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: Accessibility standards?” 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 48 comments from 16 users; moderators responded 23 times.

Twelve users described themselves as travelers. Of those twelve, one described his/her-self as also being a disability advocate, three as relatives/friends of a traveler with disability, and one as a travel agency owner or staff. One user described his/her-self as a relative/friend of a traveler with a disability, two as a site designers or programmers and useability experts (one of these two specified that were also a researcher in disabilities and universal design), and one as a being interested in the protection of the traveling public.

Nine of the users self identified as having a disability – four with mobility, four with visibility, and one with hearing. All nine said they used assistive/adaptive technology, including: wheel chair, cane, walker, captioning, videophone, screen magnifier, screen reader, braille printer, book reader, text-to-speech software, and large print.

§3. Necessity/desirability of kiosk accessibility standards

One commenter expressed uncertainty about whether “DOT and DOJ are the best people to propose such a standard.” Another commenter (travel agent who is blind) replied. S/he spoke from personal experience about the necessity of regulations for airport kiosks and websites due to a growing number of individuals who are blind, whether by birth, disease, accidents, or from being veterans. S/he is a member of the National Federation of the Blind (NFB), which has had accessibility cases against airports dismissed because the “ADA doesn’t have any jurisdiction at the airports or the websites in this matter.”

One commenter (travel agency owner or staff) spoke out against “revamping all the kiosks,” suggesting instead a “priority lane” where travelers with disabilities could get “personal assisted service.” (A similar comment from this commenter appears in the Kiosks: Costs & Benefits draft summary.) The commenter (travel agent who is blind) responded that travelers with disabilities want “independence and not special treatment.” Another commenter (traveler and someone with a friend or relative who has a disability) agreed that “[s]egregating people with disabilities into a separate line is … stigmatizing,” and explained that people with disabilities are “normal people” who want “equal treatment” not “special treatment.”

One commenter (traveler) suggested that this was an example of “government trying to implement an inefficient and costly requirement.” S/he further predicted that the airlines will not absorb the cost of complying with this regulation and would pass it on to “everyone who travels.” Finally, this commenter found it “very difficult to believe” that there wasn’t an alternative with a “more reasonable” cost. The commenter (travel agent who is blind) disagreed, stating “if someone cannot use something that everyone else can, that is downright discrimination.” Another reiterated the importance of independence: “disabled people would benefit greatly from air travel accessibility kiosks in that in the growing age of computers, people would not be needed for their special assistance.” [This comment was made on the Website: Benefits and Costs post.]

Another commenter (traveler) suggested that there should not be “government regulations” on kiosk accessibility, because airline industry competition would “create similar accessibility standards” if they were cost efficient. (See the Kiosks: Costs and benefits draft summary for a similar comment from another commenter.) This commenter also suggested that “there needs to be a cost-benefit analysis” to “determine if the benefit is really worth the cost;” s/he did not respond to the moderator’s question about whether s/he considered the cost analysis done by DOT adequate.

§4. Other standards

Four commenters suggested that DOT should consider other standards and technologies to create guidelines for airport kiosks.

One (site designer or programmer/usability expert) suggested DOT consider incorporating parts of the Election Assistance Commission’s Voluntary Voting System Guidelines (VVSG) (particularly chapter 3) because they “specifically address[] kiosk-type systems” without requiring use of “personal assistive technology.” S/he included a link to the VVSG and explained that these standards “draw[] on 508 and WCAG along with AADAG.” A second commenter (traveler with visual and mobility disabilities) concurred.

Another (travel agent who is blind) pointed out that people who are blind have been using ATMs “for a very long time” and that many accessibility features of ATMs have already been established. Discussing DOT’s questions regarding volume controls, this commenter pointed to ATMs and said, “[t]his is basically standard stuff.”

On the other hand, see the next section for the reservations of one commenter (researcher in disabilities and universal design) about whether ATM standards are completely appropriate for kiosks.

