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Welcome to Regulation Room! The Energy Independence and Security Act of 2007, or EISA, is the federal law requiring the creation of the tire fuel efficiency information program described here. The bold text prior to “(EISA)” in paragraph 2 is a link to view the entire EISA bill.
Requiring tire manufacturers to have printouts of the ratings is an interesting idea. In the proposed rule, NHTSA specifically asked for suggestions for ensuring that consumers receive the new tire rating information.
Regarding the proposal that the NHTSA adopt an Energy-Star like system in addition to the label, would consumers understand that the Energy-Star like system refers solely to the tire’s fuel efficiency?
NHTSA is also considering whether to include a combined rating that would convert all three metrics on the above label – fuel efficiency, safety, and durability – into one overall rating. Should the agency adopt such a combined rating? Would consumers find a combined rating useful when purchasing replacement tires?
What do you think about BarbaraB’s suggestion for a dedicated internet terminal provided by tire retailers? Would an NHTSA-specific “kiosk” be useful to consumers who can’t (or don’t care to) look up tire information on their mobile devices?
You make an interesting point about the qualitative and quantitative differences in scoring. If NHTSA created a standardized metric on which all tires would be measured, some tires would receive a higher score, perhaps a 100, and other a lower score, such as 40. Would that be enough information that the first tire would serve the consumer better for fuel efficiency than the second tire, or would you prefer a more concrete quantitative approach?
Yes, there was a problem with the data being added to the survey plugin. There were 8 who responded with “yes” and one with “not sure.” We will correct these figures in the final version.
Would you find a different graph or visual representation helpful or would the stars alone suffice to give you all the information you needed to make an informed decision?
Thank you. This is a helpful suggestion. We’ll put in citations to the NPRM where we can in the final summary. Once the rule comment period closes, we’ll also talk to the agency more generally about what would be useful to them.
This comment was emailed to Regulation Room on 4/22 from the President of Morris Area Freewheelers.
Regulation Room,
Distracted driving due to cell phones can be stopped.
Making it illegal won’t stop the carnage.
Making it impossible will.
Software now exists that renders cellphones inoperable when the built-in GPS indicates the phone is moving over some threshold, e.g. 10 mph.
You can purchase and install this software now.
Legislation that forces manufacturers to make this software part of the phone’s firmware can be used to stop distracted driving.
Just look at our drunk driving laws. They are total failures.
People get killed by drunk drivers every day.
This technological problem can be totally solved by technology.
Driving while texting is DWB – Driving While Blind.. You may as well be blind.
It has already been proven that cell phone use in cars renders driver safety statistics comparable to drunk driving, regardless of whether they are doing it hands free or not.
Oops. Some people used the Site FEEDBACK button for their comments. Sorry about the confusion.
Here’s a comment left there by an unidentified participant. (If you submitted this comment and want to have it posted under your user name, contact us.)
What happens to children flying alone? The airlines require that a companion (an employee of the airline) be assigned (for a fee) to children under a certain age for the duration of their travels. How do the children just over the cut-off fend for themselves? ALL minors should have additional protections as they will not be able to stand up and be heard as an adult might. I have not heard anything about the treatment of minors. Anyone?
Thanks for your insightful comments, Msolo. What does the rest of the room think about the idea of keeping 1-2 seats unoccupied prior to flight? Should this apply to all flights?
Thanks, all, for such a spirited discussion. To those who have have experienced flight with severe peanut allergies, would having a “no nut” section of the plane comprising multiple rows help? Some commenters have drawn analogies to no-smoking sections in restaurants — would this be a viable compromise?
An interesting point has been raised: compensation for bumping a passenger may be well above the combined cost of the original ticket price and the cost of having to change travel plans. Is this an unfair boon for passengers? Should the compensation match what the passenger actually ends up spending?
This is an interesting point on the rights of volunteers to be bumped. The proposed rule has requirements for written explanations by airlines, in Section 250.9. Should this be explicitly extended to those who volunteer to be bumped? Or are these rights not enough?
Thank you for your comment – many people are concerned about the lack of clear and understandable rules on what passengers’ rights are. The proposed rule makes some changes in requiring what airlines tell passengers, at Section 250.9. Do these changes go far enough?
Thank you – your browser is working and you have posted successfully. That’s a good example of a contingency plan airports could consider.
Though the statistics on tarmac delays are through April (as posted on this site), do you think airlines should provide airport information to those purchasing tickets?
That’s a good point. It has been suggested by other participants that there be “peanut-free zones” on flights, just as there are non-smoking zones in restaurants, where the zones are to be maintained on the airplane at all times and are kept the same for every flight. Would this address the issue of residue, or would more be needed to keep passengers and flight attendants who handle peanuts out of the area?
This raises an interesting point that has been mentioned here by other commentators: even with prior notice, flight personnel often overlook those passengers with peanut allergies. Besides better training, what else could be done to make flight personnel more aware of the issue as they balance their other duties? Should notices of keeping “buffer zones” or “no peanut zones” free of peanuts be included in the routine safety announcements? Should personnel be required to check off a list of self-designated passengers with peanut allergies and make note of where they sit before in-flight service?
This raises an interesting point: should rules include the right of airlines to take off should the problem become fixed more quickly than expected? Should airlines give an estimated length of delay but require passengers to arrive at the gate half an hour or an hour before that, in case the issue is resolved quickly?
Thank you for wanting to contribute. All comments you post will be considered by the DOT. All postings under the “People’s Comments” boxes (which is where you’ve posted here) are the comments that will be considered and summarized. By posting, it does open it up for discussion by other contributors, because all comments are public as part of the rule-making process. You do not have to respond, however, or include any identifying information – all comments made on this site will be considered no matter what.
Thanks for your comment. The DOT has proposed requiring updates within 30 minutes when there are known delays. In your case, this may have helped your family. The DOT is also considering specifying the methods carriers have to use for updates, which would include weather conditions. Do you think requiring uniform standards of disclosure would help avoid the situation your family faced?
That’s an interesting point. Many major airlines seem to have the policy that for customers canceling a non-refundable ticket, the entire cost, including taxes, is applied as a credit to future ticket purchases. They will, however, include a cancellation fee (approx. $100-150). This is true for JetBlue, United, and US Airways. Do any contributors know of airlines that do not allow the cancellation of non-refundable tickets to be used as a credit like this?
@Elle: thank you for the website.
@Mulder: thank your for your comment. You seem to draw a distinction between reported food allergies and actual food allergies. Do you have any knowledge of any study or paper that draws out the importance of such a distinction in terms of public policy?
I found your point about time delays interesting. Do you think a person who needs absolute timely delivery of luggage, by informing the airline of such a need, should be treated any differently then then the person who is not terribly inconvenienced by a 2-4 hour delay?
Thank you for your comment. Do you have any suggestions for how to enforce/provide incentive for airlines to give accurate estimates? Would you for example support certain penalties?
Thank you for your comment. Should the airlines be required to ask every passenger whether they are allergic to peanuts/other allergies, or do you think it should be up to the person with the particular allergy to inform the airline ahead of time?
You make an interesting comment about the airline business model. Do you have any ideas about how airlines might treat their customers better without having to increase prices? Or do you think that simply treating customers well–along the lines you suggest–would more than make up for lost revenue by attracting more business overall?
Transferability is a good suggestion. What if there are people who know for sure that they do not want to transfer their ticket? Should the airlines have a mandatory transferability fee, which they would then refund to people who end up not transferring their ticket?
Thank you for your comment and sharing your personal experience with voucher based compensation.
Were airlines to offer monetary compensation, how do you think the compensation should be calculated or capped, given the caps that the department has in mind?
Thank you for your insightful comment and alternative suggestion. With regard to your comment on the caps, what do you think would be a better amount, in your opinion to limit overbooking, or, if as you say the auction scheme is a better alternative, how do you think the DoT should go about implementing and enforcing such a system for the airlines?
Thank you for your comment. A few other posters have also brought up the issue of forcing emergency landings in case of a reaction, but you are the first to have brought up the point that such an event effects all the passengers. Do you know of any instances or studies that might indicate how many flights are forced to land due to onboard allergic reactions?
Thank you for the input. You raise an important issue concerning the tradeoff between providing additional facilities to benefit passengers but also possibly increasing consumer costs.
Thank you for your input and for sharing a personal story of how your family was directly impacted by this issue. You raise a very interesting point concerning the effects of peanut allergies not just on those that suffer from them, but also the impact they have on families/friends. The DOT is interested in learning more about how one family member’s allergy can impact the travel plans of the entire family.
Thank you for your input. The DOT would be very interested in seeing any data that you have on the airborne risks associated with peanut consumption on commercial flights.
Thank you for your post. You are correct; much of the discussion has focused on children with peanut allergies and has neglected the impact allergies may have on adults. We certainly encourage more people to post about the impact of peanut allergies on adult airline travelers.
The comparison between non-smoking flights and peanut-free flights is an interesting one.
Beyond the fact that smoking has been showing to cause a plethora of health problems for all people, why do you that some airlines have banned smoking but not peanuts? Do you think that banning or restricting peanuts can be left to the airlines, with those airlines seeking to attract peanut-allergy sufferers, and thereby increase business, or would more direct government action be necessary, along the lines of a smoking ban?
How do you think a ban on peanuts in flight should work? Would it be a good idea to ban peanut product sales throughout the airport? If a complete ban is not feasible (in that people might bring peanut products onto the plane on their own), what other measures might the DOT take to ensure the safety of allergic passengers?
You raise an interesting point about the costs of peanut allergies. If otherwise productive members of society cannot work due to allergies, there might be more general effects on economic efficiency.
Do you, or do any of our commenters on either side of the issue have any economic data relating to lost productivity due to peanut allergies? It would be useful to the discussion and to DOT to know what the full current costs of peanuts on planes, and the benefits that may be realized by banning them.
Excellent suggestions, Darkhelmet22. The idea of automatically including certain options with a clear option to remove them is intriguing. Does anyone else have suggestions on what options should be considered “standard”?
Thank you for your comment howie. The DOT would like to see any information you may be aware of concerning the relative safety of peanut products on airplanes.
