Comments - Regional Airline Association

112. How many manufacturers currently make accessibleautomated airport kiosks?113. How many manufacturers that make inaccessibleautomated airport kiosks are capable of making anaccessible model?114. How much lead-time does a company that manufacturesinaccessible automated airport kiosks need to developand start manufacturing an accessible model as proposedin this SNPRM?115. What is the size of companies that manufactureautomated airport kiosks?116. How many manufacturers of automated airport kiosksare small businesses?117. Do these smaller companies manufacture products otherthan automated airport kiosks?118. Do smaller companies have the capital and technologyavailable to make accessible automated airport kiosks?119. Would smaller companies be able to handle the marketdemand for accessible automated airport kiosks resultingfrom this rule or might cost or other reasons delay themanufacturing technology for such kiosks causing thesecompanies to be pushed out of the market?120. What is the cost difference between manufacturing a newautomated airport kiosk that meets accessibilitystandards and one that does not?121. What is the cost of retrofitting an existing kiosk to meetaccessibility standards versus manufacturing a newaccessible kiosk?122. What are the costs of developing accessible carriersoftware applications that are capable of running onproprietary or shared-use kiosks that have accessiblehardware features?123. Are there significantly greater quantitative andqualitative benefits and lower costs associated with52 No manufacturer makes an accessible kiosk that meets the SNPRMstandard, primarily because the Department created a new, never beforeseen standard, so it would be impossible for any manufacturer to havecreated a compliant kiosk prior to release of the SNPRM.52 Unknown.52 Manufacturers need a minimum of one year to develop an accessible kioskto meet any kiosk regulatory requirements. It will take at least another sixmonths to test and incorporate a new kiosk into the manufacturing process.52 Unknown.52 Unknown.52 Unknown.52 Unknown.52 No manufacturer would be able to meet the demand created by theSNPRM because it will take 12 months for any manufacturer to develop aprototype kiosk and an additional 24 months and provide them in sufficientquantity to carriers.52 The cost difference ranges from a low of $2000 to a high of $20,000, witha median cost difference of $9,250 per kiosk.52 The Department should not require a retrofit because doing so wouldviolate the APA and Executive Orders 12866 and 13563.52 Shared kiosk costs are similar to carrier-owned kiosks.Yes, given the median incremental cost of an accessible kiosk is $9,250per kiosk, requiring all kiosks are accessible will be much more costly.