Another commenter (person with a mobility impairment who uses a wheelchair) was optimistic that “a review of currently available technology and the experience of people with disabilities in its use, should be helpful in developing kiosks that can be adequately used by most people with most disabilities. I don’t see why most kiosks can’t be accessible by the time the rules are effective.”

§5. Specific aspects of proposed standards

Several commenters had reactions and suggestions to specific elements of the proposed kiosk standard. One commenter in particular (researcher in disabilities and universal design) made multiple detailed comments. These are summarized in the sections that follow.

At the same time, a recurring theme of commenters who self-identified as having disabilities was that DOT should consult with, and test proposed standards on, individuals with disabilities. (One noted that such testing is needed to accurately assess costs and benefits.)

§6. Auditory output; privacy

Commenters are concerned about sensitive information being handled by airport kiosks and some had suggestions for how to maximize traveler privacy.

The commenter (travel agent who is blind) explained that travelers with disabilities resolve this issue by carrying earphones and plugging them into kiosks that have “standard sockets.” S/he also suggested that the community of people with disabilities “know[s] what is out there that we can use, and how to do it to protect privacy” — the “only thing these businesses have to do is ask.”

A commenter (researcher in disabilities and universal design) addressed this issue in depth: “Because financial transactions are being conducted on such kiosks, a private listening option must be provided through an industry-standard headset connector. A headset/headphone jack is better than a handset, because people may not have two hands free to simultaneously hold the handset and operate the device (for example, because they are holding luggage or have a physical limitation). In addition, a headset jack is required to allow users to connect their own neckloops or other hearing technologies to the device besides just headphones. Because different headphones and other hearing technologies will result in different volumes when plugged in, a volume control must be also be provided. Headphone jacks are typically the most inexpensive option available for providing sound. Computers inside a kiosk typically have audio output capability, so only a wire and jack mounted on the housing needs to be installed. Installing a speaker for use in public locations typically requires installation of speakers and an audio amplifier.”

S/he added: “It is possible to wirelessly pair a Bluetooth headset or headphones to a device to provide audio to the user. The biggest problem with Bluetooth audio is that a user must pair the device. Typically there are pairing settings in a visual menu on a Bluetooth enabled device, but a person who is blind cannot see to make the pairing and they cannot yet hear because the Bluetooth headset is not yet paired! Also, Bluetooth is likely of limited utility because not everyone who might use such wireless headsets at a kiosk owns a wireless headset or has them available when they need them. Today, a headphone jack is a better choice to use because more people carry around personal headphones for private listening. Airlines buy inexpensive headphones in bulk and could potentially make them available to customers who need them for the kiosk. Thus, Bluetooth could be provided but it would have to be in addition to a headphone jack, not instead of one.”

One commenter (traveler who has mobility and visual disabilities) specifically asked for design specifications that protect privacy for travelers with visual disabilities to use credit cards: “I have had to use strangers to help me put in credit cards etc. when using a kiosk and this is very concerning to me. I am hopeful that when designing a new kiosk system there would be some privacy guidelines and/or shell so that a person can put in there ID and Credit Card for charges without having to be totally in the open.” See the next section for this commenter’s discussion of the needed tactile signaling.

§7. Volume control

Two commenters addressed the importance of volume control specifications.

The travel agent who is blind wrote that ATMs and other machines have up/down controls for volume, and that “[t]his is basically standard stuff.”

The researcher in disabilities and universal design addressed the issue in detail: “It is important that a system have volume control for all forms of audio output. This includes both the standard output and any assistive audio output. People plugging in headphones or hearing technologies into headphone jacks need to have control over the audio because the volumes vary widely for different headphones. What might be a fine volume for one person with one set of headphones might be painfully loud to another person with a different set of headphones. With speakers, the user may need to adjust the volume to account for ambient noise or their own ability to hear.”

S/he warned, however: “Note that specifying an absolute volume level for headphones cannot be done because of differences between headphones. The audio signal should be provided at a standard output level for the jack with volume control. People who need significant amplification beyond what is usually provided at the audio jack of a computer or kiosk may carry a personal audio amplifier or amplified headphones. It is important that the method of changing the volume does not require the person to initially hear the audio. For example, a person who is blind and has difficulty hearing at the default level would not be able to adjust the volume if the only means for doing so were to navigate through audio menus on the system. Finally, since some users who are hard of hearing may set the volume very high, it is important that the volume be reset after each user.”

