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Regardless of which standard is used, the standard should be linked to the current published version of the technical standards. Web design trends change faster than the federal regulatory process. To avoid this problem, the regulation should have an “automatic update” provision so that the legally enforceable technical standard changes to match the most current version of WCAG or Section 508 when updates to those standards are published by W3 or the Access Board. Perhaps a grace period of six months from publication would be sufficient to allow for compliance. If it is absolutely necessary to go through the notice and comment process in order to update the legally enforceable technical standards, then DOT should automatically initiate a parallel regulatory update that adopts the new version of the standard on the day they are published by either w3 or the Access Board.
the final regulations should explicitly prohibit use of conforming alternate versions of the primary website. History has proven that separate but equal is never an effective approach to public access. As a regular user of assistive technology and several carrier websites, I have experienced situations where there were material gaps in the information and functionality on the text-only site compared with that on the carrier’s primary site.
To illustrate, I visited a carriers text-only site and noticed that the list of airports to choose from in a drop-down menu listed an airport that the carrier no longer serviced. The primary page was updated to display only the currently serviced airports but the users of the text-only page were unaware of the omitted airport. I regularly observe similar problems where the text-only pages lag behind updates made to the primary website.
I now always attempt to use the primary version of a website first because the text-only version is not often updated in a timely manner or has broken links that go unfixed for long periods of time. I suspect that the problems with the text-only sites fall below the radar because of the small population of disabled users multiplied by the unwillingness of disabled persons to spend time voicing a complaint once they have already spent a large amount of time working with an inaccessible website interface. (In my experience, I once opted to patronize a different carrier instead of wasting further time filing a complaint against the offending carrier’s text-only website). Even considering the already relatively small size of the disability community, many members of that community likely use the primary site which detracts from the number of users who are testing and providing feedback on the text-only site. Further, the carrier’s investment of resources in establishing a under-used and under-maintained text-only version detracts from making the primary website fully accessible and fully integrated.
In general, I prefer to use the main version of a webpage. Most air carriers already make a good percentage of their primary pages accessible. It wouldn’t take much more work for carriers to ensure that the remaining portions that are not accessible come into compliance with the technical standards. Moreover, I will be better able to communicate with the carrier’s website tech support team or nondisabled fellow users of the website, who are usually more familiar with the primary version of the website.
The term “website” should include all web-based forms of electronic information technology and alternative versions of the information delivered on a website. For example, would an Apple iPhone or Google Android App fall within the definition of a “website?” As many carriers are experimenting with these “web-based” alternatives or supplements to their traditional websites, it is important that disabled persons also have access to these new forms of electronic information technology. As a disabled person, I often find myself accessing proprietary apps for my favorite venders just as often as I visit their traditional websites.
Regardless of which standard is used, the standard should be linked to the current published version of the technical standards. Web design trends change faster than the federal regulatory process. To avoid this problem, the regulation should have an “automatic update” provision so that the legally enforceable technical standard changes to match the most current version of WCAG or Section 508 when updates to those standards are published by W3 or the Access Board. Perhaps a grace period of six months from publication would be sufficient to allow for compliance. If it is absolutely necessary to go through the notice and comment process in order to update the legally enforceable technical standards, then DOT should automatically initiate a parallel regulatory update that adopts the new version of the standard on the day they are published by either w3 or the Access Board.
the final regulations should explicitly prohibit use of conforming alternate versions of the primary website. History has proven that separate but equal is never an effective approach to public access. As a regular user of assistive technology and several carrier websites, I have experienced situations where there were material gaps in the information and functionality on the text-only site compared with that on the carrier’s primary site.
To illustrate, I visited a carriers text-only site and noticed that the list of airports to choose from in a drop-down menu listed an airport that the carrier no longer serviced. The primary page was updated to display only the currently serviced airports but the users of the text-only page were unaware of the omitted airport. I regularly observe similar problems where the text-only pages lag behind updates made to the primary website.
I now always attempt to use the primary version of a website first because the text-only version is not often updated in a timely manner or has broken links that go unfixed for long periods of time. I suspect that the problems with the text-only sites fall below the radar because of the small population of disabled users multiplied by the unwillingness of disabled persons to spend time voicing a complaint once they have already spent a large amount of time working with an inaccessible website interface. (In my experience, I once opted to patronize a different carrier instead of wasting further time filing a complaint against the offending carrier’s text-only website). Even considering the already relatively small size of the disability community, many members of that community likely use the primary site which detracts from the number of users who are testing and providing feedback on the text-only site. Further, the carrier’s investment of resources in establishing a under-used and under-maintained text-only version detracts from making the primary website fully accessible and fully integrated.
In general, I prefer to use the main version of a webpage. Most air carriers already make a good percentage of their primary pages accessible. It wouldn’t take much more work for carriers to ensure that the remaining portions that are not accessible come into compliance with the technical standards. Moreover, I will be better able to communicate with the carrier’s website tech support team or nondisabled fellow users of the website, who are usually more familiar with the primary version of the website.
The term “website” should include all web-based forms of electronic information technology and alternative versions of the information delivered on a website. For example, would an Apple iPhone or Google Android App fall within the definition of a “website?” As many carriers are experimenting with these “web-based” alternatives or supplements to their traditional websites, it is important that disabled persons also have access to these new forms of electronic information technology. As a disabled person, I often find myself accessing proprietary apps for my favorite venders just as often as I visit their traditional websites.