Agency Proposal

By the Regulation Room team based on the SNPRM

Websites: Implementation when?

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§1. Compliance timelines

DOT proposes that the website accessibility standards would be phased in over 3 stages (or “tiers”):

Tier 1: Any new or completely redesigned primary website brought online 180 days (6 mos.) or more after the regulations become effective must be fully compliant. DOT’s review of carrier sites showed that larger carriers tend to redesign their sites every 2-4 years; smaller carriers, every 4-5 years. If these patterns continue, about half of larger carriers and a third of smaller carriers will come into full accessibility compliance during the first 2 years after the regulations become effective. Tier I apparently does not apply to new or redesigned OTA websites.

  • DOT defines “complete redesign” as ”technical changes affecting a substantial portion of the site such as its visual design (the site’s ‘look and feel’), upgrading the site to ensure its overall compliance with technical standards, or reorganizing the site’s information architecture. Updating the information content of one or more Web pages alone would not constitute a Web site redesign.” Should new pages be included in this Tier, even if they are not part of a new or completely redesigned site? Making new pages fully accessible may be difficult without redesigning fundamental elements of the entire site, such as navigation; but should DOT adopt a standard that new pages comply to the “maximum extent feasible”?

Tier 2: Pages for core air travel services and information on existing sites must be fully accessibly within 12 months (1 year) of the regulations’ effective date. The list of these core functions is: booking or changing a reservation; flight check-in; accessing a personal travel itinerary or frequent flyer account; flight status or schedules; carrier contact information. Tier 2 apparently does not apply to core-function pages of OTA websites. It would not affect small carriers whose sites do not provide these core functions. (See Websites: Which? What Content?)

  • DOT recognizes that the carrier’s home page may not be covered by the core-function list. Are alternative means for finding accessible core-function pages on the site acceptable? (e.g., through a Google search)
  • Is the reservation booking mechanism more difficult to make accessible than other functions? If so, is 12 months enough time for achieving accessibility? Alternatively, could just this function feasibly be required within 180 days?

Carriers would have the choice to comply with Tier 2 by linking travelers with disabilities to accessible core-function pages on the carrier’s mobile version of its website, rather than redesigning pages on the primary website. (Travelers with disabilities would then have the choice of using the mobile version on either a desktop computer or a mobile device.)

  • Mobile versions of websites eliminate or simplify graphical menus and other non-text design features, so they tend to be more accessible anyway. What have travelers with disabilities experienced when accessing services and information
    on carriers’ mobile sites? Do mobile sites provide the all the core functions listed above?
  • DOT assumes that a mobile compliance option for Tier 2 would be easier for carriers because mobile site pages could be redesigned more readily than individual pages on primary websites. How much time is reasonably needed to make an existing mobile site accessible?

Tier 3: All public pages of all US carriers’ primary websites, and all covered pages of foreign carriers’ websites (see Websites: Which? What Content?) must be fully accessible by 24 months (2 years) after the new regulations’ effective date. By this date, carriers must also make sure the websites of their medium or large OTAs are accessible, and that their small ticket agents with inaccessible websites are using other means to offer travelers with disabilities equal access to web specials and other web-only services. (See Websites: Which? What Content?) As DOT’s proposal is currently written, a carrier could not choose to comply at Tier 3 by retaining a non-accessible primary web site that sends travelers with disabilities to an accessible mobile website.

  • Is a 2-year time frame sufficient to make all publicly available content on a carrier’s existing main website accessible?

In proposing the 3-Tier approach, DOT is trying to balance making core services accessible to travelers with disabilities quickly, with the time and money involved in redesigning large and complex websites. (See Websites: Benefits & Costs of Accessibility).

  • When DOT first proposed website accessibility in 2004, some carriers estimated it would take 4,700-6,000 hours of planning, programming and testing to make their primary websites compliant. DOT’s current time estimates are much lower (260-1,500 hours depending on site size. See RIA Table 23). In general, should the compliance timelines be longer – to, e.g., 12 months for Tier 1, 18 months for Tier 2, and 30 months for Tier 3?
  • Is there another, better approach for setting compliance deadlines?

Read what DOT said: SNPRM: 2004 Website Comments, SNPRM: Current Website Proposal, SNPRM: Website Implementation Approach and Time Frame ; RIA 6.1: Current Industry Website Practices, RIA 6.3: Website Compliance Scenarios

Proposed new §382.43(c)(1),(2)

§2. Alternate Access to Air Travel Information

While inaccessible website content is being updated on the 3-Tier schedule, carriers must use other ways (e.g., telephone, in person) to make web-based fares and other web offers and services available to travelers with disabilities who self-identify as being unable to use the carrier’s site. Even after websites fully comply with the proposed accessibility standards, DOT will require carriers to continue to do this for travelers who are still be unable to use the website because of disability (e.g., travelers who are deaf-blind).

Read what DOT said: SNPRM: Current Website Proposal
Proposed new § 382.43(e), (f)

Peoples' Comments

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September 19, 2011 11:29 am

I think that the timeline for the 3 tiers has to be more flexible. Some airlines may be a lot closer than others to becoming accessible already. DOT could give a little more time to the airlines that are currently further behind or are struggling more financially already.

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    October 31, 2011 6:04 pm

    I think this says that completely new sites that come online 6 months after the regulations become effective. That is often a year or more after they are approved. That seems long enough.

    Notice that it also allows a smaller airline, which might only redesign its site every 4-5 years to wait to comply until it does.

    That means that full compliance might be 5-7 years out. At the speed of technology, that’s a REALLY LONG TIME>

    Making a web site accessible is old technology. WCAG 2.0 was completed in ~2006 or 2007. The Section 508 refresh advisory committee finished at about the same time. That’s already 5 years ago. There’s no excuse for more delay.

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      November 3, 2011 11:09 am

      Thanks whitneyq. Judging from your comments so far, it seems like you might have some expertise about the accessibility issues DOT is trying to tackle. Do you have a background or training in the area that would be helpful for DOT to know as it considers your comments?

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December 2, 2011 10:10 am

I know that it has been frustrating to me because I cannot access the web or websites related to airlines and when I call the airlines (it is difficult to find airline numbers because everything is so web based now). I am always told that I cannot get the same prices and options that are available on the web because I a using people to assist me with my airline reservations etc. It would be nice to see some equal access opportunities for individuals with disabilities so they would not have to incur extra charges and not be given the same opportunities that are on the web because they are not available to people who use the phone.

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    December 2, 2011 12:31 pm

    Thank you for sharing your story. These proposals would require airlines to provide web-based fares to travelers with disabilities who try to book a flight over the telephone. In your experience, do airlines follow these types of requirements correctly?

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