§8. Tactile symbols

Commenters strongly supported a requirement for “tactile symbols” on kiosks.

The commenter site designer or programmer/usability expert said, “I applaud the inclusion of a standard set of symbols for common functions. Unlike a personal computer, we use many different airlines. It will help if they all have the same tactile symbols.”

The commenter researcher in disabilities and universal design said, “Tactile controls that meet the specifications in Section 508 [36 CFR 1194.23(k) & .25(c)] are good to include. Having tactilely discernible controls is good for people who must explore the device and find controls by touch. It is necessary to be able to find the controls without activating them or surrounding controls by simply touching them. Similarly, providing the status of toggle/locking controls audibly or tactilely is good for people who cannot see so that they can determine the status. It is best if they do not need to change the status in order to discover it; however, since it is easily reversed, this is not necessary.”

At the same time, s/he cautioned: “The tactile markings are taken from the ADA Accessibility Guidelines for ATM keys on a numeric keypad. Those exact markings should not be required for *all* other types of keypads, keyboards, or controls because they are not appropriate in all circumstances–for example, the Enter key on a keyboard is discernible by location and size (and shape in many cases) and should not be required to also have a raised circular tactile icon on it. As another example, a different device with right and left keys for navigation might be marked with raised right and left arrows, which would conflict with the Clear/Correct labeling of ATMs. It might be best for the ATM conventions to apply if an ATM-like interface and keypad is used, but it is too limiting for other circumstances and approaches to making kiosks accessible.”

With respect to keypad & keyboard arrangement, this commenter emphasized: “Numeric keys on a physical, hardware input device must be available in a standard arrangement for people who touch type and cannot see. Number keys may be provided in a 3×4 numeric keypad in (1) an ascending (telephone-style) or (2) descending (10-key computer style) arrangement of keys or (3) in a line at the top of a touch-type-able QWERTY keyboard. These three arrangements are common and recognized by users. It would be good to specify a QWERTY arrangement for physical, hardware keyboards on which users can touch type if they are included on kiosk. Many people who are blind can touch type.”

The commenter who expressed concern about privacy of inputting credit cards made a plea for clear tactile signals: “As a person with a visual and mobility disability I find it difficult to use kiosks because it is very hard to put in credit cards etc. because there is no guide (something tactile to put my credit card in before it is loaded). I know that most airlines are going to a kiosk only check in and no human person to assist and it is frustrating because I can’t see or feel where to put in information and/or get information out such as boarding passes etc.”

§9. Touchscreens

Commenters were concerned about how touchscreen technology would be treated.

One commenter (traveler with a visual disability) warned: “Not all blind people are knowledgeable about operating touch screens. The learning curve is too steep for the airline check-in process.” S/he believes that “a keypad with distinct keys as described on this page for ATMs or mass transit ticket machines is much more readily accessible.”

Another (traveler with a visual disability) addressed DOT’s statement about software being available to help people with visual disabilities use touchscreens. S/he warned that “the recent software is useful for many users but will likely not be useful for all of them.” S/he urged that “DOT should consider testing this software with a wide range of potential users so that a proper cost-benefit analysis can be completed before making a revision to allow this software as an alternative to tactile keys.”

The researcher in disabilities and universal design agreed that having a touchscreen only design is problematic and suggested an additional design specification for the new regulation: “Some people cannot easily use a touchscreen or other controls if that touchscreen requires body or skin contact. For example, a person with prosthetic hands would not be able to use a capacitive touchscreen. While it would be preferable if they could use the touchscreen directly, the person should at least be able to use alternative controls to access the device. A new provision might read: ‘Usable without body contact. A least one mode of operation for all functionality shall be provided that does not require body contact or close contact.’”

