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Why would it be easier for DOT to determine compliance through random spot checks than it would be for the carrier to make a conformance claim? I think DOT underestimates what’s involved in verifying compliance, even with WCAG 2.0. DOT should wait and see what kind of guidelines the WCAG Evaluation Methodology Task Force comes up with.
If DOT assumes the cost per unit would rise if fewer accessible kiosks were needed, why assume the cost per unit would stay the same if more were needed? The point about recovering development costs should work both ways.
This exception is really important. I only have myself, my partner, and our secretary to deal with our files and there’s already a bunch of new paperwork and software requirements we’re struggling to keep up with. Unless there’s a break for small companies, this seems like it just favors big companies because they have a lot more money and resources to keep making these changes.