Preliminary Regulatory Analysis

ACAA SNPRM

Accessible Kiosks and Web Sites

Contract No.:

GS-10F-0269K

Order No.:

DTOS59-09-F-10094

Project No.:

1030-000

Submitted To:

Office of the Assistant General Counsel

Aviation Enforcement and Proceedings

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building

Washington, DC 20590-0001

Submitted By:

Econometrica, Inc.

4416 East-West Highway

Suite 215

Bethesda, Maryland 20814

September 7, 2011
ACAA SNPRM Regulatory Analysis: Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

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Table of Contents

Executive Summary...................................................................................................................... 1

Introduction................................................................................................................................... 3

1. Guarantees of Equal Access for Persons with Disabilities.................................................. 4

1.1. Air Carrier Access Act (ACAA).......................................................................................... 4

1.2. Section 707 of the ADA Accessibility Guidelines .............................................................. 5

1.3. Section 508........................................................................................................................... 5

1.4. Website Accessibility Initiative (WAI) ............................................................................... 6

2. Disabled Passengers Requiring Accommodation in Air Travel ......................................... 6

2.1. Extent and Severity of Disabilities in the U.S. Population.................................................. 7

2.2. Use of Electronic Technologies by People with Disabilities............................................... 9

2.3. Travel Behavior of People with Disabilities...................................................................... 11

3. An Overview of the Air Transportation Sector and Current Regulatory Structure ..... 12

3.1. Flights and Passengers....................................................................................................... 13

3.2. U.S. and Foreign Air Carriers............................................................................................ 13

3.3. Airports.............................................................................................................................. 16

3.4. Travel Agencies and Tour Operators................................................................................. 16

3.5. Regulatory Authorities....................................................................................................... 17

4. General Framework for Analysis of Benefits and Costs................................................... 18

4.1. Nature of Benefits Anticipated .......................................................................................... 18

4.2. Types of Compliance Costs Incurred................................................................................. 19

4.3. General Assumptions Used to Estimate Benefits and Costs.............................................. 20

4.4. Components of the Requirement-Specific Evaluations..................................................... 21

5. Evaluation of Proposed Requirements for Accessible Kiosks.......................................... 21

5.1. Current Industry Practices and the Need for Regulatory Requirements............................ 21

5.2. Proposed Requirements to Address Identified Needs........................................................ 23

5.3. Compliance Scenarios Evaluated....................................................................................... 25

5.4. Estimated Benefits of Proposed Requirements.................................................................. 26

5.5. Estimated Costs of Proposed Requirements...................................................................... 30

5.6. Estimated Net Benefits and Discussion of Preliminary Results........................................ 33

6. Evaluation of Proposed Requirements for Accessible Web Sites..................................... 35

6.1. Current Industry Practices and the Need for Regulatory Requirements............................ 35

6.2. Proposed Requirements for Addressing Identified Needs................................................. 38

6.3. Compliance Scenarios Evaluated....................................................................................... 39

6.4. Estimated Benefits of Proposed Requirements.................................................................. 41

6.5. Estimated Costs of Proposed Requirements...................................................................... 49

6.6. Estimated Net Benefits and Discussion of Preliminary Results........................................ 55
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Appendix: Carrier Web Site Characteristics and Accessibility ........................................... A-1

A.1. Web Site Technology and Accessibility ......................................................................... A-1

A.2. Carrier Web Site Characteristics..................................................................................... A-2

A.3. Carrier Web Site Accessibility........................................................................................ A-4

A.4. Mobile Versions of Carrier Web Sites............................................................................ A-5

A.5. Screen Reader Parsing of Full and Mobile Versions of Carrier Web Sites.................... A-6
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List of Tables

Table ES1 - Present Value of Net Benefits for Proposed Requirements, Years 1-10 (millions) ... 2

Table 1 - U.S. Population by Disability Status, 2005 and 2009 ..................................................... 8

Table 2 - Internet Use Rates among Various Populations............................................................ 10

Table 3 - Internet Use among Disabled and Non-Disabled Population........................................ 11

Table 4 - Selected Data for 2002 from BTS Freedom to Travel .................................................. 12

Table 5 - Selected Data from Open Doors Organization/Harris Interactive................................. 12

