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DOT should adopt a performance standard in addition to the proposed technical accessibility standards. Being able to complete transactions with not much more time required is ultimately what matters. The types and versions of assistive technologies should be those used commonly by blind consumers (in the case of this section); these are readily identifiable as those exhibiting at conventions of these blind consumers.
Regarding that DOT notes that software is now available to give people with vision impairments access to touchscreen-based technology: the recent software is useful for many users but will likely not be useful for all of them. DOT should consider testing this software with a wide range of potential users so that a proper cost-benefit analysis can be completed before making a revision to allow this software as an alternative to tactile keys.
Time-outs are an accessibility barrier. Especially when using a new kiosk, it takes additional time for other users and me to learn how to conduct a transaction. For example, Amtrak has accessible kiosks, which are very useful for printing a ticket already purchased (equivalent to just getting a boarding pass for a flight), but it may take significantly longer to complete more complex transactions (such as changing a reservation) if I hadn’t done it before.
Regarding ticket scanners (especially for use during irregular operations), DOT asked: What are the costs associated with making these accessible? DOT should also consider the benefit of reduced airline staff time serving passengers unable to use the current generation of scanners–time which can be devoted to more complicated problems during the irregular operations (such as passengers whose reservations must have the service of airline staff).
DOT should not include non-airport kiosks because some of them will have to meet both DOT accessibility standards and DOJ ADA standards anyway. This having to meet two sets of regulations, intended to achieve the same goal, is a true example of inappropriate overreach and bureaucracy which will frustrate the cause of accessibility. Alternatively, DOT and DOJ should determine which standard will apply.
DOT asks:
Should DOT require that carriers give priority kiosk access to travelers with disabilities? DOT worries that if travelers without disabilities can use accessible (as well as nonaccessible) kiosks, travelers with disabilities may wait longer than average because they need one of a limited number of machines. But reserving accessible kiosks for travelers with disabilities, or giving them priority access, could segregate and stigmatize them. What is the best resolution of this dilemma?
My response:
The best resolution would be to roll out accessible kiosks in the lines reserved for priority/elite/premium class passengers. This would best reduce disabled users’ wait times (since airlines work to make these lines short), are in a location identifiable in another way, and will ensure that disabled priority/elite/premium class passengers have access to accessible kiosks. While this will stigmatize some disabled passengers, it seems the best interim solution until the goal of 100% accessibility is achieved.
Passengers with disabilities are often already able to use the priority/elite/premium class lines today (though this is probably on more of an ad hoc, charity basis and not as a matter of right). When 100% accessibility is achieved, it is indeed my hope that passengers with disabilities would be able to use every line–and the line most appropriate to their travel just as their non-disabled fellow customers.
DOT should adopt a performance standard in addition to the proposed technical accessibility standards. Being able to complete transactions with not much more time required is ultimately what matters. The types and versions of assistive technologies should be those used commonly by blind consumers (in the case of this section); these are readily identifiable as those exhibiting at conventions of these blind consumers.
Yes, I will.
Regarding that DOT notes that software is now available to give people with vision impairments access to touchscreen-based technology: the recent software is useful for many users but will likely not be useful for all of them. DOT should consider testing this software with a wide range of potential users so that a proper cost-benefit analysis can be completed before making a revision to allow this software as an alternative to tactile keys.
Time-outs are an accessibility barrier. Especially when using a new kiosk, it takes additional time for other users and me to learn how to conduct a transaction. For example, Amtrak has accessible kiosks, which are very useful for printing a ticket already purchased (equivalent to just getting a boarding pass for a flight), but it may take significantly longer to complete more complex transactions (such as changing a reservation) if I hadn’t done it before.
Regarding ticket scanners (especially for use during irregular operations), DOT asked: What are the costs associated with making these accessible? DOT should also consider the benefit of reduced airline staff time serving passengers unable to use the current generation of scanners–time which can be devoted to more complicated problems during the irregular operations (such as passengers whose reservations must have the service of airline staff).
DOT should not include non-airport kiosks because some of them will have to meet both DOT accessibility standards and DOJ ADA standards anyway. This having to meet two sets of regulations, intended to achieve the same goal, is a true example of inappropriate overreach and bureaucracy which will frustrate the cause of accessibility. Alternatively, DOT and DOJ should determine which standard will apply.
DOT asks:
Should DOT require that carriers give priority kiosk access to travelers with disabilities? DOT worries that if travelers without disabilities can use accessible (as well as nonaccessible) kiosks, travelers with disabilities may wait longer than average because they need one of a limited number of machines. But reserving accessible kiosks for travelers with disabilities, or giving them priority access, could segregate and stigmatize them. What is the best resolution of this dilemma?
My response:
The best resolution would be to roll out accessible kiosks in the lines reserved for priority/elite/premium class passengers. This would best reduce disabled users’ wait times (since airlines work to make these lines short), are in a location identifiable in another way, and will ensure that disabled priority/elite/premium class passengers have access to accessible kiosks. While this will stigmatize some disabled passengers, it seems the best interim solution until the goal of 100% accessibility is achieved.
jbjordan’s suggestion is a good one.
Passengers with disabilities are often already able to use the priority/elite/premium class lines today (though this is probably on more of an ad hoc, charity basis and not as a matter of right). When 100% accessibility is achieved, it is indeed my hope that passengers with disabilities would be able to use every line–and the line most appropriate to their travel just as their non-disabled fellow customers.