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I

On Scope

In regards to the issue of rather website applicability should be limited to air carriers who

operate at least one aircraft with more than sixty seats, it would be remiss to limit disability

compliance regulation to only larger but not smaller commercial carriers and promote an

unbalance between companies. The purpose of the revised legislation in the Air Carrier Access

Act is to prevent discrimination by providing greater accommodations for individuals with

disabilities, and as such drawling a line of compliance based on the fiscal size of a vendor is not

only arbitrary but counterproductive to promoting the goal of equality among parties. In not

applying the same standards to small and large vendors, an unfairness of trade is created which

could potentially create deep seated effects in the market by creating different standards of

compliance based on carrier size. On one hand, forcing only larger airlines to meet the

additional compliance standard may serve as a means of attracting disabled customers away from

small carriers which may limit their amount of business. Conversely, in not extending this

additional standard of compliance to smaller vendors, an unfairness of standards results in which

smaller carriers not being forced to comply with standards as stringent as larger carriers. Some

dissenters to this opinion may argue there is a significantly higher level of difficulty in ensuring

smaller vendors comply with these standards, but the onerousness of this task is not evidence

compliance should not be extended to small vendors, rather the acknowledgement of an

additional challenge in the methods and means by which such purposes are pursued. Either way

one views the impact of treating smaller carriers different from larger carriers, there would not be

an overriding incentive to determine compliance based on business size.

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II

Kiosks Self Contained; Privacy

In regards to the proposed rule making airport kiosks self contained to allow use by all

passengers regardless of disabilities or limitations would allow for a more seamless experience

for passengers in airport terminals. Requiring speech activation in conjunction with the audible

feedback would not only allow consumers with visual disabilities to access the kiosks without

the need for airline staff for assistance; but those travelers who may have deficiencies in their

literacy would also benefit from this option. All that a passenger would be required to produce to

access this option is a personal headset or audio loop as the kiosk will provide the necessary

assistance that a passenger may require to complete their transaction. If the audio feedback is

available in a number of different languages this may also make the travel experience of all

travelers who may bemore proficient in a language not spoken by the airline staff or provided

through the written prompts.

The privacy concerns are an important issue to address with this proposed regulation

especially in situations where the kiosk may be projecting the prompts through speakers or

through the audible response of the traveler. Requiring that a headset or audio loop be connected

to activate the audio feedback would help resolve this issue but it could be rendered futile if the

traveler does not have either component available. If the information will be projected through

speakers as an alternative to private listening through a headset, the concern would lie in how to

relay important yet sensitive information to and from the traveler without compromising their

privacy. A situation may arise where a traveler is visually impaired, uses the projection speakers,

and must respond audibly back to the kiosk the relevant sensitive information needed to

complete the transaction. This proposed rule asks that automated airport kiosks shall provide the

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opportunity for the same degree of privacy of input and output available to all individuals.

Providing this right to privacy while also accommodating for certain disabilities which create the

need for audibly communicated information may be troublesome.

III

Kiosks: Benefits & Costs of Accessibility

On the whole, this proposed regulation would, in theory, make air travel a more

enjoyable and efficient experience for travelers with and without disabilities. Monetary benefits

to disabled travelers amount to $76.9 million over a ten year period. The Department of

Transportation reaches this number by estimating that it would save each disabled traveler who

used a disabled friendly kiosk 13 minutes of check in time, multiplying that number by the

Federal Aviation Administrations estimated value of $28.60 for every hour of travel time, and

then multiplying that by the DOTs estimate that 1.2 million disabled would use the kiosks.

Additionally, it would result in harder to quantify benefits for the disabled, such as an increase in

independence, sense of inclusion, and privacy. Furthermore, it would secure a costs savings to

airlines of $45.9 million over the same 10 year period while only costing the industry $21.4

million to install and maintain the kiosks. That results in a total savings of 24.5 million.

However, as one disabled traveler, alposner, noted in the comment section of the

regulationroom.org, more automation introduced through the use of kiosks may result in fewer

ticket and gate agents. Kiosks save airlines money precisely because they are able to reduce

head count by employing fewer ticket and gate agents. Some disabled travelers rightfully worry

that if airlines reduce their amount of service men and women to save costs and instead install

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kiosks to print tickets this will result in less attention that many disabled travelers need and

value. This issue is not addressed in the possible costs section in the same website. To be fully

informed on this issue the DOT needs to provide more information to travelers on how airlines

would continue to deliver the same or better staff personnel service to disabled and non-disabled

travelers after airlines reduce staff to realize the costs savings of kiosk deployment.

IV

On Foreign Carrier Requirements

I strongly disagree with application of WCAG 2.0requirements on foreign carriers with

respect to public-facing pages on websites they own or control that market covered air

transportation to the general public in the U.S.

There are three indicators if a foreign carrier website is marketing air transportation to the

general public in the U.S.: (1) Contains an option to view content in English, (2) advertises or

sells flights operating to, from, or within the U.S., and (3) displays fares in U.S. dollars. The (2)

and (3) indicators are not reliable, however, for the following reasons:

1. Foreign carriers should not be required to provide website accessibility for foreign flights that

begin or end in the U.S (as opposed to the ones within U.S.). The number of disabled people who

plan to go abroad and who also prefer to use the accessible websites and buy tickets by

themselves is low. Of those disabled Americans who wish to buy international tickets, they

would rarely go abroad by themselves. As opposed to other countries, the U.S. is the most

disabled friendly country with all the things favoring the disabled andit could be hard to travel by

a disabled person alone.Rather, they will have somebody accompanied. Of those disabled people

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from non-English speaking countries, who want to buy international tickets, they would use the

webpage in their own language and they are probably flying back to their hometown. They

would find somebody in their country about the ticket, who will use their own language, too.

And this goes back to the first indicator that the accessibility requirements have nothing to do

with the websites in non-English languages. The cost of the complex technology, as suggested by

ITSA, is prohibitively high. As reasoned above, it is not cost efficient to spend $20,000-$30,000

per company plus maintenance to provide such infrequently visited web pages. However, foreign

carriers still have to conform to the requirements if they provide domestic airline services for

non-discrimination and fairness reasons. The (2) indicator should only aim at the requirements

for domestic services provided by foreign carriers.

2. The most possible reason why foreign air carriers display some of their fares in U.S. dollars is

that it is easier for customers to compare the prices with domestic carriers. If this indicator

counts, then no foreign carrier is willing to provide such convenience, which is not the purpose

of the requirements. The (3) indicator should be abandoned.

There are certain exceptions to the disabled who still wish to use disabled-friendly

booking system to buy international tickets from foreign carriers and who would feel distressed

by the result of the comments above. The alternative, as suggested by the ways for smaller

carriers or agencies, is to use human service and make discounted web-based fares due to their

disability. This can reduce the cost as well as conform to the non-discrimination policy.