Comments - Regional Airline Association

57. Should the Department require carriers to developguidance manuals for such personnel on how toimplement technical accessibility standards so that theirWeb sites are also functionally usable by individualswith disabilities (i.e., they are able to access or acquirethe same information, engage in the same interactions,and enjoy the same products and services as nondisabledusers of their Web site with substantiallyequivalent ease of use)?Ensuring Ticket Agents Meet Web SiteAccessibility and Service Obligations58. The Department seeks public comment on the specificmethods carriers might use to ensure that their ticketagents marketing air transportation to the general publicin the U.S. are complying with both the requirements tomake the Web pages on their Web sites related tocovered air transportation accessible and to provideWeb-based discounts and amenities to individuals whoare unable to use their Web sites due to a disability.59. With respect to ensuring Web site accessibility, shouldwe require carriers to notify their agents that their Websites must be in compliance with WCAG 2.0 by twoyears after the rule’s effective date?60. Would such notification to agents be sufficient, or shouldwe require carriers to obtain certification from theiragents by two years after the rule’s effective date thattheir Web sites are compliant?61. Should we permit carriers to rely solely on their agents’certifications of Web site compliance, or should we alsorequire carriers to monitor their agents’ Web sites onceor twice a year?62. What about simply requiring carriers to bring anyinaccessible agent Web sites that they become aware ofto the attention of the those agents, and if the agent doesnot respond, bring those agent Web sites to thea website or at least allow a text alternative version.35 No, the Department should instead adopt regulatory alternatives that givecarriers the flexibility to consider usability features. Carriers shoulddetermine how best to provide guidance for accessible websites. Anymanual requirements will further burden carrier staff that are already busyimplementing other passenger protection requirements.35 Carriers will have no leverage to enforce DOT regulations. If theDepartment is interested in regulating ticket agent websites, it should do sodirectly not through carriers. Indirect regulation of ticket agents will causeconflicts in contractual relationships, slow implementation, and createanother layer of bureaucracy that does not benefit consumers.36 No, the Department should regulate ticket agents directly for the reasonsdescribed above.36 No, the Department should regulate ticket agents directly for the reasonsdescribed above.36 No, the Department should regulate ticket agents directly for the reasonsdescribed above.36 No, the Department should regulate ticket agents directly for the reasonsdescribed above. It is not clear how a carrier may become aware of anagent’s inaccessible website. If the assumption is that carrier personnelwill investigate complaints by passengers, this would require additional