Air Travel Accessibility

§1. The technical standards

When DOT first considered website accessibility in 2004, it proposed using the technical standards for federal websites under Section 508 of the Rehabilitation Act of 1973. Some commenters liked the Section 508 standards, but others thought DOT should use the standards created by the Web Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C). The W3C is the principal international organization that creates standards for the Web. Member companies and groups have full-time staff dedicated to working together to develop various technical and usability standards. DOT did not like the WAI standard available at that time (Web Content Accessibility Guidelines (WCAG) 1.0 (1999)) because some requirements were not testable, making compliance difficult to verify. The guidelines have since been revised. Web Content Accessibility Guidelines (WCAG) 2.0 (2008) was created through a process that involved web developers, accessibility experts and the disability community. WCAG 2.0 is more extensive and specific than WCAG 1.0 and, in DOT’s view, solves the verifiability problem. DOT is now proposing to adopt WCAG 2.0 as the technical standards for air travel websites.

WCAG 2.0 establishes 4 general design principles: perceivable (users must be able to perceive all site information with at least one of their senses), operable (the site can’t require interaction that users can’t perform), understandable (users must be able to understand both how the site works and the information on it), and robust (content must be reliably available through assistive technologies). (See WCAG 2.0 “Understanding the Four Principles of Accessibility”) These are made more specific through 12 design and function guidelines.

Each guideline has a set of “success criteria” that are used to determine compliance (“conformance”) with the guideline. But it’s a little more complicated because for each guideline, there are 3 possible “levels of conformance“: A, AA, and AAA. Each level is more demanding than the previous one. According to WCAG 2.0, “Following these guidelines will make content accessible to a wider range of people with disabilities, including blindness and low vision, deafness and hearing loss, learning disabilities, cognitive limitations, limited movement, speech disabilities, photosensitivity and combinations of these.” (“Abstract” of WCAG 2.0 Guidelines). At the same time, though, WCAG 2.0 also warns: “Although content may satisfy the Success Criteria, the content may not always be usable by people with a wide variety of disabilities.” (“Introduction” to “Understanding WCAG 2.0″) (Because some travelers with disabilities–for example, people who are deaf-blind–may be unable to use even conforming websites, DOT would continue to require airlines to make web-only specials and similar information available by telephone or in-person to such travelers. See Websites: Implementation When?)

DOT proposes to require the WCAG 2.0 AA conformance level. This means the website must satisfy the success criteria of both level A and level AA. DOT is not proposing to go as high as level AAA because even W3C does not recommend this level as the standard for entire websites: the AAA success criteria are so demanding that it’s impossible to satisfy them for some kinds of web content.

DOT again considered using the Section 508 standards. But those standards were issued in 2000 and are now out of date. The U.S. Access Board is now working on revising them. Revised Section 508 standards won’t be completed for a few years, but the also proposes using WCAG 2.0. (See the U.S. Access Board draft revisions to Section 508 standards. ) Even so, DOT wants to know:

• Are there other accessibility performance standards DOT should consider?
• Do any carriers now have websites that conform to WCAG 2.0 Level AA? Do these standards provide sufficient accessibility?
• On the other hand, is Level AA too high? DOT initially intended to require accessibility for visual disabilities only, but recognized that WCAG 2.0 Level AA is considered to be the most up-to-date and widely used accessibility standard available. DOT believes there are significant commercial and other benefits to harmonizing with international accessibility standards, and expects that about 4.3 million users with disabilities will benefit from requiring the WCAG 2.0 Level AA standards. Still, redesigning carrier sites (especially very large ones) will be expensive. See Websites: Benefits & Costs of Accessibility. Will there be diminishing returns for the investment required to meet all the Level AA success criteria? Should DOT instead make the requirement Level A conformance? or Level A conformance plus some individual Level AA criteria, so long as the result is at least as accessible as the current Section 508 technical standards? If so, which Level AA criteria should be specifically included?