Table 6 - Scheduled Passenger Service: Departures and Passengers, 2009 ................................. 13

Table 7 - Scheduled Passenger Service on U.S. Carriers, 2009 ................................................... 14

Table 8 - U.S. Carriers by Size Class, 2009.................................................................................. 15

Table 9 - Number of Foreign Carriers .......................................................................................... 16

Table 10 - Passenger Enplanements by Size of Airport, 2009 ..................................................... 16

Table 11 - Travel Agencies and Tour Operators, 2007 ................................................................ 17

Table 12 - Number of Passengers Benefitting from Accessible Kiosks....................................... 27

Table 13 - Value of Passenger Time and Carrier Labor Cost Savings from Accessible Kiosks.. 29

Table 14 - Number of Accessible Kiosks Required/Installed....................................................... 31

Table 15 - Compliance Costs for Accessible Kiosks.................................................................... 32

Table 16 - Present Value of Accessible Kiosk Benefits and Costs............................................... 33

Table 17 - Kiosk Benefits, Costs, and Net Benefits by Year........................................................ 34

Table 18 - Mobile Site Adoption and Comparative Read Times.................................................. 36

Table 19 - Mobile Web Site Content for Reporting Carriers........................................................ 37

Table 20 - Annual Time Savings from Proposed Tier 2 and Tier 3 Requirements...................... 44

Table 21 - Estimated Benefits from Proposed Tier 2 and Tier 3 Requirements........................... 45

Table 22 - Estimated Web Site Revision Costs to Comply with Tier 2 Requirements................ 51

Table 23 - Estimated Web Site Revision Costs to Comply with Tier 3 Standards....................... 53

Table 24 - Ongoing Annual Site Maintenance Costs.................................................................... 54

Table 25 - Present Value of Accessible Web Site Benefits and Costs ......................................... 55

Table 26 - Web Site Benefits, Costs, and Net Benefits by Year .................................................. 57

Table A-1 - Carrier Web Site Element Counts........................................................................... A-4

Table A-2 - Accessibility Testing of Carrier Web Site Home Pages ......................................... A-5

Table A-3 - Mobile Web Site Content for Reporting Carriers ................................................... A-6

Table A-4 - Carrier Web Site Screen Reader Times................................................................... A-7
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Executive Summary

The U.S. Department of Transportation (DOT) is issuing a Supplemental Notice of Proposed 

Rulemaking (SNPRM) to ensure that automated airport kiosks and air travel Web sites are 

accessible to air travelers with disabilities. The Department is proposing to require carriers (and 

airports, in the case of shared-use kiosks) to ensure that all new orders for automated airport 

kiosks are for models that comply with the technical standard set forth in the proposed rule.1

U.S. and foreign carriers would be required to meet the Level A and AA success criteria and 

performance requirements included in the Web Content Accessibility Guidelines (WCAG) 2.0 

standards for Web site accessibility. Carriers would also be required to ensure that the Web sites 

of large travel agents and tour operators (hereinafter referred to collectively as “ticket agents”) 

selling air transportation on their behalf meet the same accessibility standard and that large and 

small ticket agents provide Web-based discounts and other Web-based amenities to the 

passengers who contact them offline upon request when their Web sites cannot be used by

passengers with a disability because of their disability.

Econometrica has been tasked with developing a regulatory evaluation for these proposed 

regulatory requirements. In this preliminary analysis, we provide an overview of current industry 

practices, describe the alternatives that were evaluated, identify the parties affected by these 

alternatives, develop preliminary estimates of benefits and costs that can be quantified, and 

indicate the nature of additional benefits and costs for which no quantitative estimates could be 

developed.

All quantified benefits and costs estimated for individual requirements were translated into 

current values for each year in the 10-year period beginning with calendar year 2013 (hereinafter

referred to as “Year 1”).

2 In accordance with Office of Management and Budget (OMB)

guidelines, a discount rate of 7 percent is used in the primary analysis and is supplemented with 

overall estimates using a 3-percent discount rate as well.

 1 As discussed below, this standard is based primarily on Section 707 of the Department of Justice’s 2010 ADA 

Standards but also incorporate elements of the current Section 508 requirements for self-contained, closed machines.