Thank you for your comments Antanagoge. The rights discussion is an important one when trying to evaluate public policy. If there are any other areas of the DOT proposal you think would benefit from a clarification of the rights issue, or the lack thereof, please comment on those issues as well.
Hi again, Antanagoge, and thanks for providing a link to that study. Is it possible to post the entire article as well, or is that unavailable? Also, while we truly appreciate your interest in the peanut allergen regulation, if you have comments on one of the other proposed regulations, I’m sure the community would appreciate hearing from you.
Thanks for your comment. There’s been quite a bit of back and forth going on regarding ADA classifications and research regarding food allergies. If you (or anyone else here) have any links to these studies, it might be worth sharing so everyone (not to mention the DOT) can dig into the data a bit more.
Thanks for the input, steyermark. The comparison to phenylketonuira (PKU) is an interesting one. Do you have any information on the prevalence of PKU that you could share with us, so that we can discuss the relationship between PKU and allergies?
Thanks for your input, mcs24. If airlines were banned from serving peanuts, do you think it would be ideal for them to advertise that fact, so as to reduce the likelihood of people bringing peanuts onto the plane?
Thanks for your input, Marge. Do you think that there should be stricter baggage fee rules, or stricter fee rules in general, for smaller markets served by one or very few regional connector airlines, because of the dependence travelers in smaller cities and rural areas have on them?
Thanks to Mulder and mcs24 for this dialogue. Is there anyone else who has an idea for a compromise between full allowance and an outright ban on peanuts?
kaukkonen thank you for your post. Do you have any suggestions as to where the DOT should draw the line in banning products that may contain peanut products?
Thank you for your post. Would the airlines disclosing pricing information on their website and requiring passengers to visit it before purchase be sufficient? or is more needed to properly disclose additional fees?
thebob, Thank you for your comment. Do you believe that a peanut free zone would be sufficient to alleviate the problem? or requiring those with allergies to disclose them prior to flight and then ban peanuts only on that flight?
Thank you for your comment. Do you believe it would be sufficient to ban peanut products on flights only when an allergy sufferer discloses this prior to flight?
Thank you for the comment JJ. What level of disclosure is sufficient? Is it enough for airlines to just display additional fee information on their website?
Thank you for your comment Andy. You have indicated that you travel often, the DOT would appreciate any information that you might have concerning the other areas of the proposed rule changes.
Thank you for your comment. One of the more difficult questions the proposed ban presents is exactly which products need to be banned, and which are safe. Would you have any further information as to which types of products pose an airborne threat? Do all products containing even small amounts of peanuts pose a risk?
Thank you for your post. As a Medical professional, if you are aware of any studies or other medical information that is available, it would be useful to the DOT.
Could you clarify how this quote helps us think about the best solution to the peanut allergy issue? The goal here is to have a discussion that will ultimately help DOT make better decisions about how to (or not to) regulate. Effective comments focus on the agency’s proposal and express concerns, suggestions, and recommendations clearly. See Effective Commenting on the Learn About Rulemaking page.
Thank you for your comment. One of the more difficult questions the DOT faces, if they decide to ban peanuts, is which products must be banned, and which are acceptable. Do you have any thoughts on this issue? Are products with only trace amounts of peanuts still dangerous?
Thanks for your comment, PracticalJo. How do you think airlines should deal with the transition period? Perhaps the airlines should be required to have their planes cleaned according to some protocol that would ensure that peanut allergens were safely removed from the plane, too?
Thanks for sharing your personal story with us, PracticalJo. Your experiences and suggestions are welcome and encouraged on other parts of the proposed rule as well.
As a reminder, the matter that you all are commenting on is a proposed rule, not a proposed bill. It will be put into force by the DOT according to its legislative mandate, following standard administrative law procedures.
Thank you for your comment bill. I take it you support a full ban on post purchase price increases. Would a less strict proposal, such as forcing airlines to disclose price increases and requiring customers to affirmatively agree to them, be sufficient? Would a partial ban on price increases preventing them 30-60 days before the flight work?
Thank you for the comment smr. If you are aware of any scientific research on the subject, the DOT is interested to know about it. Could peanut free flights or a peanut free zone be effective as an alternative to a full ban?
Thank you for your comment kerryk. You raise an interesting point that not all travelers can be treated equally. Do you, or any other posters, have any suggestions as to what can be done to better accommodate younger passengers?
Thanks for your thoughts, Ken and Joel, and welcome to Regulation Rooom. We will keep your posts in mind as we prepare our summary of the discussion on this site–come back periodically to see if we are done, and to read other users comments–you keep us honest!
In the mean time, check out the rest of the website and rule proposals. We’d love to hear your thoughts!
Thanks for your comment, jdanilson, and welcome to Regulation Room. We will keep them in mind while creating our discussion summary. In the mean time, please share your thoughts on other portions of the rule.
Thank you for your comment. This type of information would likely be useful to passengers, but collecting it may come at a cost to consumers due to increased flight costs. To what degree is this an acceptable expense?
Thank you for your comment piendmontgilr, While improving the way fees are regulated and defined is important; how should this information best be disseminated to travelers? Will display on airline providers websites be enough to let people know what services are included in the listed price and which are not?
Thank you for your comment, mithrandir. What type of action would be effective; would peanut free zones be enough? (or pet free zones) Could airlines make certain flights peanut free upon prior request, and use clean planes for those flights?
Thank you for your comment, alpet. You raise some very important concerns. The DOT is particularly interested to hear possible solutions. Should all fare increases be prohibited within 30-60 days prior to the flight? Should restrictions be placed upon the way airlines can advertise, if so how?
Thanks for your comment, Fairness. We will keep them in mind while creating our discussion summary. In the mean time, please share your thoughts on other portions of the rule.
Thank you for comment. In particular your concern over the actual mechanism to ensure a free flow of information between passengers, airlines, and travel agents. Do you have any suggestions to address this concern or any other concerns/suggestions regarding the proposed rule, in particular bundling charges?
Thank you for your comment. Please elaborate what might be adequate compensation say if you booked a flight well in advance, received confirmation, and made plan accordingly, only to have the scenario as you described occur? What, for example should be the compensation for the additional 5 hours tacked onto your original flight schedule?
Thanks for your comment, dwilson99. Do you think this should apply to just the ticket price, or to all charges and fees as well? For example, should airlines be able to charge a fuel surcharge if the price of oil skyrockets? Or perhaps they should be forced to eat the loss when that happens?
Thanks for your comment, openreels. The issue with international flights is that people let back into the airport might need to go through Customs and Immigration again. Do you think creating a special terminal zone where people could wait without having to be re-admitted by Customs and Immigration would be a viable solution, at least for international flights?
Thanks for your valuable input, sofiem. Do you have a source for your price decrease statistic? The DOT can only use publicly available data in making its decisions.
Thanks for your comment, peterell. How might airlines be required to guarantee a limit to wait times? Perhaps they should be required to keep minimum staffing levels based on the time of day, or day of the week?
Should there be any requirement on the part of the passenger to notify the airline of such a connection beforehand? Otherwise, aren’t we making the airline an insurer for someone’s business and/or leisure plans? It may be that we want to do that–but what might be the costs associated with unlimited reimbursements?
Thanks for sharing those studies with us, Buzzard. We will see that they get to the DOT. In the mean time, please feel free to share your thoughts on other parts of the rule. Your’s is just the kind of input we need.
Thank you for the comment mcheung. You bring up some interesting suggestions. What are the possible implications of these suggestions; will they disproportionately impact smaller aircarriers who only have small planes? What effect will it have on the number of flights offered during peak hours?
Thank you for your comment cochranels. You raise a good point about disclosure, many of the proposed rule changes would require additional mechanisms for disclosure of new information to consumers. How do you think this can best be done. Should airlines be required to display information about flight/fare changes only on their website? Should third party ticket sellers also be required to disclose new information to consumers?
Thank you for the comment, heyetec. You seem to have some knowledge about the relationship between airlines and local airports. The DOT is interested to know if it would be possible for tarmac contingency plans to be part of the airlines contract of service? Is this possible or are tarmac delays so uncertain that enforcing an airline wide policy simply is not practical?
Thank you for your comment, Amish. The DOT understands your position about completely banning overselling. Is it possible that increasing financial compensation to bumped passengers will be enough of a financial disincentive for airlines to fix the problem?
Thank you for the comment, kkpingle. If the DOT does change the way airlines structure their fees, what type of disclosure procedures will be needed? Is displaying fare change information on the carriers website enough?
Thank you for your comment, thetravelerman. Most consumers seem to be in favor of regulating airline pricing, but little has been said about the impact this may have on airlines/airports which will eventually carry over to effect passengers. The DOT wants to know more about these potential impacts.
Thank you for the comment. Allowing passengers to deplane without much wait time would certainly make travel more pleasant. The DOT is concerned about potential costs of such a system. For example, this may place a large financial burden on airlines/airports and lead to an increase in ticket prices. Would this be worth potentially paying more to fly?
Thank you for sharing your experiences brooke.browne. If an airline carrier is honest about the problem causing the delay and makes attempt to rectify the situation but nonetheless is unable to, what kind of compensation if any do you think would be in order. Or do you believe that a good faith effort on the part of the airline carrier is sufficient?
Thank you for your comment. Do you think additional fees should be leveraged if a passenger is bumped to a next flight that causes him or her to miss an important event/connection?
Thank you for your comment. You mentioned you do not think there should be a cap on the amount airlines should have to pay. Other than that are there any other guidelines for compensation that you would think is appropriate?
Thank you for your comment. Would you mind elaborating on any and all responsibilities the airlines might have towards passengers who choose to deplane? You mentioned it should be on the onus of the passenger to get back to the plane on time but should the airlines be also responsible for keeping passengers updated on the status of the departure time?
Thank you for your comment. You mentioned Eurocontrol – do you think a similar agency should replace the FAA in the United States or do you have other recommendations for solving some of the problems you have highlighted?
Thank you for your comment. You mentioned that all airlines should have a tarmac contingency plan. Are the there any other elements you think all such plans should have?