Read what DOT said: SNPRM: Current Website Proposal, SNPRM: Website Technical Accessibility Standard; RIA § 6.4: Estimated Benefits of Website Requirements

Proposed new § 382.43(c)

§2. Conforming alternate versions

WCAG 2.0 specifically allows sites to comply by creating conforming alternate versions of the entire site or of specific pages, rather than modifying the original. Several reasons are given for this:

1. New technologies may not yet support accessibility, but there are good reasons for using an innovative technology while waiting for an accessible version of it.
2. It may not be possible to modify some content on a page (e.g., for legal reasons), or there may be reasons why it is important to preserve material on the site that was not originally accessibly designed. (For example, on Regulation Room we preserve older, nonaccessible versions of the site for research purposes.)
3. Sometimes, the best experience for users with certain disabilities will be a specifically designed page/site, even if the original page/site can be modified to meet the guidelines.

Still, according to WCAG 2.0, “providing an alternate version is a fallback option for conformance to WCAG and the preferred method of conformance is to make all content directly accessible.” (WCAG 2.0: “Understanding Conforming Alternate Versions”) The current proposal permits conforming alternate versions, but DOT emphasizes that the “intent” of its accessibility requirements is that content should be directly accessible whenever possible.

Some carriers offer a text-only feature on the primary Web site; a text-only feature is described as a site compatible with screen-reader technology and can easily be accessed through a link on the primary Web site that directs the user to the text-only page. A text-only page will meet the required level of accessibility and be considered a conforming alternate version only if the site satisfies the following requirements:

• The site conforms at the designated level of A or AA.
• The site provides all the same information and functionality in the same human language.
• The site provides content that is as up-to-date as the carrier’s primary page.
• The site can be reached from the carrier’s primary page through an accessibility supported mechanism, or the primary page can only be reached from the text-only site, or the primary page can only be reached from the text-only site and the primary page also provides a mechanism to reach the text-only site.

1. Should the final regulations explicitly prohibit use of conforming alternate versions except “when necessary to provide the information, services, and benefits on a specific web page or website as effectively to individuals with disabilities as to individuals without disabilities”? What circumstances would make it “necessary” to use a conforming alternate version?
2. DOT is seeking comments from customers with disabilities on their experiences using-text only carrier Web sites. Are there gaps in the information and functionality on the text-only site compared with that on the carrier’s primary site?
3. Would the costs of making a text-only version accessible and in conformance with AA standards be substantially lower than for the standard website?

Read what DOT said: SNPRM: Current Website Proposal, SNPRM: Website Technical Accessibility Standard, Extension of Comment Period and Clarification Notice

§3. Performance standards?

The National Federation of the Blind (NFB) has urged DOT to specify performance (usability) standards as well as technical standards. NFB emphasized that complying with a technical standard without understanding the underlying accessibility goal can lead to implementing the standard in a way that hinders rather than helps access. For example, the WCAG 2.0 requirement for headings to identify items on a Web page (information, navigation controls, graphics, etc.) can result in a Web page with so many headings that screen readers can’t efficiently navigate it. Similarly, full compliance with the WCAG 2.0 requirement to label links with an “alt-tag” is not helpful if the alt-tags don’t adequately explain the link’s purpose. Because implementing requirements like headings and alt tags requires some subjective judgment, NFB thinks there must be standards for ensuring that a Level AA-compliant Web page is actually usable by travelers with disabilities.

There is no performance standard in DOT’s current proposal. NFB recommended the following: the web pages must ensure that persons with disabilities “may access or acquire the same information, engage in the same interactions, and enjoy the same products and services” offered to Web site users without disabilities “with a substantially similar ease of use.” DOT recognizes that whether ease of use is “substantially similar” will depend greatly on which screen reader or other assistive technology is being used. Since this is outside the control of the airlines, setting a performance standard might also require DOT to specify the types and versions of various assistive technologies to which the standard must apply.

