Draft Summary of Discussion

By the Regulation Room team based on what people have said

Kiosks: Benefits & costs of accessibility

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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 “Kiosks: Benefits & costs of accessibility” 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 7 comments from 5 users; moderators responded 5 times.

Four users described themselves as travelers and one as a site designer or programmer and a useability expert. Of the four travelers, one was also a relative/friend of a traveler with a disability and one was a travel agency owner or staff. One traveler said he/she had a vision and a hearing impairment and used assistive/adaptive technology, including: hearing aids, braille, large print, optical aids, a hand held closed circuit television, and screen enlargement computer software.

§3. Benefits and costs to travelers

Interestingly, there was disagreement among commenters about whether kiosk accessibility would benefit travelers.

One commenter (self-identified as a traveler with visual and hearing disabilities who uses assistive/adaptive technologies) strongly favored the website accessibility proposals but fears unanticipated negative consequences from kiosk accessibility, based on experience in other areas: “I suspect that the plan may ‘backfire,’ making airport access more difficult. Not being able to read airport signage, and therefore requiring ‘meet and assist’ assistance to my designated gate, I find it most convenient to find a ticket agent who will also call for assistance to take me through security and to my gate. If kiosks become more widely used (or possibly required) in the future, it is likely to mean fewer ticket agents, thus longer wait times on line, and more difficulty and delays acquiring the assistance I need. Making kiosks available to those disabled individuals who wish to use them may be a good idea in theory, but, as proven by the growth of ATMs and self-service checkouts, the more automation – the less human assistance!”

One commenter (self-identified as travel agency owner or staff) similarly questioned whether travelers with disabilities would rather deal with kiosks than have human assistance. S/he claims that even most travelers without disabilities hate kiosks and would rather have personal assistance. S/he proposes instead that airlines be required to have a priority lane with human assistance for disabled travelers, predicting that “this has got to be cheaper and less of a technical challenge.”

See also the Kiosks: Accessibility standards draft summary for discussion of, and reaction to, “separate by equal” proposals.

Disagreeing, another commenter (self-identified as a usability/site design expert) said “I love using the kiosks” and questioned “Why would we assume that an independent person with disabilities wouldn’t, too.” S/he also pointed out that “[y]ou don’t have to use assistive technology to benefit from an accessible kiosk. Many of us have older eyes and value larger type. … Audio can be very helpful for people who don’t read English well (but who can understand it when spoken). Easy-to-press buttons are useful when you are carrying bags.”

Finally, one commenter (self-identified as a traveler) also drew on earlier regulatory experience to oppose the proposal: “Look what requirements on tarmac delays have done – increased flight cancellations. Look at what the airlines did to find other revenues – they added exorbitant fees onto travelers if they couldn’t fit all their travel gear into a small bag. The airlines won’t pay for this requirement if it get enacted – everyone who travels will. I find it very difficult to believe that there is not a more reasonable cost way to achieve the same end goal.”

§4. Benefits and costs to airlines and airports

The commenter who self-identified as a usability/site design expert countered with a different regulatory example: “This discussion seems to assume that it is difficult or expensive to make a kiosk accessible. It is not. It may take a change in corporate processes, or in our culture. But neither the technologies or design requirements are new and novel. Amtrak, for example, has had accessible kiosks for many years as have many local train services. Airline kiosks are even easier, because they don’t have to be ‘hardened’ for outside use.” S/he questioned how, if most of the $750 per unit cost is design and development, the costs would not go down with additional units. In any event, “if they save $3.70 per passenger using a kiosk, it doesn’t take many passengers with disabilities to make up for the cost.”

However, one commenter (self-identified as a traveler) disputed this: “If this would save airlines $45.9 million in labor costs they would have already eagerly done this on their own.” For a similar comment from a different commenter, see the Kiosks: Accessibility standards draft summary.

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