Thank you for the comment, FedupPAX. You raise an interesting idea of allowing airlines to use each others gates when appropriate. The logistics of this idea may be difficult to implement though.
You raise an interesting position. A number of posters have been concerned over the possibility that deplaning might increase delays for all travelers by overburdening busy airports. Anyone have thoughts on this?
Thank you for your comment. The idea that the DOT should directly determine baggage fees is an interesting one. What does everyone think about this, and – if you agree – what would be a reasonable price?
Thank you for your comment – do you think that the DOT’s proposed rules for compensation for bumping would be enough of a deterrent to airlines/remedy for passengers? Or do you think more should be done, and if so, what would you propose?
Thanks for your comment Jason and welcome to Regulation Room! You’re saying you agree that safety should be a consideration, but that this proposal will cost too much.
DOT and FMCSA are interested in hearing ideas that you and other commenters may have. Do you have suggestions for how to reduce the expected cost without sacrificing safety?
Thank you for your great comment aaron and welcome to Regulation Room! You raise a lot of good, practical points likely to get FMCSA’s attention.
You mentioned that the government could subsidize production of new trucks so that they come pre-fitted with EOBRs. Could you share more details about how you see this working? Would truck owners receive subsidies to equip old trucks as well? What do other commenters think about this proposal?
What do think of the ideas jeff raises below?
Also, aaron, maybe you have ideas about what whether FMCSA should phase in compliance by carrier size. You can read and discuss the current proposal here.
You can see the current specifications for what EOBRs must be able to do here. Do you think cell phones could handle it? If not, is there more in the specifications than FMCSA really needs?
Welcome to Regulation Room Jason and Merc! This issue post deals with DOT’s question regarding who would have to use an EOBR. Specifically, the DOT has asked whether short haul carriers (including SH HazMat carriers and SH passenger-carrying CMVs) should be required to switch to EOBRs and, if so, what the best way to implement this requirement would be? Do you have any suggestions regarding who should be covered by this proposed rule?
Thank you for your comment Merc. Is there a reason why you believe 24 hours is not enough time when the documents are all electronic as opposed to hard copy? You suggest 48 hours, is there any particular reason you believe it should be extended to this particular point?
Thank you for your comment sewest, and welcome to Regulationroom! Improving safety is one of FMCSA’s primary reasons for considering the switch to mandatory EOBR use. It seems from your other comments that you own or operate at least one truck. Do you see some type of mandatory EOBR use improving or harming safety? Any knowledge you have about how these devices would work in the real world would be very helpful for FMCSA.
Thanks for commenting on this issue as well sewest. As the owner of one truck, are there specific aspects of these new costs that concern you more than others?
Thank you for your comment, thewanderer, and welcome to Regulation Room! Because you think that three years is too long, how long do you think that the proposal should be? Do you think that all carriers should be required to comply by the same time, or should larger carriers be required to install EOBRs sooner than smaller ones?
You also raise a lot of interesting points about Hours of Service noncompliance, and FMCSA must determine whether the costs of an EOBR rule will outweigh the societal benefits. Hours of Service noncompliance and driver fatigue as they relate to costs/benefits are a part of another discussion on Regulation Room, so perhaps you would like to contribute to the discussion of “What will this cost?” (http://regulationroom.org/eobr/what-will-it-cost/#3)
Thank you for your comment, Brian! It seems like you may have some knowledge or experience in this industry. Could you explain why or how, in your opinion, requiring EOBRs could restrict drivers’ flexibility and productivity? Do you think that EOBRs should be required at all?
FMCSA has done a significant amount of cost/benefit analysis which you can find under the section “What will this cost?” on this website. Do you think FMCSA’s analysis fully addresses your concern about shipping flexibility? Can you think of better ways for FMCSA to help small trucking companies use EOBRs without undermining flexibility?
Thank you for your comment pfifreight, and welcome to Regulation Room! You raise an interesting issue about the other players who are involved in the shipping business (shippers, brokers, and dispatchers). How could FMCSA address the problems you mentioned with these players to be able to “fix the system,” as you say? Would it be best to change the hours of service rules to take these problems into account (FMCSA is actually in the process of proposing changes to the HOS rules in another proposed rule. Information about that rule can be found here)? Or would the best solution be to regulate those other players if possible? Is there another way to improve safety while also addressing your concerns?
Welcome to Regulation Room ts safety! Thank you for your helpful comment. As a safety consultant for the industry, is there any more information you could provide about the current state of HOS compliance or other safety related information? Information about small businesses would be particularly helpful since they make up 98% of the regulated trucking industry.
Jmorris, you raise an important pratical point about some of the gray areas that exist between SH and LH carriers. Would any of the options FMCSA has proposed for covering SH carriers (such as requiring all SH drivers to use EOBRs all of the time) fix the problem you see?
It sounds like you’re talking about an alternative EOBR, one that is not part of a Fleet Management System. Is that right? FMCSA is interested in collecting data about the availability and cost of EOBRs. Do you have any links that you could share with information about other devices on the market (like the XATA Turnpike)?
It sounds like you agree with another commenter, pfifreight, that truckers can only do so much under both current trucking regulations and the proposed EOBR regulations because shippers and receivers are not held more accountable for their part in the process. Is there a way to make shippers and receivers have a bigger stake in compliance to lower the burden on truckers? Are there other ways for FMCSA to lower the costs of the proposed regulation?
If these EOBRs had a broader range of features that drivers and companies could use for different purposes, do you think the companies would be more willing to foot the bill for purchasing, installing, and maintaining them? What other features do you think would make the cost worthwhile, especially for small companies?
You may also want to add your voice to the “What about Privacy concerns” section based on your comment that EOBRs are for tracking equipment and liabilities, not for tracking drivers. You can access it by clicking here.
Does anybody else know any reasons why small and large carriers should have different deadlines to comply with the rule?
You can use any EOBR you want, as long as it meets the current EOBR specifications. If the EOBR breaks, you can use the paper logbooks until it’s fixed. FMCSA’s estimates of how long each EOBR lasts are based on the Qualcom MCP-100 model. Qualcom says that its early units are still working after a decade, so FMCSA has used that to calculate costs per unit over 10 years. Is this a fair estimate? Do you know how long other models last?
Do you know drivers that already have EOBRs installed? Do they find themselves driving faster to avoid penalties?
It also sounds like you have something to say about the HOS rules themselves. FMCSA is in the process of making changes to those in another proposed rule. You can submit a comment at regulations.gov.
Thanks for your comment. As to your and gadfly12′s concern about the actual number of documents that you still need to keep, the new EOBR requirement will ease the burden for documents by eliminating the need for paper RODs, but not for other supporting documents. According to the FMCSA:
“Although the “foundation” RODS Record of duty status burden would drop dramatically, primarily due to the elimination of paper RODS, the overall supporting documents burden would not be reduced.”
Hope this clears things up. Do you think that this requirement would still be of benefit for reduced record keeping, even with the supporting documents requirement?
It seems like you agree with ts safety’s comment that EOBRs should only be required for drivers who have repeated HOS violations. Do you see any safety benefit to requiring EOBRs for more drivers? Do you think it would increase HOS compliance overall?
If you are interested in the cost/benefit analysis of the proposed regulation, you might want to check out the post.
Virgil Tatro, your poem is clever, but rulemaking isn’t about voting or just expressing your opinion. The kind of comments that really matter are those that explain exactly why the agency should or shouldn’t do something. One person with some new information or a really good idea will have more impact than 1,000 people who just give an opinion.
So, how do you make comments that count? Focus on parts of the agency proposal that will affect you directly, or that you know something about. Express your concerns and suggestions clearly. To learn more about effective commenting click here.
Could you elaborate on your view that EOBR requirements are overly costly and skewed toward the tech providers? You should head over to the What will this cost? post and let others know what you think.
Thanks for your comment, truckdrivernews. Check out FMCSA’s analysis of EOBR Device Costs to see what the agency thinks and whether you agree. You can also comment on what you think EOBRs will cost your business specifically here. Your comment will be most helpful if you draw on personal experiences or specific data.
The fatigue-related accident rate you mentioned came from slide #21 of a webinar by Ralph Craft of FMCSA. Here is what he has to say: “The NHTSA Driver Related Crash Factors are those coded by police at the at the crash scene. Everybody agrees that this number is severely under reported by law enforcement officers. FMCSA believes the real number for fatigue in large truck crashes is in the range of 10-15%. Industry groups claim the number is lower, and safety advocates believe it is higher.”
What do you think? You can read FCMSA’s analysis of fatigue-related crashes in detail here.
Gordon, The paragraph you are referring to is a quote from another commenter. We’ll double check that we’ve got the quote correct. The effort now is to make sure we accurately include everything that was raised in the comments.
Hi Cherylchevarria! Thank you for your comments. It sounds like you think travelers who use earphones have enough privacy. DOT is also considering allowing kiosks to have loudspeakers. Do you think they should? What about other users: are there additional privacy issues with loudspeakers on airport kiosks?
Do you think that making airport kiosks work basically like ATMs would be enough? One of the things DOT is considering is whether airports are different from other places where people use kiosks, they are especially concerned that airports might be too noisy. Do you think the proposed volume levels are high enough?
Hi Chandler2, welcome to Regulation Room. DOT is proposing these regulations now because it believes that inaccessible kiosks are a violation of the Air Carrier Access Act. In addition, DOT has estimated that the benefits of this proposal will outweigh the costs. You can read more about its estimates the Kiosks: Benefits and Costs of Accessibility post. Do you think that DOT has taken everything into account in its estimation?
Hi recon14193, and welcome to Regulation Room. It seems like you feel that the overall benefits, like better accessibility for people with disabilities and financial benefits to airlines, outweigh the costs. What do you think of King Slav’s comment below, that this cost is too much for airlines without enough benefit? Do you see any other benefits to airlines that might outweigh the costs?
