The commenting period for the proposed rule has ended. You can view the final summary.

§1. What’s Going on Here?

This is a summary of discussion on the “Kiosks: Which? When?” post between September 29, 2011 and January 3, 2012. (On that date, the post was closed to further discussion.) This summary was written by the Regulation Room team based on all the comments people made. This version is a DRAFT. We need YOUR help to make sure that nothing is missing, wrong, or unclear.

Important dates:

January 3-8: Comments can be made here on the draft
January 9: Final Summary of Discussion is posted on Regulation Room and submitted to DOT as a formal comment in the official rulemaking record. (January 9 is the last day of the official commenting period.)

Things to keep in mind as you read through the draft summary and make comments:

The goal here is to give DOT the best possible picture of all the different views, concerns, and ideas that came out during the discussion. This is NOT the place to reargue your position or criticize a different one. Focus on whether anything is missing or unclear, not whether you agree or disagree.

Rulemaking is not a vote. DOT is not allowed to decide what to do based on majority rule. (Why? See Effective Commenting) Approximate numbers are provided in the summary to give DOT a sense of the frequency of views, concerns, and ideas.

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§2. Who Participated?

This post received 9 comments from 4 users; moderators responded 6 times. All users described themselves as travelers. Additionally, two are relatives or friends of a traveler with a disability and one is a disability advocate. All four users said they have a disability: two had vision, one mobility and one hearing. All four said they used assistive/adaptive technology, including: wheel chair, computer screen reader, braille printer, book reader, text to-speech software, captioning, and videophone.

§3. Proposal to include ticket scanners beyond security

Responding to the question (raised in DOT’s November 21, 2011 notice) about the costs of including ticket scanners behind security checkpoints, a commenter who self-identified as a traveler with a visual disability who uses text-to-speech software, suggested that DOT should consider the benefits of reduced airline staff time serving passengers unable to use the current generation of scanner. This time could then “be devoted to more complicated problems during the irregular operations (such as passengers whose reservations must have the service of airline staff).”

§4. Non-Airport Kiosks

With respect to including kiosks outside airports, comment was mixed.

One commenter (self-identified as a traveler and with a visual disability who uses a screen reader, braille printer, and book reader) favored inclusion. Pointing out that the Americans with Disabilities Act permits a person with a disability who is unable to drive a car to request a driver for a rental car, s/he explained: “If I were paying for a rental car or conducting some other transaction …I would need the privacy of an accessible kiosk.”

However, two other commenters, although otherwise supportive of kiosk accessibility, believe that the burdens of regulatory overlap will create more harm than good if non-airport kiosks are included. One (self- identified as a traveler with a visual disability who uses text-to-speech software) wrote: “This having to meet two sets of regulations, intended to achieve the same goal, is a true example of inappropriate overreach and bureaucracy which will frustrate the cause of accessibility. Alternatively, DOT and DOJ should determine which standard will apply.” Another (self-identified as a disability advocate who has a hearing disability and who uses captioning and videophone), suggested that “If DOJ’s ADA regulations already apply to existing kiosks, DOT should simply enforce DOJ’s regs rather than making a different set of regs with different standards” — unless “there is something about the environment/procedures that makes current DOJ standards inadequate.”

§5. New kiosks; retrofits; interim approach

One commenter, who self-identified as a traveler with a mobility impairment who uses a wheel chair, argued strongly that all new kiosks, as well as all retrofits, should “should be based on universal principles, usability features and 508.” S/he added that in practice, “separate is not equal.”

Another commenter (self-identified as a traveler with a visual impairment who uses a screen reader, braille printer, and book reader) is concerned about having fewer than all kiosks accessible: “If only some kiosks are accessible, how will a blind customer entering the airport or waiting in line know where to find them? Currently the airlines have used kiosks to replace personnel. When I arrive at airports, I often have a great deal of difficulty, and waste a lot of time, finding a person to help me check in. Passengers who require assistance to get to the gate need to check in with a person who can arrange this help, not at a kiosk.”

Another commenter (self-identified as a traveler with a visual disability who uses text-to-speech software) suggests that, initially, DOT should require the accessible kiosks to be placed in the lines reserved for priority/elite/premium class passengers. “This would best reduce disabled users’ wait times (since airlines work to make these lines short), are in a location identifiable in another way, and will ensure that disabled priority/elite/premium class passengers have access to accessible kiosks. While this will stigmatize some disabled passengers, it seems the best interim solution until the goal of 100% accessibility is achieved.” In response to the moderator’s question whether travelers with disabilities are already able to use the priority/elite/premium lines, the commenter explained: “Passengers with disabilities are often already able to use the priority/elite/premium class lines today (though this is probably on more of an ad hoc, charity basis and not as a matter of right). When 100% accessibility is achieved, it is indeed my hope that passengers with disabilities would be able to use every line–and the line most appropriate to their travel just as their non-disabled fellow customers.”

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