Draft Summary of Discussion

By the Regulation Room team based on what people have said

Websites: 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 “Websites: 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 6 users; moderators responded 7 times.

Five users described themselves as travelers and one as giving their opinion. Of the five travelers, one was also a relative/friend of a traveler with a disability and one was an airport staff person.

Three users said they had a disability, one with mobility, one with hearing and vision, and one with mobility and vision. The same three said they use assistive/adaptive technology, including: wheel chair, cane, braille, large print, optical aids, hand held computer captioned television, and screen enlargement computer software.

§3. Benefits to individuals with disabilities

Commenters with disabilities felt strongly that access was an issue of justice and fairness. One commenter, who self-identified as a traveler with a visual disability, insisted: “[T]o not consider usability when attending to these violations of federal law, we in essence lock doors of access to nearly 20 million individuals if we look at who it is that makes up the print disabled community. As a blind end user, to be precluded from independently accessing critical information to plan and arrange my travel is insulting and a violation of my civil liberties. …[W]e cannot access web sites through our computers as everyone else throughout our nation…” Another “[I]t is unfair for a site not to utilize accessible formats to assist deaf, blind, or other disabled persons to gain access to the same information as everyone else.” (These comments were made on the Websites: Accessibility standards post.)

Commenters also identified tangible costs from the current situation. Three, all of whom self-identified as travelers with disabilities (including hearing, vision, and mobility), complained strongly that airline personnel in fact do not waive the service fees for telephone reservations for people with disabilities, even though this is currently the law. [Two of these comments were made on the Websites: Accessibility standards post.] One added: “And when it comes to finding cheaper fares or less expensive alternative flight dates or times, they are no help at all. These are simple tasks for the non-disabled, but add greatly to both the cost and frustration of many disabled travelers.”

Two of these commenters pointed out that the practice of staffing customer service lines with people in other countries for whom English is not a first language imposes further costs for travelers with disabilities. One explained: “[W]e are left to make calls to reservationists, outside the US and are all too often charged a fee for using the call in desk, having to argue about the laws governing this issue, argue about why we should not and cannot be charged this fee, only to find we have in fact been charged, thereby necessitating a call to an American office rep. to ask them to reverse the charge. The simplicity and ease of making sites accessible would be cost effective and if marketed properly, open a whole market of individuals who use the computer for all aspects of their lives makes it even more difficult to get required accommodations.” (These comments were made on the Websites: Accessibility standards post.) One commenter, who self-identified as a travel agent who is blind, remarked that travelers with disabilities want “independence and not special treatment.” In addition, s/he would prefer to be able to book flights for her clients online rather than “wait on the phone for a minimum of 30 minutes .” (This comments was made on the Kiosk: Accessibility standards post.)

Finally, some commenters pointed out that accessibility requirements often benefit people other than the originally identified groups. One (self-identified as a traveler with a visual disability) called to mind the experience with building accessibility, noting that ramps and other access devices now have wider use as, for example, by parents with strollers. Another (self-identified as a traveler with visual and mobility impairments who uses a cane and needs assistance reading information on computers) pointed out that “people with cognitive disabilities have different individualized needs that may make understanding and dealing with websites difficult. These individuals can benefit from the same types of screen reading programs that benefit people who are blind because this alternative format can lend to helping them understand information more thoroughly and use information.” (These comments were made on the Websites: Accessibility standards post.)

Two individuals commented on kiosk accessibility issues; their comments are summarized at Kiosks: Benefits and costs of accessibility draft summary.

§4. Costs and benefits to industry

One commenter (self-identified as a traveler) is concerned that the regulation will be “just another burdensome cost to airlines that will be passed along to travelers. We don’t need it.” S/he also asked what existing regulation would be eliminated to offset the cost of the proposal.

Another (self-identified as a traveler with a hearing disability) agreed, calling the proposal “government overreach and interference.” S/he argued: “The benefit will never exceed costs and will drive many good companies from the web! …The economy is weak enough as is!” Another commenter (self-identified as a traveler with a visual disability) responded: “[This] is and has been a law on the books for nearly 20 years. The only issue is that is has not been effectively extended to include commercial sites. … We are talking about 20 million people [in the “print disabled” community] who would be impacted in the [United S]tates alone. We went through this same discussion decades ago when society introduced ramps and such for equal access to those in wheel chairs and other mobility devices.” S/he argued that “if built into the IT teams mission and focus [accessibility requirements] would add a minimal amount to their bottom lines.” By contrast, s/he argued, lawsuits for not being accessible could cost companies millions, pointing to the recent example of the lawsuit against Target. So the regulations would be better “both from a cost perspective and a marketing perspective.” [These last two comments were made on the Websites: Accessibility standards post.]

Finally, one commenter (self-identified as an airport staff member) said that “it is important that people have as much accessibility to all forms of interaction,” and argued that greater access to travel will allow people to “give money not only to airlines but other sectors of the economy” as well.

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