2 Some affected entities may need to begin incurring expenditures to comply with the proposed regulations relating 

to accessible Web sites as early as 6 months before the 10-year analysis period. These “Year 0” compliance costs 

have been included in the 10-year estimates of benefits and costs presented in this evaluation.
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Table ES1 - Present Value of Net Benefits for Proposed Requirements, Years 1-10 (millions)

Kiosks Web Sites

Monetized Benefits

10 Years, 7% discounting $86.2 $122.1

10 Years, 3% discounting $104.8 $147.3

Monetized Costs

10 Years, 7% discounting $15.8 $66.8

10 Years, 3% discounting $18.6 $72.6

Monetized Net Benefits

10 Years, 7% discounting $70.4 $55.3

10 Years, 3% discounting $86.2 $74.7

The expected present value (PV) of the benefits from the proposed requirements to ensure the 

accessibility of automated kiosks is estimated at $86.2 million over Years 1 through 10 using a 

7-percent discount rate. The expected present value of costs incurred by carriers and airports to 

comply with these proposed requirements is $15.8 million over 10 years, discounted at 7 percent. 

The PV of net benefits for the 10-year analysis period at a 7 percent discount rate is thus $70.4

million. Using a 3 percent discount rate, the PV of net benefits for Years 1 through 10 is 

estimated at $86.2 million.

The expected present value (PV) of the benefits from the proposed requirements to ensure air 

travel Web site accessibility is estimated at $122.1 million over Years 1 through 10 using a 7 

percent discount rate. The expected present value of costs incurred by carriers and airports to 

comply with these proposed requirements is $66.8 million over 10 years, discounted at 7 percent. 

The PV of net benefits for the 10-year analysis period at a 7 percent discount rate is thus $55.3

million. Using a 3 percent discount rate, the PV of net benefits for Years 1 through 10 is 

estimated at $74.7 million.

There are additional benefits and costs associated with the proposed requirements for which 

quantitative estimates could not be developed. These are discussed in Sections 5.4 and 5.5 for 

kiosks and in Sections 6.4 and 6.5 for Web sites.

This regulatory analysis indicates that adoption of the proposed requirements for both automated 

airport kiosks and air travel Web sites will result in projected benefits to the public that outweigh 

the estimated costs.
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Introduction

The U.S. Department of Transportation (DOT) is developing proposed regulatory requirements 

that would help to ensure nondiscrimination on the basis of disability in air travel. These 

requirements would extend beyond those included in the May 13, 2008, Final Rule amending the 

Air Carrier Access Act (ACAA). In the Final Rule, the Department noted that it planned a 

Supplemental Notice of Proposed Rulemaking (SNPRM) to discuss potential additional 

regulatory requirements in the five following areas:

Area # Description

1 Carrier-supplied in-flight medical oxygen

2 In-flight entertainment (IFE) systems

3 Automated airport kiosk accessibility

4 Carrier Web site accessibility

5 Exclusion of service animals on foreign carriers

In the accompanying SNPRM, the Department is proposing requirements addressing areas 3 and 

4 to ensure that automated airport kiosks and air travel Web sites are accessible to travelers with 

various types of disabilities. Econometrica has been tasked with developing a regulatory 

evaluation for these proposed regulatory requirements. In this preliminary analysis, we provide 

an overview of current industry practices, describe the alternatives that were evaluated, identify 

the parties affected by these alternatives, develop preliminary estimates of benefits and costs that 

can be quantified, and indicate the nature of additional benefits and costs for which no 

quantitative estimates could be developed. All of these preliminary estimates are based on data 

available thus far and are likely to be revised as additional information is obtained.

The regulatory requirements under consideration would serve to reduce or eliminate barriers to 

air travel for passengers with disabilities who require assistance or accommodation in one or 

more of the following areas:

• Hearing

• Visual

• Mobility

• Fine motor dexterity

• Cognitive

Economic evaluation of possible requirements in these areas is complicated by the fact that the 

technologies available to address many of these disabilities are continuously evolving. 