Based on conversations with kiosk vendors, DOT estimates that the additional $750 it costs to make a Kiosk accessible is a fixed cost that will not change over time. You can read more about their estimates in Section 5.5 of the Regulatory Impact Analysis (RIA). As discussed in section 2 of this post, DOT believes that there are benefits to travelers with disabilities that can’t easily be given a dollar value. Are there other benefits to travelers with disabilities that DOT is missing?
Hello whitneyq. Since it would help to have a standard set of symbols, do you think that DOT should specify how the alphabetic keys are arranged so that the layout there is standard too?
This is an interesting suggestion, whitneyq, thanks. Could you provide a little bit more information on the guidelines, and perhaps a link to them, so that others can see what you mean? Also, what might make these better than the guidelines DOT is suggesting here?
Hello, gregory.p.care, and welcome to Regulation Room. What do you think of the standards that DOT is proposing for kiosk accessibility? Are they enough, or are they missing something?
HI jbjordan and thank you for contributing such excellent comments.
In DOT’s past rule makings, airlines pushed back hard on DOT’s cost-benefit analysis and succeeded in convincing DOT not to issue the proposed rule. From what you’ve written it looks like you have some experience in accessibility design; DOT would benefit from any input you or others might have on their cost estimates or how long it will take airlines to implement the new rules. You can comment on those issues on the Kiosk cost/benefit post and Kiosk which/when post.
Hi, joanneread, and thanks for your input about avoiding flashing lights and verbal recognition. One suggestion that DOT is considering is having kiosks equipped with a telephone-style handset attached to them. Do you think that this might be a potential work-around for travelers who have difficulty speaking loudly?
Hello again, Joanneread. The team at Regulation Room looked into your concern about needing additional assistance, and we think we’ve found something helpful. TSA, the agency in charge of airport security, maintains a list of Tips For the Screening Process for travelers who may need extra assistance. Specifically, they say “”Your companion, assistant, or family member may accompany you and assist you during a private or public screening. After providing this assistance, the companion, assistant, or family member will need to be rescreened.” Hope this helps.
Welcome to Regulation Room and thank you for your participation, rjaquiss. DOT is currently proposing that websites comply with a Level AA standard (http://www.w3.org/TR/WCAG20/#conformance-reqs). It is helpful for DOT to know why you support compliance with WCAG 2.0 AA standards (see how does effective commenting work?). Also, DOT would appreciate you sharing a story you may have on the difficulty of using travel websites that are not accessible.
Thank you for your comment, webrunner949. DOT is seeking comments on what methods should be used to monitor compliance. Do you have any suggestions for methods that should be used by outside sources to ensure that sites are compliant? Should DOT itself check for compliance?
Welcome to Regulation Room, aews175. It looks like you are addressing the proposed benefits to travelers with disabilities from kiosk accessibility, which can be discussed further at the Kiosks: Benefits and Costs of Accessibility post. It would be helpful if you told DOT specifically why the benefits they list have little impact and make specific suggestions on what could be done to make your travel experience easier.
Hi aews175. Can you explain a little more about your comment? Do you mean that you think that if DOT consults with people with disabilities and looks at currently available technologies, developing kiosk standards should be straightforward? What do you think about the standards DOT is proposing?
Welcome to Regulation Room, ntwales. It seems like you are saying that quality assistive technologies are already being displayed at conventions catered to customers with disabilities. If so, could you take look at DOT’s proposed standards for accessible airline kiosks as well and tell us if you think those meet the same quality that you are talking about?
Welcome to Regulation Room and thank you for your input, mbsimon. DOT is proposing to require airlines to make checking-in an accessible function for covered airline websites (If you’re interested, you can read the proposed rule language at http://regulationroom.org/air-travel-accessibility/agency-documents/rule-text/#382.43). But nothing specifically address the point you raise about some airlines not allowing those with tickets flagged as needing special assistance to check-in online or at a kiosk. Do you think this should be made clearer in the final regulation? Also, could you provide the names what airlines you know of that don’t let people with these flagged tickets check-in online or at kiosks? You might also be interested in commenting on the proposed kiosk accessibility standards.
Thank you for sharing your personal experience with telephone reservations, alposner, and welcome to Regulation Room. Does anyone else have personal experiences they could also share about their issues with telephone reservations or air travel websites? DOT needs to know more about what people with disabilities are experiencing when they travel.
Hi lhare, thank you for sharing your knowledge. Since you see biometric identification technologies as a potential barrier to accessibility, what do you think of jbjordan’s comment that DOT should propose accessibility regulations for biometric readers even though they aren’t widely used right now?
Do you have any suggestions for how DOT can resolve this problem? Cherylechevarria has suggested that airport kiosks should be more like ATMs. Would that help?
Hi timniles and welcome to regulation room. It sounds like you’re pointing out a problem with both kiosks and websites: that airline kiosks are not accessible and even though the information is online and available to travelers through personal mobile devices, those websites are also not accessible. Is that right?
Are you suggesting that connecting personal mobile devices, such as iPhones, to kiosks would help make the information accessible?
Thank you for your comment albertrizzi. As you may know, w3c’s WCAG 2.0 standards that DOT is proposing here are only technical standards, not performance standards (you can read an explanation of the difference in section 3 of this post). Some other commenters have suggested that DOT should require performance standards for website accessibility as well (read these comments). Do you agree or are the w3c standards enough?
Welcome to Regulation Room and thank you for your comment, wi9hf. DOT is proposing that covered websites be required to comply with WCAG 2.0 Level AA standards. The standards are intended to create websites that will work better with tools that persons with disabilities utilize such as screen readers. Do you think that it would also be better to require airlines to also provide an alternative text only site?
DOT is proposing that airlines be required to make only their primary websites accessible. Do you think airlines should be required to make all of their communications with travelers accessible?
Hi, jalexander. DOT thinks that accessible redesign may benefit people with nonvisual disabilities, but has not tried to quantify that value. What issues do you feel people with cognitive, hearing and deaf/blindness disabilities have with website accessibility? In what ways would an accessible website improve their air travel experience?
DOT is currently proposing that websites be required to conform to the WCAG 2.0 Level AA accessibility standards (http://www.w3.org/TR/WCAG20/). Do you think that these standards will not be compatible with the technology you mention? If so, what other sorts of modifications should DOT consider?
Hi jalexander. Thank you for your comments. Privacy is certainly a major concern of these regulations. Can you give us an idea of what kind of changes or guidelines would help make credit card use more private at these kiosks?
Chrisa and Jalexander, at this point the proposal is limited to interactive kiosks. However, DOT recently issued a clarification of some parts of the proposal. They explained that an “automated kiosk” is “a self-service transaction machine…available at a U.S. airport to enable customers to independently obtain flight related services.” So these regulations would cover more than just check-in kiosks, in particular it would cover self-service kiosks that are past security check-points.
Perhaps these kiosks would be able to perform the scheduling functions you asked about?
That clarification is available in several forms on the agency documents page. The relevant section is on pages 16 and 17 of the PDF.
Chrisa and Jalexander, at this point the proposal is limited to interactive kiosks. However, DOT recently issued a clarification of some parts of the proposal. They explained that an “automated kiosk” is “a self-service transaction machine…available at a U.S. airport to enable customers to independently obtain flight related services.” So these regulations would cover more than just check-in kiosks, in particular it would cover self-service kiosks that are past security check-points.
Perhaps these kiosks would be able to perform the scheduling functions you asked about?
That clarification is available in several forms on the agency documents page. The relevant section is on pages 16 and 17 of the PDF.
Thanks for your comment, bigdaddy, and welcome to Regulation Room. What types of personal mobility devices are you talking about? Could you tell us a bit more about what types of information you would like the airlines to send to these devices?
Thanks for your comment, bigdaddy. DOT has asked “Would it be valuable and feasible for DOT to require that airlines work with the disability community (by, for example, establishing a committee on website accessibility) to assist carriers in maintaining accessibility through periodic site monitoring and feedback?” in Section 3 of this post. Is this similar to what you are suggesting?
Thanks for your comment, bigdaddy. Other commenters have raised a similar point that separation may be stigmatizing for people with disabilities. Can you tell us more about the universal approach you suggested?
We’ve found that a few comments were not reflected in the summary, due to some confusion on using the site’s comment interface. We’ve fixed the problem and they will be reflected in the final version.
Welcome to Regulation Room! The Energy Independence and Security Act of 2007, or EISA, is the federal law requiring the creation of the tire fuel efficiency information program described here. The bold text prior to “(EISA)” in paragraph 2 is a link to view the entire EISA bill.
Requiring tire manufacturers to have printouts of the ratings is an interesting idea. In the proposed rule, NHTSA specifically asked for suggestions for ensuring that consumers receive the new tire rating information.
Regarding the proposal that the NHTSA adopt an Energy-Star like system in addition to the label, would consumers understand that the Energy-Star like system refers solely to the tire’s fuel efficiency?
NHTSA is also considering whether to include a combined rating that would convert all three metrics on the above label – fuel efficiency, safety, and durability – into one overall rating. Should the agency adopt such a combined rating? Would consumers find a combined rating useful when purchasing replacement tires?
It can be found here: http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=110_cong_public_laws&docid=f:publ140.110.pdf
What do you think about BarbaraB’s suggestion for a dedicated internet terminal provided by tire retailers? Would an NHTSA-specific “kiosk” be useful to consumers who can’t (or don’t care to) look up tire information on their mobile devices?
Hello NYCMuscleman18,
You make an interesting point about the qualitative and quantitative differences in scoring. If NHTSA created a standardized metric on which all tires would be measured, some tires would receive a higher score, perhaps a 100, and other a lower score, such as 40. Would that be enough information that the first tire would serve the consumer better for fuel efficiency than the second tire, or would you prefer a more concrete quantitative approach?
Moderator
Yes, there was a problem with the data being added to the survey plugin. There were 8 who responded with “yes” and one with “not sure.” We will correct these figures in the final version.
Todd,
Would you find a different graph or visual representation helpful or would the stars alone suffice to give you all the information you needed to make an informed decision?
Thank you. This is a helpful suggestion. We’ll put in citations to the NPRM where we can in the final summary. Once the rule comment period closes, we’ll also talk to the agency more generally about what would be useful to them.
