammingeffort. The Department should not regulate ticket agent web sites throughcarriers.35 Yes, booking engines and java or flash programs used to enhanceconsumer experience on a carrier’s website do not easily translate to anaccessible environment. The Department should exempt these portions of