Regulatory requirements must therefore take into account not only the technologies that may be 

available to carriers for achieving compliance but also technologies that may provide better or 

more cost-effective future support options for travelers with disabilities, whether or not any 

requirements are put into effect. Consequently, an important element of this regulatory analysis 

is an assessment of the feasibility, characteristics, costs, and projected availability and efficacy of 

these new technologies.
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1. Guarantees of Equal Access for Persons with Disabilities

There are currently no Federal statutes or regulations establishing accessibility standards for U.S. 

and foreign air carrier Web sites and for automated airport kiosks. This section provides a brief 

overview of the current statutory and regulatory guarantees of equal access for persons with 

disabilities that are relevant for the evaluation of the proposed requirements to establish such 

standards in this SNPRM.

1.1. Air Carrier Access Act (ACAA)

The Department issued a final rule in 1990 implementing the 1986 Air Carrier Access Act 

(ACAA), which prohibits discrimination in the provision of airline service on the basis of 

disability. The regulations implementing the statute have been revised and extended on 

numerous occasions, most recently in a rule published on May 13, 2008. The 2008 rule extended 

the ACAA to apply to foreign carriers and added new provisions relating to passengers who need 

to use medical oxygen and passengers who are deaf or hard of hearing.

The ACAA rules are designed to minimize the special problems that travelers with disabilities 

may face as they seek to utilize the air travel system. The Department attempts to achieve this 

objective:

• By recognizing that the physical barriers encountered by passengers with 

disabilities can frequently be overcome by employing simple changes in 

layout and technology.

• By adopting the principle that many difficulties confronting passengers with 

hearing or vision impairments will be relieved if they are provided access to 

the same information that is available to all other passengers.

• Through training of all air travel personnel who come in day-to-day contact 

with persons with disabilities, to understand their needs and how they can be 

accommodated quickly, safely, and with dignity.3

In the accompanying SNPRM, the proposed accessibility requirements for automated airport 

kiosks will help to mitigate the physical barriers faced by users with mobility, hearing, cognitive,

or fine motor skill disabilities, as well as make them usable by those with vision disabilities. The 

proposed requirements for ensuring Web site accessibility primarily address the need to provide 

those with vision disabilities access to online information and services related to air travel.

 3 DOT Office of Aviation Consumer Protection and Enforcement, “New Horizons: Information for the Air Traveler 

with a Disability,” available at http://airconsumer.ost.dot.gov/publications/horizons.htm. 
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1.2. Section 707 of the ADA Accessibility Guidelines

While the ACAA governs service provision by U.S. and foreign carriers, airport-based 

operations are also subject to various other Federal laws and rules, as the text of the May 2008 

Final Rule makes clear:

U.S. airports are governed, for disability nondiscrimination, by several Federal 

laws and rules, all of which coexist on the same airport real estate. The ACAA 

and DOT’s ACAA rules apply to terminal facilities owned, leased, or controlled 

by a carrier, specifically facilities that provide access to air transportation (e.g., 

ticket counters, baggage claim areas, gates). Title II of the ADA, and the Title II 

rules of the Department of Justice (DOJ) apply to terminal facilities owned by 

public entities like state and local airport authorities. DOT’s rules under section 

504 of the Rehabilitation Act of 1973 apply to those same facilities owned by 

public entities, if they receive DOT financial assistance (i.e., under the FAA’s 

airport improvement program). In some cases, DOT’s 504 rules could apply to 

airport facilities of airlines (e.g., those air carriers who receive essential air 

service program funds from DOT). ... DOT’s Title III ADA rules apply to private 

transportation serving the airport (e.g., private taxi, demand-responsive shuttle, or 

bus service). DOJ’s Title III ADA rules also apply to places of public 

accommodation on airport grounds that serve the general public (e.g., hotels, 

restaurants, news, and gift stores).

4

Revised regulations for Titles II and III of the ADA were published on September 15, 2010. 

Standards for automatic teller machines and fare machines in Section 707 of the 2004 ADA 

Accessibility Guidelines (ADAAG), which are incorporated into both Title II and Title III of the 

2010 Standards, will become enforceable requirements on March 15, 2012. While interactive 

transaction machines (ITMs), other than automatic teller machines (ATMs), are not covered by 

Section 707, the technical standards that the Department is proposing for automated kiosks are 

based in large part on the Section 707 requirements.

