Air Travel Accessibility

The discussion is now closed. The final summary is available.

§1. Importance of good data

DOT first considered website accessibility in a 2004 rulemaking proposal, but it didn’t then 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 website 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 dollar amounts 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?

1. Travelers with disabilities who will use air travel websites and can describe how DOT’s proposal would affect their travel experience
2. Usability experts who can help assess the value of the proposed website accessibility standards
3. Technical experts who know about the feasibility and likely cost of the proposed standards and the proposed website implementation timelines
4. Airline and ticket agent personnel who have experience with air travel websites

To comment, please select the section below that best matches the point you want to make.

§2. Benefits for travelers with disabilities

DOT anticipates that travelers with disabilities will benefit from air travel websites meeting the proposed website accessibility standards in at least 4 ways:

1. Time saved in obtaining information, purchasing tickets, checking in, etc.: DOT estimates that travelers with disabilities currently spend, on average, 1.2 hours per year on inaccessible web sites. Based on a study of 100 users with vision impairments, accessibility would cut this time by about 30%. For all travelers with disabilities predicted to use air travel websites, this adds up to time savings over 10 years valued at $159.78 million (undiscounted). (See RIA Table 21)

2. Decreased travel expenses from improved access to discounted or promotional air fares and other services offered online: Airlines are currently required to give the benefit of web-only specials to travelers who cannot book online because of disabilities, without extra charge for phone assistance. (See 14 C.F.R. § 382.31(c)). But, the traveler must know to call the airline and ask. DOT has not estimated the savings to travelers who would benefit from web specials they otherwise would not have known about, because it assumes these benefits would be offset by the loss in airlines’ revenues from selling a higher proportion of lower fare tickets. Accessibility might increase the overall amount of air travel by individuals with disabilities, but DOT thinks this effect would be small.

3. Reduced effort and frustration from use of existing air travel website: It might be possible to develop dollar values for this benefit, but DOT hasn’t attempted to do so.

4. Improved ability to make travel arrangements without relying on others’ assistance: DOT believes this is an important benefit that cannot be expressed in dollar values.

DOT expects that travelers with cognitive disabilities or conditions like epilepsy may also benefit from accessible redesign, but it has not tried to estimate the value of those benefits.

Read what DOT said: SNPRM: Website Costs & Benefits; RIA § 6.4: Estimated Benefits of Proposed Website Requirements

Has DOT overvalued, undervalued, or missed any benefits to travelers with disabilities, or other travelers?

§3. Benefits for airlines

Currently, airlines must have staff to personally assist travelers who can’t use their websites because of disability, which is usually done over the phone. DOT estimates that accessibility would reduce these calls for assistance by 50%. A market research study estimates a cost of $5.50 per call. Over the projected number of travelers with disabilities, this means a savings to airlines of $11.77 million (undiscounted) over 10 years. (See RIA Table 21).

Also, the redesign process will give airlines (and, indirectly, large OTAs, see Websites: Which? What Content?) a better understanding of performance issues on their sites. And, because providing fully functional mobile versions and making primary sites accessible is the trend in computing, carriers’ and ticket agents’ corporate image may be improved. DOT has not tried to estimate a dollar value for these benefits.

Read what DOT said: SNPRM: Website Costs & Benefits; RIA § 6.4: Estimated Benefits of Website Requirements

§4. Costs to airlines

Costs for site redesign and programming will vary a lot depending on how many pages the site has (which range from 60 pages for very small carriers to 900 pages for very large carriers), and on what types of web technology the site uses. DOT separately estimated costs for Tier 2 compliance and Tier 3 compliance (See Websites: Implementation When?)

Tier 2 estimates assume that carriers will comply at this stage by making the mobile version of their sites fully accessible. Retrofitting some pages of existing sites (the core-function pages covered by proposed Tier 2, see Websites: Implementation When?) is estimated to be comparatively more expensive than designing new compliant pages. DOT estimates that mobile versions have only 1/3 as many pages (20-300 pgs.) as carriers’ primary websites. Programming costs are estimated to be $150/hr. for very large and large sites, and $120/hr. for small and very small sites. Tier 2 compliance is estimated at $6,600 per site for very small carriers to $40,500 per site for very large carriers. Total cost for all 140 US and foreign carrier sites is $2.56 million (undiscounted) (See RIA Table 22).

Read the details of DOT’s Tier 2 estimates (including discounted figures): RIA § 6.5: Estimated Costs of Website Requirements

Since Tier 3 affects medium and large travel agents/tour operators as well as carriers (see Websites: Which? What Content?), both groups are included in these cost estimates. To achieve full WCAG 2.0 Level AA compliance for primary sites, the estimated cost per site ranges from $31,200 for the smallest sites to $225,000 for the largest sites. Total Tier 3 costs are estimated at $36 million (undiscounted). (See RIA Table 23). This includes $17.4 million for the 188 affected carrier sites and $18.6 million for the 422 affected sites of medium to large travel agents/tour operators. (The number of carrier sites is greater than in Tier 2 because Tier 3 includes all carriers that market air transportation to the general public, even if their websites do not offer the core functions relating to ticket sales and check-in that Tier 2 affected. (See Website Implementation: When?)

Read the details of DOT’s Tier 3 estimates (including discounted figures): RIA § 6.5: Estimated Costs of Website Requirements

• Are there any carriers whose sites now comply with WCAG level AA? How much did those sites cost to develop?
• Are DOT’s cost estimate components off? If so, by how much? Based on what data?
• Is it possible to reasonably estimate time required to make accessible embedded content, such as PDFs and multimedia?
• Are the initial costs of creating compliant websites different from creating noncompliant ones?
• How much time will it take to make a traditional website compliant? A mobile version of the site?
• What would be the cost and technical difficulty of making mobile versions accessible?

The annual costs of maintaining and upgrading primary sites to keep them compliant is estimated to be $2 million for carriers and $2.6 million for travel agents/tour operators. (See RIA Table 24). This assumes replacing or adding 20% of existing site pages each year. Per site cost for the largest sites is $23,400. (DOT noted in the Extension and Clarification that the per page maintenance costs had inadvertently been omitted from the formula used to compute costs for all the sizes other than the largest sites.)

Read the details of DOT’s Site Maintenance estimates: RIA § 6.5: Estimated Costs of Website Requirements

• Are the maintenance costs of an accessible site different than those of a nonaccessible site?

DOT recognizes other costs that are not easily expressed in dollar values: the opportunity costs of devoting resources to accessibility rather than other Web-based business strategies such as social networking; indirect costs of program management and training; and possible loss of creativity and design options if innovative Web content or functionality cannot be made accessible.