§10. Timed response/timeouts

One commenter (traveler with a visual disability) emphasized: “Time-outs are an accessibility barrier. Especially when using a new kiosk, it takes additional time for other users and me to learn how to conduct a transaction. For example, Amtrak has accessible kiosks, which are very useful for printing a ticket already purchased (equivalent to just getting a boarding pass for a flight), but it may take significantly longer to complete more complex transactions (such as changing a reservation) if I hadn’t done it before.”

The researcher in disabilities and universal design agreed: “Timeouts that cannot be extended present an accessibility barrier to people who cannot see and who must slowly navigate through items on the screen and then listen to them. Timeouts are also an accessibility barrier to people who have slow movement, those who need to plan movement in advance, those who need time to digest information they had just heard or read, and to people who may lock up or freeze when they realize they are under a perceived short deadline to get something done.”

S/he suggested: “Certainly, unattended kiosks often need to have an inactivity timeout that resets the kiosk if the user leaves in the middle of a transaction. However, a kiosk can have short timeouts and still provide sufficient time for those who need it. It can also have short timeouts and still provide sufficient warning for people who need to request more time but cannot respond quickly. Because some people cannot respond quickly, the length of time available for the user to request more time should be specified in the DOT guidelines. To harmonize with other standards, a value of 20 sec. should be used (starting after the message is provided and read). For example, if the kiosk is required to reset after 45 seconds of inactivity, the person could be warned after 25 seconds with a displayed and audio message and then have 20 more seconds to respond.”

§11. Flashing lights speech recognition

The researcher in disabilities and universal design suggested a design specification for protecting travelers with epilepsy: “People with photosensitive epilepsy may have seizures if there is fast, bright flashing from lights or a display. As an easy rule of thumb, fewer than three flashes per second is generally considered safe. Flashing faster than that rate may be safe, but depends on the intensity and size of the flashing area. The web content accessibility guidelines (WCAG 2) has a standard for flashing that is useful.”

§12. Speech recognition

Commenters had concerns about the possibility that accessible kiosks could require speech recognition.

The researcher in disabilities and universal design explianed: “Some people cannot speak clearly enough or at all to use speech recognition systems. For example, a speech recognition system may be unable to understand the speech of a person who became deaf early in life. While speech recognition is not generally included as an option in today’s kiosks it is technology that is being used more widely in consumer electronics now, and a provision should be added to future-proof the legislation.” S/he suggested possible language for the final rule: “Usable without speech. At least one mode of operation for all functionality shall be provided that does not require user speech.”

Agreeing with these concerns, another commenter (traveler with mobility and speech disabilities) explained that s/he has epilepsy, so not only are “flashing lights out of the question,” but s/he “also cannot speak loudly or clearly enough due to an implant to control [his/her] seizures.” Therefore, speech recognition would be useless.

§13. Biometric input

The researcher in disabilities and universal design stated that “A biometrics provision like this is very important to include preemptively so that equivalent provisions do not need to be added later if/when biometrics become more widely used. Retrofitting a kiosk later to include a biometric alternative would certainly be very expensive. This gives vendors and airlines clear guidelines for biometrics and allows them to calculate the cost of inclusion.”

Another commenter (traveler with a visual disability) agreed saying, “Designing a feature to be accessible from the ground up is cheaper and takes less work than retrofitting.” S/he worried that a failure to preemptively establish standards would lead to biometric systems that were not accessible without further regulation, leading to a “burdensome process for people who cannot use the technology.” “People with disabilities are often left behind with technology upgrades and putting regulations into effect now would prevent that.” Additionally, s/he pointed out that “[i]f equipment manufactures know the rules before they design technologies, they can incorporate it.”

The researcher in disabilities and universal design also suggested that “[h]aving two biometric identification or control systems is usable by more people than only having one. However, there are some people, such as some veterans, who might have difficulty with both a fingerprint and iris scanner for example. A system with a non-biometric alternative would be usable by more people than a two-biometric system.”

The same commenter who agreed with the need to preemptively establish guidelines for biometrics agreed: “It is essential to have multiple methods of biometric identification. Eye disease can prevent adequate imaging of the iris or retina, or an inability to hold the eye still.”