1.3. Section 508

The U.S. Access Board is an independent Federal agency devoted to accessibility for people with 

disabilities. The Board develops and maintains design criteria for the built environment, transit 

vehicles, telecommunications equipment, and electronic and information technology. The 

Board’s accessibility standards for electronic and information technology developed, procured, 

maintained, or used by Federal agencies are compiled in Section 508 of the Rehabilitation Act of 

1973.5 The requirements in Part 1194.25 of Section 508 pertain to “self contained, closed 

products,” which include automated self-service machines such as kiosks. Elements of these 

standards have been incorporated into the automated airport kiosk requirements proposed in the 

accompanying SNPRM.

 4 DOT, 73 FR 27614, May 13, 2008, as modified by Correction Notices 74 FR 11469, March 18, 2009 and 75 FR 

44885, July 30, 2010.

5 Section 508 accessibility standards, information on best practices, and links to training and technical support 

forums are available at www.Section508.gov.
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Part 1194.22 of Section 508 covers Federal agencies’ Web-based Intranet and Internet 

information and applications. These requirements include 16 specific standards, which are 

designed to ensure that Federal agencies’ Web sites can be processed and interpreted by assistive 

technology such as screen readers. In July 2010, the Access Board issued an Advanced Notice of 

Proposed Rulemaking (ANPRM) to solicit comment on revising or “refreshing” the current 

Section 508 standards. However, the timeframe for final publication of the refreshed Section 508 

standard is uncertain at present.

In the interim, the Department has based its proposed requirements for Web site accessibility on 

Web Content Accessibility Guidelines (WCAG) Version 2.0, discussed below. The Access

Board stated in the ANPRM that it was considering harmonizing the Section 508 standards with 

WCAG 2.0, and it requested public comment on a specific technical approach to doing so.

1.4. Website Accessibility Initiative (WAI)

The World Wide Web Consortium (W3C) is an international community of Web programmers 

and users that develops technical specifications and guidelines for Web site technology. W3C, 

through its Website Accessibility Initiative (WAI), has twice developed and issued sets of 

consensus accessibility guidelines. Version 1.0 of the Web Content Accessibility Guidelines 

(WCAG) provided the foundation for the current Section 508 standards for Web site

accessibility. After a long development and review process, Version 2.0 was published on 

December 11, 2008. WCAG 2.0 encompasses 12 guidelines that seek to ensure that Web sites 

are “Perceivable, Operable, Understandable, and Robust” for people with various types of 

disabilities. In contrast to many of the elements of Version 1.0, the performance criteria specified 

in each section of the WCAG 2.0 guidelines are widely regarded to be operationally achievable, 

measurable, and potentially enforceable.6

Both WCAG 1.0 and 2.0 have been incorporated into government-enacted Web site accessibility 

requirements by reference. For example, all official Web sites of the European Union institutions 

are currently expected to follow the WCAG 1.0 guidelines for accessible Web content. In the 

accompanying SNPRM, the Department is proposing to ensure the accessibility of air travel Web 

sites through requirements that reference the WCAG 2.0 standards.

2. Disabled Passengers Requiring Accommodation in Air Travel

This section provides an overview of the data sources and estimates that can be used to estimate 

the population of disabled passengers who may reasonably be expected to benefit from the 

proposed requirements in the accompanying SNPRM. As the discussion below indicates, 

adequate public survey data are available to estimate the prevalence of specific disabilities (such 

as hearing, mobility, and vision-related disabilities) for both the U.S. population generally and 

among selected age groups. There are also estimates available for the overall rates of Internet 

 6 WCAG 2.0 and other guidance, examples, best practices, and resources are available at 

http://www.w3.org/standards/webdesign/accessibility.
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access among people without and with disabilities, although data on the extent to which the 

frequency and nature of online activity varies among people with specific types of disabilities are 

limited. Finally, estimates of the extent of air travel by people with disabilities are available from 

two surveys. Collectively, these data sources provide a foundation for deriving estimates of the 

numbers of potentially affected air travelers requiring accommodation from measures of the U.S. 

population with specific disabilities.

2.1. Extent and Severity of Disabilities in the U.S. Population

Information on the extent and severity of disabilities in the U.S. population is available from a 

variety of government data sources. The most useful of these are the American Community 

Survey (ACS) and the Survey of Income and Program Participation (SIPP), both of which 

provide estimates of the proportion of the U.S. population in selected age groups who have 

hearing or vision disabilities or who have disabilities related to mobility.

