Agency Proposal
Kiosks: Benefits & costs of accessibility
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§1. Importance of good data
DOT first considered kiosk accessibility in a 2004 rulemaking proposal, but at that time it didn’t have the solid data about society-wide benefits and costs of new standards that it is legally required to have. (See DOT’s discussion of lack of kiosk data). Now, it has collected a lot of data, which is summarized in this post. (You can find all the details in the “Regulatory Impact Assessment” (RIA)). DOT wants help from you to check the accuracy of its estimates, provide additional information, and point out things it might have missed. Two things to remember: (1) Benefits and costs “count” even if it’s not easy to reduce them to dollars and cents. Many benefits from accessibility may fall in this category. Providing more detail helps DOT take these kinds of benefits and costs into account. (2) Benefits and costs that can be expressed in money must be backed up by data; general claims about expenses or savings don’t count for much without specifics.
Who should look carefully at this benefit and cost information?
- Travelers with disabilities who will use kiosks and can describe how DOT’s proposal would affect their travel experience
- Usability experts who can help assess the value of the proposed kiosk accessibility standards
- Technical experts who know about the feasibility and likely cost of the proposed standards and proposed kiosk implementation timelines
- Airline and airport personnel with practical experience about the current check-in process
To comment, please select the section below that best matches the point you want to make.
§2. Benefits: Travelers with disabilities
The proposed changes will allow travelers with vision or hearing impairments and travelers in wheelchairs to have the same convenience and time savings from using kiosk check-in now available to other travelers.
DOT estimates that travelers with disabilities would wait on average 13 minutes less to check in than they currently do waiting for help from airline staff. This figure is based on earlier expert estimates under the ADA for accessible ATMs and ticketing machines. Using (1) this figure; (2) the Federal Aviation Administration’s standard value of $28.60 per hour for traveler time; and (3) DOT’s estimate that an annual average of 1.2 million travelers with disabilities would be able and willing to use accessible kiosks, DOT estimates a 10-year total of $76.9 million (undiscounted) in time savings for these travelers. (See RIA Table 13)
Read the estimate details (including a discounted figure): RIA §5.4: Estimated Benefits of Proposed Kiosk Requirements.
- What percentage of travelers who can’t use current kiosks would use an accessible kiosk if one were available? To what extent do travelers with disabilities prefer to check in on-line before they get to the airport? Is the preference for on-line vs. airport kiosk check-in likely to change in the future?
- Is the 13 minute estimate accurate? Would the time saved vary by airport? If so, what airport characteristics would affect the amount of time saved?
- In general, what factors (e.g., number of flights, distance of flight, destination, number of passengers per flight, time between scheduled departures) have the greatest impact on wait time for a kiosk check-in?
- Suppose DOT were to require that 25% or 50%, rather than 100%, of kiosks be made accessible? (See Kiosks: Which? When?) Is it possible to reliably estimate how the time-saved numbers would change? Suppose DOT were also to require that travelers with disabilities be given priority access to one of the accessible kiosks? If DOT did not require priority access, how much longer would the wait time of these travelers be than the wait time of travelers who can use any machine?
DOT also recognizes benefits to travelers with disabilities that can’t easily be given a dollar value:
- Increased independence. Travelers with disabilities would have the full range of check-in choices (on-line pre-airport; airport kiosk; airport counter) and the ability to choose according to their own personal preferences.
- Increased sense of inclusion. Accessible kiosks will remove the embarrassment some travelers feel when needing to get assistance from an airline employee.
- Increased privacy. Accessible kiosks reduce the risks that may be associated with giving sensitive personal information to strangers during assisted check-ins.
Is there a way to monetize any of these? Are there others benefits to travelers with disabilities that DOT is missing?
Read what DOT said: SNPRM: Kiosk Costs & Benefits; RIA §5.4: Estimated Benefits of Proposed Kiosk Requirements.