• Should DOT adopt a performance standard in addition to the proposed technical accessibility standards? What should it be? To what types and versions of assistive technologies should it apply?
• Would it be valuable and feasible for DOT to require that airlines work with the disability community (by, e.g., establishing a committee on website accessibility) to assist carriers in maintaining accessibility through periodic site monitoring and feedback?
• Do timeouts present barriers for users with disabilities to using websites? If so, what are the costs and difficulties of providing timeout capability?

Read what DOT said: SNRPM: Website Technical Accessibility Standard

§4. Verifying compliance

A key problem with WCAG 1.0 was difficulty verifying that a site met the standards. According to WAI: “All WCAG 2.0 Success Criteria are written as testable criteria for objectively determining if content satisfies them.” (WCAG 2.0 “Understanding Conformance”) At the same time, WAI also warns: “There is as yet no tool that can perform a completely automatic assessment on the checkpoints in the guidelines, and fully automatic testing may remain difficult or impossible.” (WCAG 2.0 “Conformance Logos”) And, as the discussion of headers and alt-tags in the previous Section points out, literal compliance with the technical standards is not necessarily the same as assuring usability for travelers with disabilities. WAI is starting a WCAG 2.0 Evaluation Methodology Task Force “to develop more comprehensive guidance on evaluating web accessibility. The Evaluation Task Force will develop an internationally harmonized methodology for evaluating websites’ conformance to WCAG 2.0.” (The first draft is scheduled for December 2011, with revisions scheduled for public comment at several points in 2012.)

DOT has not proposed any specific way to verify compliance with the accessibility standards. WCAG 2.0 allows, but does not require, sites to contain a “conformance claim.” This is a statement specifying which site content conforms to what Level as of a specific date, and includes the web technologies relied on. Conformance must be determined page-by-page and retested every time a page is changed. DOT has considered whether to require carriers to include conformance claims on their sites, but is concerned that making and maintaining the claim may be too costly, given the kind of testing it requires and the size, complexity and changing nature of many carriers’ websites (see RIA Table 23).

• Can the available protocols and procedures for testing conformance with WCAG 2.o be implemented cost effectively by carriers?
• What other means are available to readily identify a site’s compliance?
• Are there any specific technical barriers to maintaining site accessibility once full compliance is initially achieved?
• Should DOT do random spot checks of carrier and online ticket agent (OTA) sites to monitor compliance? What methods should DOT use to determine whether the site complies?
• Should DOT require carriers to develop manuals for their web designers and programmers on how to implement the accessibility standards? Would this improve initial implementation of the standards? Would it help ensure that sites remain accessible as they are updated in the future?

Read what DOT said: SNPRM: Website Technical Accessibility Standard, SNPRM: Website Compliance Verification and Usability

§5. Mobile sites & other requirements?

Although the current proposal doesn’t require that mobile versions of air travel websites be made accessible (see Websites: Which? What Content?), DOT is considering such a requirement. Also, carriers could use accessible mobile sites as an interim compliance option. (See Websites: Implementation When?) For mobile sites, should the technical accessibility standards include not only WCAG 2.0 Level AA but also conformance with W3C Mobile Web Best Practices 1.0 (2008)?

For primary websites, DOT wants comment on two additional possible requirements beyond WCAG 2.0 itself:

1. Requiring web pages that are accessible to be identified as such. DOT suggests, as an example, a tag readable by screen readers. WCAG 2.0 does make available to web designers (but does not require) logos indicating compliance level that can be placed on each conforming page. It also provides the html code to alert screen readers to the presence and meaning of the logo.
2. Requiring that the site alert users when a link takes them to third party sites for booking non-air travel services (e.g., car rental) that may not be accessible.

Are there any other things DOT should require beyond WCAG 2.0?

Read what DOT said: SNPRM: Website Current Proposal, SNPRM: Scope of Website Requirements