This comment was emailed to Regulation Room on 4/22 from the President of Morris Area Freewheelers.
Regulation Room,
Distracted driving due to cell phones can be stopped.
Making it illegal won’t stop the carnage.
Making it impossible will.
Software now exists that renders cellphones inoperable when the built-in GPS indicates the phone is moving over some threshold, e.g. 10 mph.
You can purchase and install this software now.
Legislation that forces manufacturers to make this software part of the phone’s firmware can be used to stop distracted driving.
Just look at our drunk driving laws. They are total failures.
People get killed by drunk drivers every day.
This technological problem can be totally solved by technology.
Driving while texting is DWB – Driving While Blind.. You may as well be blind.
It has already been proven that cell phone use in cars renders driver safety statistics comparable to drunk driving, regardless of whether they are doing it hands free or not.
And the carnage continues.
Oops. Some people used the Site FEEDBACK button for their comments. Sorry about the confusion.
Here’s a comment left there by an unidentified participant. (If you submitted this comment and want to have it posted under your user name, contact us.)
What happens to children flying alone? The airlines require that a companion (an employee of the airline) be assigned (for a fee) to children under a certain age for the duration of their travels. How do the children just over the cut-off fend for themselves? ALL minors should have additional protections as they will not be able to stand up and be heard as an adult might. I have not heard anything about the treatment of minors. Anyone?
Welcome, Hgranato. You raise a unique point. Is regulating peanuts in this manner arbitrary? What do other commenters think?
Thanks for your insightful comments, Msolo. What does the rest of the room think about the idea of keeping 1-2 seats unoccupied prior to flight? Should this apply to all flights?
Thanks, all, for such a spirited discussion. To those who have have experienced flight with severe peanut allergies, would having a “no nut” section of the plane comprising multiple rows help? Some commenters have drawn analogies to no-smoking sections in restaurants — would this be a viable compromise?
An interesting point has been raised: compensation for bumping a passenger may be well above the combined cost of the original ticket price and the cost of having to change travel plans. Is this an unfair boon for passengers? Should the compensation match what the passenger actually ends up spending?
This is an interesting point on the rights of volunteers to be bumped. The proposed rule has requirements for written explanations by airlines, in Section 250.9. Should this be explicitly extended to those who volunteer to be bumped? Or are these rights not enough?
Thank you for your comment – many people are concerned about the lack of clear and understandable rules on what passengers’ rights are. The proposed rule makes some changes in requiring what airlines tell passengers, at Section 250.9. Do these changes go far enough?
Thank you – your browser is working and you have posted successfully. That’s a good example of a contingency plan airports could consider.
Though the statistics on tarmac delays are through April (as posted on this site), do you think airlines should provide airport information to those purchasing tickets?
That’s a good point. It has been suggested by other participants that there be “peanut-free zones” on flights, just as there are non-smoking zones in restaurants, where the zones are to be maintained on the airplane at all times and are kept the same for every flight. Would this address the issue of residue, or would more be needed to keep passengers and flight attendants who handle peanuts out of the area?
This raises an interesting point that has been mentioned here by other commentators: even with prior notice, flight personnel often overlook those passengers with peanut allergies. Besides better training, what else could be done to make flight personnel more aware of the issue as they balance their other duties? Should notices of keeping “buffer zones” or “no peanut zones” free of peanuts be included in the routine safety announcements? Should personnel be required to check off a list of self-designated passengers with peanut allergies and make note of where they sit before in-flight service?
This raises an interesting point: should rules include the right of airlines to take off should the problem become fixed more quickly than expected? Should airlines give an estimated length of delay but require passengers to arrive at the gate half an hour or an hour before that, in case the issue is resolved quickly?
Thank you for your comment, jmb. In case other contributors are interested, a press release summing up the Mt. Sinai study mentioned here is available at http://www.mountsinaifpa.org/about-us/news-archive/rate-of-childhood-peanut-allergies-more-than-tripled-between-1997-and-2008.
Thank you for wanting to contribute. All comments you post will be considered by the DOT. All postings under the “People’s Comments” boxes (which is where you’ve posted here) are the comments that will be considered and summarized. By posting, it does open it up for discussion by other contributors, because all comments are public as part of the rule-making process. You do not have to respond, however, or include any identifying information – all comments made on this site will be considered no matter what.
We look forward to your contribution!
Thanks for your comment. The DOT has proposed requiring updates within 30 minutes when there are known delays. In your case, this may have helped your family. The DOT is also considering specifying the methods carriers have to use for updates, which would include weather conditions. Do you think requiring uniform standards of disclosure would help avoid the situation your family faced?
That’s an interesting point. Many major airlines seem to have the policy that for customers canceling a non-refundable ticket, the entire cost, including taxes, is applied as a credit to future ticket purchases. They will, however, include a cancellation fee (approx. $100-150). This is true for JetBlue, United, and US Airways. Do any contributors know of airlines that do not allow the cancellation of non-refundable tickets to be used as a credit like this?
@Elle: thank you for the website.
@Mulder: thank your for your comment. You seem to draw a distinction between reported food allergies and actual food allergies. Do you have any knowledge of any study or paper that draws out the importance of such a distinction in terms of public policy?
I found this particular article to be interesting: http://www.justnews.com/travelgetaways/23871727/detail.html
Thank you for your comment. Do you have any other suggestions for how amenities should be presented to the consumer?
I found your point about time delays interesting. Do you think a person who needs absolute timely delivery of luggage, by informing the airline of such a need, should be treated any differently then then the person who is not terribly inconvenienced by a 2-4 hour delay?
Thank you for your comment. Do you have any suggestions for how to enforce/provide incentive for airlines to give accurate estimates? Would you for example support certain penalties?
Thank you for your comment. Should the airlines be required to ask every passenger whether they are allergic to peanuts/other allergies, or do you think it should be up to the person with the particular allergy to inform the airline ahead of time?
You make an interesting comment about the airline business model. Do you have any ideas about how airlines might treat their customers better without having to increase prices? Or do you think that simply treating customers well–along the lines you suggest–would more than make up for lost revenue by attracting more business overall?
Transferability is a good suggestion. What if there are people who know for sure that they do not want to transfer their ticket? Should the airlines have a mandatory transferability fee, which they would then refund to people who end up not transferring their ticket?
Thank you for your comment and sharing your personal experience with voucher based compensation.
Were airlines to offer monetary compensation, how do you think the compensation should be calculated or capped, given the caps that the department has in mind?
Thank you for your insightful comment and alternative suggestion. With regard to your comment on the caps, what do you think would be a better amount, in your opinion to limit overbooking, or, if as you say the auction scheme is a better alternative, how do you think the DoT should go about implementing and enforcing such a system for the airlines?
Thank you for your comment. A few other posters have also brought up the issue of forcing emergency landings in case of a reaction, but you are the first to have brought up the point that such an event effects all the passengers. Do you know of any instances or studies that might indicate how many flights are forced to land due to onboard allergic reactions?
Thanks for the comment. Do you have the specific cases or links that address this distinction?
Thank you for the input. You raise an important issue concerning the tradeoff between providing additional facilities to benefit passengers but also possibly increasing consumer costs.
Thank you for your input and for sharing a personal story of how your family was directly impacted by this issue. You raise a very interesting point concerning the effects of peanut allergies not just on those that suffer from them, but also the impact they have on families/friends. The DOT is interested in learning more about how one family member’s allergy can impact the travel plans of the entire family.
Thank you for your input. The DOT would be very interested in seeing any data that you have on the airborne risks associated with peanut consumption on commercial flights.
Thank you for your post. You are correct; much of the discussion has focused on children with peanut allergies and has neglected the impact allergies may have on adults. We certainly encourage more people to post about the impact of peanut allergies on adult airline travelers.
Thanks for your input, kateinhawaii.
The comparison between non-smoking flights and peanut-free flights is an interesting one.
Beyond the fact that smoking has been showing to cause a plethora of health problems for all people, why do you that some airlines have banned smoking but not peanuts? Do you think that banning or restricting peanuts can be left to the airlines, with those airlines seeking to attract peanut-allergy sufferers, and thereby increase business, or would more direct government action be necessary, along the lines of a smoking ban?
Thanks for sharing your experiences, AllergyDad.
How do you think a ban on peanuts in flight should work? Would it be a good idea to ban peanut product sales throughout the airport? If a complete ban is not feasible (in that people might bring peanut products onto the plane on their own), what other measures might the DOT take to ensure the safety of allergic passengers?
Thanks for your input, FoodAllergyMom.
You raise an interesting point about the costs of peanut allergies. If otherwise productive members of society cannot work due to allergies, there might be more general effects on economic efficiency.
Do you, or do any of our commenters on either side of the issue have any economic data relating to lost productivity due to peanut allergies? It would be useful to the discussion and to DOT to know what the full current costs of peanuts on planes, and the benefits that may be realized by banning them.
Excellent suggestions, Darkhelmet22. The idea of automatically including certain options with a clear option to remove them is intriguing. Does anyone else have suggestions on what options should be considered “standard”?
Thank you for your comment. The studies that you mentioned are exactly the type of information that the DOT is looking for.
Thank you for your comment howie. The DOT would like to see any information you may be aware of concerning the relative safety of peanut products on airplanes.
Any data that you might have about the prevalence or severity of peanut allergies would be useful to the DOT.
thank your for the link Antanagoge!
Thank you for your comments Antanagoge. The rights discussion is an important one when trying to evaluate public policy. If there are any other areas of the DOT proposal you think would benefit from a clarification of the rights issue, or the lack thereof, please comment on those issues as well.
Hi again, Antanagoge, and thanks for providing a link to that study. Is it possible to post the entire article as well, or is that unavailable? Also, while we truly appreciate your interest in the peanut allergen regulation, if you have comments on one of the other proposed regulations, I’m sure the community would appreciate hearing from you.
Thanks for your comment. There’s been quite a bit of back and forth going on regarding ADA classifications and research regarding food allergies. If you (or anyone else here) have any links to these studies, it might be worth sharing so everyone (not to mention the DOT) can dig into the data a bit more.