§3. Benefits: Airlines & airports
Airlines should see a cost reduction when fewer travelers require help from a gate agent. In 2008, an airline trade publication estimated that kiosk check-ins save airlines an average of $3.70 per traveler. Using the estimated number of travelers with disabilities who could and would use kiosks, DOT calculates total cost savings to airlines at $45.9 million over 10 years (undiscounted).
Read the estimate details (including a discounted figure): RIA §5.4: Estimated Benefits of Proposed Kiosk Requirements.
- Are these estimates of cost savings for fewer agent-assisted check-ins accurate?
- Is it is possible to put a dollar figure on the reduced risk of litigation against airports and airlines by travelers with disabilities who complain about inaccessible kiosks under the ADA or other statutes?
Another benefit to airlines, not easy to quantify, is reduced congestion at ticket counters and better customer service. Accessible kiosks will lessen the demands on customer service agents for routine services like check-in and seat assignment, giving them more time to deal with travelers needing special attention for ticketing and baggage issues. Are there other benefits to airlines or airports?
Read what DOT said: SNPRM: Costs & Benefits; RIA §5.4: Estimated Benefits of Proposed Kiosk Requirements.
§4. Benefits to other travelers
DOT recognizes that reduced congestion at ticket counters means less waiting time for all travelers who need services available only from an agent. Also, travelers other than those with vision or auditory impairments, or who use a wheelchair, will benefit from accessible kiosks. For example, those with difficulty reading (or reading English) will be able to get kiosk instructions audibly. Is there is a way to value these benefits? Are there other benefits to travelers?
Read what DOT said: SNPRM: Kiosk Costs & Benefits; RIA §5.4: Estimated Benefits of Proposed Kiosk Requirements.
§5. Costs to airlines & airports
Kiosks have to be maintained and purchased in the normal course of business, so the cost calculations must be based on the difference between the cost of nonaccessible and accessible units. Based on DOT’s conversations with sellers of kiosks, it estimates an added cost of $750 per unit. This includes the cost of developing new hardware, middleware, and software (although hardware modifications such as keypad and audio jacks are estimated to represent no more than 10%-20% of this figure). DOT believes that the $750/unit additional cost will not decrease if more units are ordered. Using this figure, and estimates of the number of existing kiosks (11,000), the estimated addition of new kiosks (500/yr, decreasing as more travelers use on-line check-in before arriving at the airport), and the kiosks estimated 5-year useful life (see Kiosks: Which? When?) DOT calculates a 10-year, industry-wide cost of $21.4 million (undiscounted). (See RIA Table 15)
Read the estimate details (including a discounted figure): RIA §5.5: Estimated Kiosk Costs
- How accurate is the $750 additional cost estimate? What is the cost of developing middleware and software for a kiosk that has accessible hardware features?
- If DOT were to require that some existing kiosks be retrofitted (see Kiosks: Which? When?), what would retrofitting cost?
- DOT assumes that the cost per unit would rise if it were to require only 25% or 50% of total kiosks to be accessible (see Kiosks: Which? When?) because recovery of hardware, middleware, and software development costs would be spread over fewer units. Is this an accurate assumption? To what extent would cost projections change if DOT required accessibility of fewer than 100% of kiosks?
- How accurate is DOT’s estimate of number of kiosks now in service? How many of these are owned by airlines? What is the ownership breakdown of the rest?
- Is a 5-year useful life accurate?
- Are DOT’s estimates of annual increase in number of kiosks over time accurate? Are new services anticipated to be available on future kiosks that might affect these estimates?
- Do accessible kiosks have a higher installation, operation or maintenance cost? If so, how much and why?
Read what DOT said: SNPRM Kiosk Costs & Benefits; RIA §5.5: Estimated Kiosk Costs.
Are there any other costs that DOT has not recognized?
If DOT assumes the cost per unit would rise if fewer accessible kiosks were needed, why assume the cost per unit would stay the same if more were needed? The point about recovering development costs should work both ways.
