12.07.2015 Views

Comments - Regional Airline Association

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102. Do passengers with disabilities prefer to check-in onlineat home to using an automated airport check-in kiosk?103. Is there a quantifiable benefit associated with reducedrisk in having to provide sensitive personal informationto strangers in order to receive assistance at aninaccessible kiosk?104. Is there a quantifiable benefit associated with reducedrisk of legal action related to kiosk inaccessibility?105. What cost savings can be expected from the reduction inresources carriers will have to allocate to provideequivalent alternative service to passengers withdisabilities who cannot use a carrier’s inaccessible kioskat an airport location (e.g., assisting passengers at theticket counter or at an inaccessible kiosk versus directingpassengers to the carrier’s accessible automated kiosk atthat airport location)?106. What is the cost impact of requiring carriers to provideequivalent service to passengers who cannot use anaccessible kiosk due to their disability at airport locationswhere all automated kiosks are accessible?107. Would a requirement for accessible automated airportkiosks have a significant impact on the cost, inventory,or delivery of such kiosks, and if so, for how long?108. Can manufacturers of accessible automated airportkiosks meet the market demand if 100% of new kiosksordered starting 60 days after the final rule’s effectivedate be accessible?109. If not, up to what percentage of new automated airportkiosks could the Department require to be accessible(e.g., 50% or 75%) before the demand would exceedwhat the manufacturers could meet?110. How often are automated airport kiosks replacedtypically?111. How many manufacturers currently make automatedairport kiosks?accessible kiosks.51 No comment.51 No, there is no benefit. Carriers already have this information, which isaccessible by the carrier’s agents. Therefore, there are no reduced risks ofproviding sensitive personal information to carrier agents who assistpassengers at an inaccessible kiosk.51 No.51 There will be no cost savings because carriers have agents at check in nowthat serve all passengers. The Department should exclude any cost savingsin this area.51 There is no or de minimus cost because carriers already staff check inareas.52 Yes, as detailed in our cost benefit comments, accessible kiosks are moreexpensive and more costly to maintain.52 No. Vendors have stated they would not be able to meet the demand foraccessible kiosks. They have said that time is required for engineering,product development, testing and deployment to all their customers. It willrequire a delay of 36 months to meet the demand.52 The demand cannot be met if the Department keeps the proposed 60-daytime period. The demand can probably be met if the Department delaysthe effective date for 36 months and only requires 10% of kiosk order to befor accessible kiosks.52 Industry practice varies from 2-3 years to 5 years.52 Unknown.

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