Thanks for sharing your experience. Do think the proposed changes could have helped you in that situation?
Thanks for your input. MickC. Short of suing for your baggage fee back, what might be a good enforcement mechanism for passengers to get a refund?
Thanks for the input, steyermark. The comparison to phenylketonuira (PKU) is an interesting one. Do you have any information on the prevalence of PKU that you could share with us, so that we can discuss the relationship between PKU and allergies?
Thanks for your input, mcs24. If airlines were banned from serving peanuts, do you think it would be ideal for them to advertise that fact, so as to reduce the likelihood of people bringing peanuts onto the plane?
Thanks for your input, Marge. Do you think that there should be stricter baggage fee rules, or stricter fee rules in general, for smaller markets served by one or very few regional connector airlines, because of the dependence travelers in smaller cities and rural areas have on them?
Thanks to Mulder and mcs24 for this dialogue. Is there anyone else who has an idea for a compromise between full allowance and an outright ban on peanuts?
kaukkonen thank you for your post. Do you have any suggestions as to where the DOT should draw the line in banning products that may contain peanut products?
Thank you for your post. Would the airlines disclosing pricing information on their website and requiring passengers to visit it before purchase be sufficient? or is more needed to properly disclose additional fees?
Thank you for your comment Cyberjev. Do you have any specific suggestions as to ways that education can be used to limit potential exposure?
thebob, Thank you for your comment. Do you believe that a peanut free zone would be sufficient to alleviate the problem? or requiring those with allergies to disclose them prior to flight and then ban peanuts only on that flight?
Thank you for your comment. Do you believe it would be sufficient to ban peanut products on flights only when an allergy sufferer discloses this prior to flight?
Thank you for your post midimagic. The DOT is interested in hearing alternative solutions.
Thank you for the comment JJ. What level of disclosure is sufficient? Is it enough for airlines to just display additional fee information on their website?
Thank you for your comment Andy. You have indicated that you travel often, the DOT would appreciate any information that you might have concerning the other areas of the proposed rule changes.
Thank you for your comment. One of the more difficult questions the proposed ban presents is exactly which products need to be banned, and which are safe. Would you have any further information as to which types of products pose an airborne threat? Do all products containing even small amounts of peanuts pose a risk?
Thank you for your post. As a Medical professional, if you are aware of any studies or other medical information that is available, it would be useful to the DOT.
Thank you for your detailed comment!
Thank you for your comment! Would you mind elaborating on the type of study you would require before any action is taken by the DOT on this issue?
Could you clarify how this quote helps us think about the best solution to the peanut allergy issue? The goal here is to have a discussion that will ultimately help DOT make better decisions about how to (or not to) regulate. Effective comments focus on the agency’s proposal and express concerns, suggestions, and recommendations clearly. See Effective Commenting on the Learn About Rulemaking page.
Thank you for your post. Do you have any thoughts on the specific regulatory proposals for dealing with baggage fees?
Thank you for your comment. One of the more difficult questions the DOT faces, if they decide to ban peanuts, is which products must be banned, and which are acceptable. Do you have any thoughts on this issue? Are products with only trace amounts of peanuts still dangerous?
Thank you for commenting. If you don’t mind sharing, what are you researching and to what purpose?
Thanks for your comment, PracticalJo. How do you think airlines should deal with the transition period? Perhaps the airlines should be required to have their planes cleaned according to some protocol that would ensure that peanut allergens were safely removed from the plane, too?
Thanks for sharing your personal story with us, PracticalJo. Your experiences and suggestions are welcome and encouraged on other parts of the proposed rule as well.
As a reminder, the matter that you all are commenting on is a proposed rule, not a proposed bill. It will be put into force by the DOT according to its legislative mandate, following standard administrative law procedures.
Thank you for your comment bill. I take it you support a full ban on post purchase price increases. Would a less strict proposal, such as forcing airlines to disclose price increases and requiring customers to affirmatively agree to them, be sufficient? Would a partial ban on price increases preventing them 30-60 days before the flight work?
Thank you for the comment smr. If you are aware of any scientific research on the subject, the DOT is interested to know about it. Could peanut free flights or a peanut free zone be effective as an alternative to a full ban?
Thank you for your comment. You raise an interesting issue about finding the right balance to accommodate everyone’s needs.
Thank you for your comment kerryk. You raise an interesting point that not all travelers can be treated equally. Do you, or any other posters, have any suggestions as to what can be done to better accommodate younger passengers?
Thanks for your thoughts, Ken and Joel, and welcome to Regulation Rooom. We will keep your posts in mind as we prepare our summary of the discussion on this site–come back periodically to see if we are done, and to read other users comments–you keep us honest!
In the mean time, check out the rest of the website and rule proposals. We’d love to hear your thoughts!
Thanks for your comment, jdanilson, and welcome to Regulation Room. We will keep them in mind while creating our discussion summary. In the mean time, please share your thoughts on other portions of the rule.
Thank you for your comment. This type of information would likely be useful to passengers, but collecting it may come at a cost to consumers due to increased flight costs. To what degree is this an acceptable expense?
Thank you for your comment piendmontgilr, While improving the way fees are regulated and defined is important; how should this information best be disseminated to travelers? Will display on airline providers websites be enough to let people know what services are included in the listed price and which are not?
Thank you for your comment, mithrandir. What type of action would be effective; would peanut free zones be enough? (or pet free zones) Could airlines make certain flights peanut free upon prior request, and use clean planes for those flights?
Thank you surfmaniac8. What do you think the best way to disseminate this information to the public is? Is display in the carrier’s website enough?
Thank you for your comment, alpet. You raise some very important concerns. The DOT is particularly interested to hear possible solutions. Should all fare increases be prohibited within 30-60 days prior to the flight? Should restrictions be placed upon the way airlines can advertise, if so how?
Thanks for your comment, Fairness. We will keep them in mind while creating our discussion summary. In the mean time, please share your thoughts on other portions of the rule.
Thank you for comment. In particular your concern over the actual mechanism to ensure a free flow of information between passengers, airlines, and travel agents. Do you have any suggestions to address this concern or any other concerns/suggestions regarding the proposed rule, in particular bundling charges?
Thank you for your comment. Please elaborate what might be adequate compensation say if you booked a flight well in advance, received confirmation, and made plan accordingly, only to have the scenario as you described occur? What, for example should be the compensation for the additional 5 hours tacked onto your original flight schedule?
Thanks for the heads up. We will keep that in mind.
Thanks for your comment, dwilson99. Do you think this should apply to just the ticket price, or to all charges and fees as well? For example, should airlines be able to charge a fuel surcharge if the price of oil skyrockets? Or perhaps they should be forced to eat the loss when that happens?
Thanks for your comment, openreels. The issue with international flights is that people let back into the airport might need to go through Customs and Immigration again. Do you think creating a special terminal zone where people could wait without having to be re-admitted by Customs and Immigration would be a viable solution, at least for international flights?
Thanks for sharing your concerns. How do you think the airlines might accommodate people with special medical needs during tarmac delays?
Thanks for your valuable input, sofiem. Do you have a source for your price decrease statistic? The DOT can only use publicly available data in making its decisions.
Thanks for your comment, peterell. How might airlines be required to guarantee a limit to wait times? Perhaps they should be required to keep minimum staffing levels based on the time of day, or day of the week?
Should there be any requirement on the part of the passenger to notify the airline of such a connection beforehand? Otherwise, aren’t we making the airline an insurer for someone’s business and/or leisure plans? It may be that we want to do that–but what might be the costs associated with unlimited reimbursements?
Thanks for sharing those studies with us, Buzzard. We will see that they get to the DOT. In the mean time, please feel free to share your thoughts on other parts of the rule. Your’s is just the kind of input we need.
Thank you for the comment mcheung. You bring up some interesting suggestions. What are the possible implications of these suggestions; will they disproportionately impact smaller aircarriers who only have small planes? What effect will it have on the number of flights offered during peak hours?
Thank you for your comment cochranels. You raise a good point about disclosure, many of the proposed rule changes would require additional mechanisms for disclosure of new information to consumers. How do you think this can best be done. Should airlines be required to display information about flight/fare changes only on their website? Should third party ticket sellers also be required to disclose new information to consumers?
Thank you for the comment dentedskull. You raise a good issue about passenger safety.
Thank you for the comment, heyetec. You seem to have some knowledge about the relationship between airlines and local airports. The DOT is interested to know if it would be possible for tarmac contingency plans to be part of the airlines contract of service? Is this possible or are tarmac delays so uncertain that enforcing an airline wide policy simply is not practical?
Hi Fairness; thanks for your comment! Any suggestions on how a simplified refund system might work?
Thank you for your comment, Amish. The DOT understands your position about completely banning overselling. Is it possible that increasing financial compensation to bumped passengers will be enough of a financial disincentive for airlines to fix the problem?
Thank you for the comment, kkpingle. If the DOT does change the way airlines structure their fees, what type of disclosure procedures will be needed? Is displaying fare change information on the carriers website enough?
Thank you for your comment. Would you mind elaborating on the six sigma approach? Thank you!
Should there be any other factors such as weight involved in the calculation for when if ever the airlines should charge for baggage?
Thank you for your comment, thetravelerman. Most consumers seem to be in favor of regulating airline pricing, but little has been said about the impact this may have on airlines/airports which will eventually carry over to effect passengers. The DOT wants to know more about these potential impacts.
Thank you for the comment, Karen Williams. The DOT appreciates hearing about the impact of the current system.
Thank you for the comment. Allowing passengers to deplane without much wait time would certainly make travel more pleasant. The DOT is concerned about potential costs of such a system. For example, this may place a large financial burden on airlines/airports and lead to an increase in ticket prices. Would this be worth potentially paying more to fly?
Thank you for the clarification heyetech!
Thank you for sharing your experiences brooke.browne. If an airline carrier is honest about the problem causing the delay and makes attempt to rectify the situation but nonetheless is unable to, what kind of compensation if any do you think would be in order. Or do you believe that a good faith effort on the part of the airline carrier is sufficient?