§14. Contrast ratio

The researcher in disabilities and universal design urged that the final rule contain a specification for contrast ratio on the kiosk screen borrowed from the same standards being proposed for website accessibility: “A value for the contrast ratio between text and its background should be specified so that designers have guidance about how much contrast is necessary. In order to harmonize with other standards, a value of 3:1 should be used (using the formula in the web content accessibility guidelines (WCAG 2). For enhanced contrast, a ratio of 1:4.5 or even of 1:7 might be specified.”

§15. Captioning; coordinating speech and visual outputs

The researcher in disabilities and universal design emphasized the broader value of captioning: “The captioning provision is a good provision and should be kept. Besides being helpful to travelers who cannot hear well, captions are helpful for all people when the airport environment is too loud. It also helps those travelers for whom English is a second language because they can both read and listen.”

Another commenter (disability advocate with a hearing disability) suggested, “If closed-captioned, the trigger (whether icon, button, key, etc.) to activate captions should be clearly visible and easy to find. Perhaps a standardized location.”

The researcher in disabilities and universal design also strongly supported coordinating visual and speech outputs: “It is very good that the provision requires that the speech output be coordinated with visual output for the [reasons given in the NPRM]. It should also be noted that many people who are legally blind can see, and the visual display can be helpful for them even if the text is too small to be read. A headphone jack would be better than a handset because a person might not be able to use two hands (e.g., holding luggage or because of disability) to both control the device and hold the handset.”

However, s/he suggests a terminology change to avoid confusion: “The provision references being ‘speech enabled.’ People reading the provision may initially assume the phrase means ‘speech recognition,’ because of increasing consumer familiarity with that technology. Instead, the phrase ‘speech output’ should be used because it is more accurate.”

§16. Physical standards: Height; clear floor space

The researcher in disabilities and universal design suggested a specific wording change to the proposed standard: “This is a useful provision for people in wheelchairs and people with short stature. The intent of the provision is that people can read the display from a point 40 inches high, not simply view it. Revising the provision slightly, using the word ‘readable’ instead of ’visible’ would make the intent clear.”

§17. Other problems faced by travelers with disabilities

One commenter (traveler with a visual disability who uses a screen reader) urged DOT to consider the need for “more mobile and hands on devices to provide access to information at the kiosk and information boards. Possible links to i phones to list current information or EM alerts. At present screen readers are not workable on weblinks and the touch screens at data terminals are not usable.”

Two commenters (traveler with mobility and vision disabilities and friend or relative of a traveler with a disability who also has mobility and speech disabilities his/her-self) expressed frustration that airport schedule signage is also not accessible and is not covered by this proposed rule. The traveler with mobility and vision disabilities explained: “I am wondering if there would be a way of auditorily accessing information on the display screens (that are high above and give information about whether or not flights are on time and when they will be flying). At this time it is very frustrating because even if you are at a gate and knew the initial departure of your plane the gate display does not necessarily tell you about changes to that departure time or to the gate. I have run into situations where the gate and departure times have changed and because there was not human interaction it was hard to dealing with the situation. I also have a mobility disability and need airport assistance to get from check in to the gate and had no way to access airport assistance if my gate changed. The people that provide assistance with getting me wheelchair assistance from gate to gate were not available if there were changes. This is probably due to the lack of personnel as well as hardships relating to trying to keep track of people who need assistance and when they need assistance.”

Finally, a commenter (traveler with a mobility disability who uses a wheel chair) wrote about a proposed benefit from kiosk accessibility, which belonged on the Kiosks: Benefits and Costs of Accessibility post. The commenter said, “[T]he more that I can manage my whole travel experience without a lot of interaction with staff, the more seamless my trip will be. At present, I try to do as much as possible online, but once at the airport I still need to negotiate red caps, security personnel, gate check-in personnel, luggage handlers and flight attendants, many of whom still do not have a clear idea of how to interact with people with disabilities. The kiosks will make little impact on this.” [This comment was made on the Website: Benefits and Costs post.]

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