I fail to see why airlines and airports should have to pay these added costs instead of just having priority lines for the disabled to be serviced by humans. The latter has got to be cheaper and less of a technical challenge. Do the disabled really want to use kiosks instead of getting personal service? Most able-bodied people would rather have the personal service and hate the kiosks.
mencik, could you say more about why you believe that most able-bodied people would rather have the personal service and hate the kiosks? DOT recognizes benefits to travelers with disabilities that can’t easily be given a dollar value, such as increased independence and increased privacy. You can read more about these benefits in the Regulatory Impact Analysis (RIA).
This regulation is another example of government trying to implement an inefficient and costly requirement on taxpaying travelers. Look what requirements on tarmac delays have done – increased flight cancellations. Look at what the airlines did to find other revenues – they added exorbitant fees onto travelers if they couldn’t fit all their travel gear into a small bag. The airlines won’t pay for this requirement if it get enacted – everyone who travels will. I find it very difficult to believe that there is not a more reasonable cost way to achieve the same end goal.
Hi mcheung, DOT believes that this proposed rule would save airlines $45.9 million in labor costs and save passengers $76.9 million by reducing waiting times. You can read more about these benefits in Table 13 of the Regulatory Impact Analysis. Do you think the Agency has considered everything that it should? What, if anything, do you think should be added to the calculation of costs and benefits?
The DOT is wrong. If this would save airlines $45.9 million in labor costs they would have already eagerly done this on their own.
Hi kingslav, and thanks for your comment. We hope that you continue to air your concerns and suggestions about DOT’s rule. However, opinions alone, without more explanation and reasoning, are not useful to DOT because they do not help them figure out what is wrong with the proposed rule and what should be changed. Is there anyplace you could point DOT and other commentors to that shows that airlines would do this on their own without regulation if they could save on labor costs?
This discussion seems to assume that it is difficult or expensive to make a kiosk accessible. It is not. It may take a change in corporate processes, or in our culture. But neither the technologies or design requirements are new and novel. Amtrak, for example, has had accessible kiosks for many years as have many local train services. Airline kiosks are even easier, because they don’t have to be “hardened” for outside use.
You don’t have to use assistive technology to benefit from an accessible kiosk.
- Many of us have older eyes and value larger type. At least on my airline, they do this pretty well already.
- Audio can be very helpful for people who don’t read English well (but who can understand it when spoken).
- Easy-to-press buttons are useful when you are carrying bags.
If most of the $750 per unit cost is design and development, how can the airlines claim that costs do not go down with additional use.
And if they save $3.70 per passenger using a kiosk, it doesn’t take many passengers with disabilities to make up for the cost.
The real question is why we are not willing to put all of our impressive technology to work creating a world in which everyone is included. I love using the kiosks? Why would we assume that an independent person with disabilities wouldn’t, too.
Based on conversations with kiosk vendors, DOT estimates that the additional $750 it costs to make a Kiosk accessible is a fixed cost that will not change over time. You can read more about their estimates in Section 5.5 of the Regulatory Impact Analysis (RIA). As discussed in section 2 of this post, DOT believes that there are benefits to travelers with disabilities that can’t easily be given a dollar value. Are there other benefits to travelers with disabilities that DOT is missing?
As a visually impaired person I DO NOT believe kiosks access would be beneficial. In fact, I suspect that the plan may ‘backfire’, making airport access more difficult. Not being able to read airport signage, and therefore requiring “meet and assist” assistance to my designated gate, I find it most convenient to fint a ticket agent who will also call for assistance to take me through security and to my gate. If kiosks become more widely used (or possibly required) in the future, it is likely tomean fewer ticket agents, thus longer wait times on line, and more difficulty and delays acquiring the assistance I need. Making keosks available to those disabled individuals who wish to use them may be a good idea in theory, but, as proven by the growth of ATMs and self service checkouts, the more automation – the less human assistance!
Thanks for your comment, alposner. Welcome to Regulation Room. Throughout the proposal, DOT has focused on trying to make sure airlines are providing the exact same type of service to travelers with disabilities as they do to travelers who do not have disabilities. Is this the wrong way to approach these issues in an airport? Are there any other potential costs to travelers that the Agency has overlooked?