Thank you for your comment. Do you think additional fees should be leveraged if a passenger is bumped to a next flight that causes him or her to miss an important event/connection?
Thank you for your comment. You mentioned you do not think there should be a cap on the amount airlines should have to pay. Other than that are there any other guidelines for compensation that you would think is appropriate?
Thank you for your comment. Would you mind elaborating on any and all responsibilities the airlines might have towards passengers who choose to deplane? You mentioned it should be on the onus of the passenger to get back to the plane on time but should the airlines be also responsible for keeping passengers updated on the status of the departure time?
Thank you for your comment. You mentioned Eurocontrol – do you think a similar agency should replace the FAA in the United States or do you have other recommendations for solving some of the problems you have highlighted?
Thank you for your comment. You mentioned that all airlines should have a tarmac contingency plan. Are the there any other elements you think all such plans should have?
Thank you for the comment, FedupPAX. You raise an interesting idea of allowing airlines to use each others gates when appropriate. The logistics of this idea may be difficult to implement though.
You raise an interesting position. A number of posters have been concerned over the possibility that deplaning might increase delays for all travelers by overburdening busy airports. Anyone have thoughts on this?
Thank you for your comment. The idea that the DOT should directly determine baggage fees is an interesting one. What does everyone think about this, and – if you agree – what would be a reasonable price?
Thank you for your comment – do you think that the DOT’s proposed rules for compensation for bumping would be enough of a deterrent to airlines/remedy for passengers? Or do you think more should be done, and if so, what would you propose?
There is no discussion on the final summary.
Thanks for your comment Jason and welcome to Regulation Room! You’re saying you agree that safety should be a consideration, but that this proposal will cost too much.
DOT and FMCSA are interested in hearing ideas that you and other commenters may have. Do you have suggestions for how to reduce the expected cost without sacrificing safety?
It sounds like you have something to say about the proposed hours of service rule. You can tell DOT about that here: http://www.regulations.gov/#%21documentDetail;D=FMCSA-2004-19608-4095
If DOT could take care of that problem, do you think requiring EOBRs makes sense?
Thank you for your great comment aaron and welcome to Regulation Room! You raise a lot of good, practical points likely to get FMCSA’s attention.
You mentioned that the government could subsidize production of new trucks so that they come pre-fitted with EOBRs. Could you share more details about how you see this working? Would truck owners receive subsidies to equip old trucks as well? What do other commenters think about this proposal?
What do think of the ideas jeff raises below?
Also, aaron, maybe you have ideas about what whether FMCSA should phase in compliance by carrier size. You can read and discuss the current proposal here.
You can see the current specifications for what EOBRs must be able to do here. Do you think cell phones could handle it? If not, is there more in the specifications than FMCSA really needs?
Welcome to Regulation Room Jason and Merc! This issue post deals with DOT’s question regarding who would have to use an EOBR. Specifically, the DOT has asked whether short haul carriers (including SH HazMat carriers and SH passenger-carrying CMVs) should be required to switch to EOBRs and, if so, what the best way to implement this requirement would be? Do you have any suggestions regarding who should be covered by this proposed rule?
Thank you for your comment Merc. Is there a reason why you believe 24 hours is not enough time when the documents are all electronic as opposed to hard copy? You suggest 48 hours, is there any particular reason you believe it should be extended to this particular point?
Thank you for your comment sewest, and welcome to Regulationroom! Improving safety is one of FMCSA’s primary reasons for considering the switch to mandatory EOBR use. It seems from your other comments that you own or operate at least one truck. Do you see some type of mandatory EOBR use improving or harming safety? Any knowledge you have about how these devices would work in the real world would be very helpful for FMCSA.
Thanks for commenting on this issue as well sewest. As the owner of one truck, are there specific aspects of these new costs that concern you more than others?
Thank you for your comment, thewanderer, and welcome to Regulation Room! Because you think that three years is too long, how long do you think that the proposal should be? Do you think that all carriers should be required to comply by the same time, or should larger carriers be required to install EOBRs sooner than smaller ones?
You also raise a lot of interesting points about Hours of Service noncompliance, and FMCSA must determine whether the costs of an EOBR rule will outweigh the societal benefits. Hours of Service noncompliance and driver fatigue as they relate to costs/benefits are a part of another discussion on Regulation Room, so perhaps you would like to contribute to the discussion of “What will this cost?” (http://regulationroom.org/eobr/what-will-it-cost/#3)
Thank you for your comment, Brian! It seems like you may have some knowledge or experience in this industry. Could you explain why or how, in your opinion, requiring EOBRs could restrict drivers’ flexibility and productivity? Do you think that EOBRs should be required at all?
FMCSA has done a significant amount of cost/benefit analysis which you can find under the section “What will this cost?” on this website. Do you think FMCSA’s analysis fully addresses your concern about shipping flexibility? Can you think of better ways for FMCSA to help small trucking companies use EOBRs without undermining flexibility?
Thank you for your comment pfifreight, and welcome to Regulation Room! You raise an interesting issue about the other players who are involved in the shipping business (shippers, brokers, and dispatchers). How could FMCSA address the problems you mentioned with these players to be able to “fix the system,” as you say? Would it be best to change the hours of service rules to take these problems into account (FMCSA is actually in the process of proposing changes to the HOS rules in another proposed rule. Information about that rule can be found here)? Or would the best solution be to regulate those other players if possible? Is there another way to improve safety while also addressing your concerns?
Welcome to Regulation Room ts safety! Thank you for your helpful comment. As a safety consultant for the industry, is there any more information you could provide about the current state of HOS compliance or other safety related information? Information about small businesses would be particularly helpful since they make up 98% of the regulated trucking industry.
Jmorris, you raise an important pratical point about some of the gray areas that exist between SH and LH carriers. Would any of the options FMCSA has proposed for covering SH carriers (such as requiring all SH drivers to use EOBRs all of the time) fix the problem you see?
It sounds like you’re talking about an alternative EOBR, one that is not part of a Fleet Management System. Is that right? FMCSA is interested in collecting data about the availability and cost of EOBRs. Do you have any links that you could share with information about other devices on the market (like the XATA Turnpike)?
As part of a small trucking company, could you share specific details about how this would place a great burden on you?
This is a great comment with a lot of useful information that FMCSA is looking for.
What do other users think about ryanbarnett’s comment? If a logs-only EOBR were offered, would trucking companies be interested in purchasing this?
It sounds like you agree with another commenter, pfifreight, that truckers can only do so much under both current trucking regulations and the proposed EOBR regulations because shippers and receivers are not held more accountable for their part in the process. Is there a way to make shippers and receivers have a bigger stake in compliance to lower the burden on truckers? Are there other ways for FMCSA to lower the costs of the proposed regulation?
If these EOBRs had a broader range of features that drivers and companies could use for different purposes, do you think the companies would be more willing to foot the bill for purchasing, installing, and maintaining them? What other features do you think would make the cost worthwhile, especially for small companies?
You may also want to add your voice to the “What about Privacy concerns” section based on your comment that EOBRs are for tracking equipment and liabilities, not for tracking drivers. You can access it by clicking here.
Does anybody else know any reasons why small and large carriers should have different deadlines to comply with the rule?
You can use any EOBR you want, as long as it meets the current EOBR specifications. If the EOBR breaks, you can use the paper logbooks until it’s fixed. FMCSA’s estimates of how long each EOBR lasts are based on the Qualcom MCP-100 model. Qualcom says that its early units are still working after a decade, so FMCSA has used that to calculate costs per unit over 10 years. Is this a fair estimate? Do you know how long other models last?
Do you know drivers that already have EOBRs installed? Do they find themselves driving faster to avoid penalties?
It also sounds like you have something to say about the HOS rules themselves. FMCSA is in the process of making changes to those in another proposed rule. You can submit a comment at regulations.gov.
Thanks for your comment. As to your and gadfly12′s concern about the actual number of documents that you still need to keep, the new EOBR requirement will ease the burden for documents by eliminating the need for paper RODs, but not for other supporting documents. According to the FMCSA:
“Although the “foundation” RODS Record of duty status burden would drop dramatically, primarily due to the elimination of paper RODS, the overall supporting documents burden would not be reduced.”
Hope this clears things up. Do you think that this requirement would still be of benefit for reduced record keeping, even with the supporting documents requirement?
It seems like you agree with ts safety’s comment that EOBRs should only be required for drivers who have repeated HOS violations. Do you see any safety benefit to requiring EOBRs for more drivers? Do you think it would increase HOS compliance overall?
If you are interested in the cost/benefit analysis of the proposed regulation, you might want to check out the post.
Virgil Tatro, your poem is clever, but rulemaking isn’t about voting or just expressing your opinion. The kind of comments that really matter are those that explain exactly why the agency should or shouldn’t do something. One person with some new information or a really good idea will have more impact than 1,000 people who just give an opinion.
So, how do you make comments that count? Focus on parts of the agency proposal that will affect you directly, or that you know something about. Express your concerns and suggestions clearly. To learn more about effective commenting click here.
Could you elaborate on your view that EOBR requirements are overly costly and skewed toward the tech providers? You should head over to the What will this cost? post and let others know what you think.
Also, you may interested in the DOT’s proposed rule specifically dealing with HOS policies:
http://www.regulations.gov/#%21documentDetail;D=FMCSA-2004-19608-4095
That looks like a much cheaper option than the one FMCSA pointed to. Do you know if it meets the EOBR specifications?
Can you post a link to the product you mentioned so other commenters can see if it would work for them?
Thanks for your comment, truckdrivernews. Check out FMCSA’s analysis of EOBR Device Costs to see what the agency thinks and whether you agree. You can also comment on what you think EOBRs will cost your business specifically here. Your comment will be most helpful if you draw on personal experiences or specific data.
The fatigue-related accident rate you mentioned came from slide #21 of a webinar by Ralph Craft of FMCSA. Here is what he has to say: “The NHTSA Driver Related Crash Factors are those coded by police at the at the crash scene. Everybody agrees that this number is severely under reported by law enforcement officers. FMCSA believes the real number for fatigue in large truck crashes is in the range of 10-15%. Industry groups claim the number is lower, and safety advocates believe it is higher.”
