Draft Summary of Discussion

By the Regulation Room team based on what people have said

Websites: Which? What content?

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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 “Websites: Which? What content?” 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 4 comments from 2 users; moderators responded twice.

One users described her/himself as a traveler and a travel agency owner or staff. The other described her/himself as a site designer or programmer, usability expert, and an air carrier staff.

§3. General summary

One commenter, who self-identified as a travel agency owner or staff, disagreed with requiring any website redesign:”The best compromise is simply to require the airlines to provide the same pricing by telephone or TTY as is available on the web, for those with disabilities. This will be a whole lot cheaper to implement and avoid a whole lot of unnecessary rework for websites.”

The second commenter, who self-identified as both airline staff member and a site designer or programmer/usability expert, criticized the proposal to regulate online ticket agents (OTAs) indirectly by holding airlines accountable for accessibility of OTAs’ websites. S/he pointed out that DOT is already regulating OTAs directly for fare advertisements (noting recent large fines imposed on Orbitz) and strongly argued that DOT should take the same direct regulation approach to accessibility. “Why would we expect airlines to face fines for content and functionality that they do not directly control?” This commenter also asked how DOT would enforce such a policy: “Sending a notice is easy. Checking for full accessibility compliance is not and is costly. Is the expectation that the airline would do more than send a notice or adjust contracts to note that the OTA site(s) should be accessible or be held accountable for any fines? Would it be the airline fined rather than the OTA if a violation of regulations was found?”

Additionally, the commenter posed a question: “Will transactional HTML emails generated by the website be included in the content that is required to be accessible?

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