ACI-NA, Airlines Find Flaws in DOT’s Kiosk Proposal

ACI-NA, working in conjunction with Airlines For America, the International Air Transport Association, and a number of other associations, on Jan. 9 filed extensive joint comments with the DOT noting a number of flaws in a proposed rule requiring airport and airline automated kiosks to be accessible to passengers with disabilities.

While many airlines use automated kiosks at airports to perform customer service functions such as automated flight check-in and printing of boarding passes and, increasingly for bag tag printing, rebooking passengers from cancelled flights, and reporting lost luggage, DOT believes that these kiosks remain largely inaccessible to passengers with vision and mobility impairments. In the comments, it is pointed out to the DOT that the accessible device it wants currently is not manufactured anywhere in the world.

While supporting a balanced approach to improve and encourage kiosk and website accessibility, the comments point out numerous flaws in the analyses, costs, benefits, and timelines DOT set forth in the proposed rule. The comments propose numerous and more flexible alternatives, less burdensome than the DOT prescriptive proposal, for providing passengers with disabilities with access to air carrier services.  The flexible approach proposed by the comments would allow continued innovations to improve the experience of all passengers, including the use of the latest technologies for passengers with disabilities.

As for automated ticketing kiosks at U.S. airports having 10,000 or more yearly enplanements, DOT is proposing that all kiosk orders initiated 60 days after the effective date of the rule must meet given standards for providing accessibility to individuals with visual, mobility, tactile, and hearing disabilities.  These proposed standards would apply to both proprietary and shared-use kiosks. For passengers who are unable to use the kiosks, DOT will continue to require carriers to provide equivalent service (e.g., permitting the passenger to go to the front of the line at the ticket counter or to provide airline personnel to assist with the kiosk).

The comment incorporates valuable and extensive information provided by the IATA Common Use Working Group on the research, redesign, and reprogramming needed to develop accessible kiosks. It is worthy of note that the IATA Group, which is composed of carrier, airport, and vendor representatives, reports that no kiosks currently exist that meet the proposed DOT kiosk standard for accessibility. The comments provide that the DOT's 60 day proposal, stated above, is unrealistic. Instead, the association's comments state that a minimum of two years after DOT establishes any accessibility standard is required for the industry to develop, test, and begin procurement of accessible kiosks. In addition, installation of accessible kiosks should be phased after this two-year period rather than requiring all procured kiosks to be accessible. The comments also oppose any retrofitting of existing kiosks as being cost prohibitive and impractical.

The comments also note serious flaws in DOT’s benefit-cost analysis including, but certainly not limited to the substantial costs of software and hardware development. As a result, the costs of DOT’s rule as proposed far outweigh the benefits.

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