What do you think? You can read FCMSA’s analysis of fatigue-related crashes in detail
here.
Gordon, The paragraph you are referring to is a quote from another commenter. We’ll double check that we’ve got the quote correct. The effort now is to make sure we accurately include everything that was raised in the comments.
Hi Cherylchevarria! Thank you for your comments. It sounds like you think travelers who use earphones have enough privacy. DOT is also considering allowing kiosks to have loudspeakers. Do you think they should? What about other users: are there additional privacy issues with loudspeakers on airport kiosks?
Do you think that making airport kiosks work basically like ATMs would be enough? One of the things DOT is considering is whether airports are different from other places where people use kiosks, they are especially concerned that airports might be too noisy. Do you think the proposed volume levels are high enough?
Hi Chandler2, welcome to Regulation Room. DOT is proposing these regulations now because it believes that inaccessible kiosks are a violation of the Air Carrier Access Act. In addition, DOT has estimated that the benefits of this proposal will outweigh the costs. You can read more about its estimates the Kiosks: Benefits and Costs of Accessibility post. Do you think that DOT has taken everything into account in its estimation?
Hi recon14193, and welcome to Regulation Room. It seems like you feel that the overall benefits, like better accessibility for people with disabilities and financial benefits to airlines, outweigh the costs. What do you think of King Slav’s comment below, that this cost is too much for airlines without enough benefit? Do you see any other benefits to airlines that might outweigh the costs?
Based on conversations with kiosk vendors, DOT estimates that the additional $750 it costs to make a Kiosk accessible is a fixed cost that will not change over time. You can read more about their estimates in Section 5.5 of the Regulatory Impact Analysis (RIA). As discussed in section 2 of this post, DOT believes that there are benefits to travelers with disabilities that can’t easily be given a dollar value. Are there other benefits to travelers with disabilities that DOT is missing?
Hello whitneyq. Since it would help to have a standard set of symbols, do you think that DOT should specify how the alphabetic keys are arranged so that the layout there is standard too?
This is an interesting suggestion, whitneyq, thanks. Could you provide a little bit more information on the guidelines, and perhaps a link to them, so that others can see what you mean? Also, what might make these better than the guidelines DOT is suggesting here?
Hello, gregory.p.care, and welcome to Regulation Room. What do you think of the standards that DOT is proposing for kiosk accessibility? Are they enough, or are they missing something?
HI jbjordan and thank you for contributing such excellent comments.
In DOT’s past rule makings, airlines pushed back hard on DOT’s cost-benefit analysis and succeeded in convincing DOT not to issue the proposed rule. From what you’ve written it looks like you have some experience in accessibility design; DOT would benefit from any input you or others might have on their cost estimates or how long it will take airlines to implement the new rules. You can comment on those issues on the Kiosk cost/benefit post and Kiosk which/when post.
Hi, joanneread, and thanks for your input about avoiding flashing lights and verbal recognition. One suggestion that DOT is considering is having kiosks equipped with a telephone-style handset attached to them. Do you think that this might be a potential work-around for travelers who have difficulty speaking loudly?
Hello again, Joanneread. The team at Regulation Room looked into your concern about needing additional assistance, and we think we’ve found something helpful. TSA, the agency in charge of airport security, maintains a list of Tips For the Screening Process for travelers who may need extra assistance. Specifically, they say “”Your companion, assistant, or family member may accompany you and assist you during a private or public screening. After providing this assistance, the companion, assistant, or family member will need to be rescreened.” Hope this helps.
Welcome to Regulation Room and thank you for your participation, rjaquiss. DOT is currently proposing that websites comply with a Level AA standard (http://www.w3.org/TR/WCAG20/#conformance-reqs). It is helpful for DOT to know why you support compliance with WCAG 2.0 AA standards (see how does effective commenting work?). Also, DOT would appreciate you sharing a story you may have on the difficulty of using travel websites that are not accessible.
Thank you for your comment, webrunner949. DOT is seeking comments on what methods should be used to monitor compliance. Do you have any suggestions for methods that should be used by outside sources to ensure that sites are compliant? Should DOT itself check for compliance?
Welcome to Regulation Room, aews175. It looks like you are addressing the proposed benefits to travelers with disabilities from kiosk accessibility, which can be discussed further at the Kiosks: Benefits and Costs of Accessibility post. It would be helpful if you told DOT specifically why the benefits they list have little impact and make specific suggestions on what could be done to make your travel experience easier.
Hi aews175. Can you explain a little more about your comment? Do you mean that you think that if DOT consults with people with disabilities and looks at currently available technologies, developing kiosk standards should be straightforward? What do you think about the standards DOT is proposing?
Welcome to Regulation Room, ntwales. It seems like you are saying that quality assistive technologies are already being displayed at conventions catered to customers with disabilities. If so, could you take look at DOT’s proposed standards for accessible airline kiosks as well and tell us if you think those meet the same quality that you are talking about?
Welcome to Regulation Room and thank you for your input, mbsimon. DOT is proposing to require airlines to make checking-in an accessible function for covered airline websites (If you’re interested, you can read the proposed rule language at http://regulationroom.org/air-travel-accessibility/agency-documents/rule-text/#382.43). But nothing specifically address the point you raise about some airlines not allowing those with tickets flagged as needing special assistance to check-in online or at a kiosk. Do you think this should be made clearer in the final regulation? Also, could you provide the names what airlines you know of that don’t let people with these flagged tickets check-in online or at kiosks? You might also be interested in commenting on the proposed kiosk accessibility standards.
Thank you for sharing your personal experience with telephone reservations, alposner, and welcome to Regulation Room. Does anyone else have personal experiences they could also share about their issues with telephone reservations or air travel websites? DOT needs to know more about what people with disabilities are experiencing when they travel.
Hi lhare, thank you for sharing your knowledge. Since you see biometric identification technologies as a potential barrier to accessibility, what do you think of jbjordan’s comment that DOT should propose accessibility regulations for biometric readers even though they aren’t widely used right now?
Do you have any suggestions for how DOT can resolve this problem? Cherylechevarria has suggested that airport kiosks should be more like ATMs. Would that help?
Hi timniles and welcome to regulation room. It sounds like you’re pointing out a problem with both kiosks and websites: that airline kiosks are not accessible and even though the information is online and available to travelers through personal mobile devices, those websites are also not accessible. Is that right?
Are you suggesting that connecting personal mobile devices, such as iPhones, to kiosks would help make the information accessible?
Thank you for your comment albertrizzi. As you may know, w3c’s WCAG 2.0 standards that DOT is proposing here are only technical standards, not performance standards (you can read an explanation of the difference in section 3 of this post). Some other commenters have suggested that DOT should require performance standards for website accessibility as well (read these comments). Do you agree or are the w3c standards enough?
Welcome to Regulation Room and thank you for your comment, wi9hf. DOT is proposing that covered websites be required to comply with WCAG 2.0 Level AA standards. The standards are intended to create websites that will work better with tools that persons with disabilities utilize such as screen readers. Do you think that it would also be better to require airlines to also provide an alternative text only site?
DOT is proposing that airlines be required to make only their primary websites accessible. Do you think airlines should be required to make all of their communications with travelers accessible?
Hi, jalexander. DOT thinks that accessible redesign may benefit people with nonvisual disabilities, but has not tried to quantify that value. What issues do you feel people with cognitive, hearing and deaf/blindness disabilities have with website accessibility? In what ways would an accessible website improve their air travel experience?
DOT is currently proposing that websites be required to conform to the WCAG 2.0 Level AA accessibility standards (http://www.w3.org/TR/WCAG20/). Do you think that these standards will not be compatible with the technology you mention? If so, what other sorts of modifications should DOT consider?
Hi jalexander. Thank you for your comments. Privacy is certainly a major concern of these regulations. Can you give us an idea of what kind of changes or guidelines would help make credit card use more private at these kiosks?
Regarding time-outs, do you think jbjordan’s suggestion would work? Do users with disabilities need more time?
Do other commenters have experience with the Amtrak kiosks? Do they work well? Should DOT consider these as a model?
Chrisa and Jalexander, at this point the proposal is limited to interactive kiosks. However, DOT recently issued a clarification of some parts of the proposal. They explained that an “automated kiosk” is “a self-service transaction machine…available at a U.S. airport to enable customers to independently obtain flight related services.” So these regulations would cover more than just check-in kiosks, in particular it would cover self-service kiosks that are past security check-points.
Perhaps these kiosks would be able to perform the scheduling functions you asked about?
That clarification is available in several forms on the agency documents page. The relevant section is on pages 16 and 17 of the PDF.
Chrisa and Jalexander, at this point the proposal is limited to interactive kiosks. However, DOT recently issued a clarification of some parts of the proposal. They explained that an “automated kiosk” is “a self-service transaction machine…available at a U.S. airport to enable customers to independently obtain flight related services.” So these regulations would cover more than just check-in kiosks, in particular it would cover self-service kiosks that are past security check-points.
Perhaps these kiosks would be able to perform the scheduling functions you asked about?
That clarification is available in several forms on the agency documents page. The relevant section is on pages 16 and 17 of the PDF.
Welcome to RegulationRoom and thank you for your comment. Do you think requiring open-captioning would be a better/easier solution?
It looks like you’re responding to the Moderator’s question to you in Section 1 of the Website Implementation Post about your experiences with booking a flight over the telephone.
Thanks for your comment, bigdaddy, and welcome to Regulation Room. What types of personal mobility devices are you talking about? Could you tell us a bit more about what types of information you would like the airlines to send to these devices?
Thanks for your comment, bigdaddy. DOT has asked “Would it be valuable and feasible for DOT to require that airlines work with the disability community (by, for example, establishing a committee on website accessibility) to assist carriers in maintaining accessibility through periodic site monitoring and feedback?” in Section 3 of this post. Is this similar to what you are suggesting?
Thanks for your comment, bigdaddy. Other commenters have raised a similar point that separation may be stigmatizing for people with disabilities. Can you tell us more about the universal approach you suggested?