The American Community Survey (ACS)

The Census Bureau conducts the ACS on an annual basis to be able to present a more detailed 

profile of the U.S. population than is available from the decennial Census of Population. The 

2008 and 2009 ACS results provide recent estimates of the proportion of the population aged 18 

to 64 years, as well as 65 and older, respectively, who have serious difficulty seeing, serious 

difficulty hearing, or ambulatory difficulty.7

One limitation of the ACS data is that the survey does not collect information on the use of 

assistive technologies, so it is not possible to determine the proportion of people in each of these 

age ranges who used wheelchairs, for example. In addition, the criteria used to identify hearing 

and vision difficulties may be less stringent than those that could be used to define the population 

of individuals who may require accommodation under the ACAA or other Federal accessibility 

statutes and regulations.

The Survey of Income and Program Participation (SIPP)

The Census Bureau also periodically conducts the SIPP, which asks more detailed questions 

about a variety of household characteristics and finances. The 2005 SIPP included a supplement 

on disability status, which was used to develop estimates of the U.S. population with specific 

disabilities reported to be “severe” or “not severe.” The 2005 SIPP also specifically asked about 

the use of wheelchairs.8 In contrast to the ACS, the SIPP results are reported for the U.S. 

population aged 15 years and older (rather than 18 and older), as well as for those 65 and older.

While there are differences between the two sources in the overall methodology, data collection 

instruments, and dates of administration, it is useful to compare selected results from the 2009 

ACS and 2005 SIPP. 

 7 The portion of the ACS questionnaire that collects information about disabilities was revised substantially 

beginning with the 2008 survey, so estimates from the 2008 and 2009 ACS cannot directly be compared with the 

results from previous years. See Matthew Brault, “Review of Changes to the Measurement of Disability in the 2008 

American Community Survey,” Census Bureau, September 22, 2009.

8 The 2008 SIPP also included a supplement that asked disability-related questions, but the results from this section 

of the survey had not yet been released at the time this evaluation was prepared.
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Table 1 - U.S. Population by Disability Status, 2005 and 2009

SIPP, 2005 ACS, 2009

Number 

(1,000s)

Percent of 

Group

Number 

(1,000s)

Percent of 

Group

All ages 291,099 301,472

With a disability 54,430 18.7%

Severe disability* 34,953 12.0% 36,151 12.0%

Aged 15 and older ** 230,391 227,114

With a disability 49,073 21.3%

Severe disability* 32,776 14.2% 33,244 14.6%

Difficulty seeing 7,794 3.4% 5,966 2.6%

Severe difficulty seeing*** 1,783 0.8%

Difficulty hearing 7,809 3.4% 9,761 4.3%

Severe difficulty hearing *** 992 0.4%

Ambulatory difficulty 27,360 11.9% 19,014 8.4%

Used a wheelchair*** 3,311 1.4%

Aged 15 to 64** 195,363 189,181

With a disability 30,940 13.4%

Severe disability* 19,833 8.6% 19,055 10.1%

Difficulty seeing 4,260 1.8% 3,270 1.7%

Severe difficulty seeing*** 819 0.4%

Difficulty hearing 3,894 1.7% 3,914 2.1%

Severe difficulty hearing *** 465 0.2%

Ambulatory difficulty 14,014 6.1% 9,800 5.2%

Used a wheelchair*** 1,488 0.6%

Aged 65 and older 35,028 37,932

With a disability 18,133 51.8%

Severe disability* 12,943 37.0% 14,189 37.4%

Difficulty seeing 3,534 10.1% 2,696 19.0%

Severe difficulty seeing*** 964 2.8%

Difficulty hearing 3,915 11.2% 5,847 15.4%

Severe difficulty hearing *** 527 1.5%

Ambulatory difficulty 13,346 38.1% 9,213 24.3%

Used a wheelchair*** 1,823 5.2%

*Asked as “serious disability” on ACS data collection instrument.

**ACS estimates are for age 18 and older.

***Not included on ACS data collection instrument.

Source: Census Bureau, “Americans With Disabilities: 2005,” Current Population Reports, P70-117, 

December 2008 and 2009 American Community Survey.
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In presenting these comparisons, we have aligned the overall percentages of the population in 

each age range reporting any type of disability in the 2009 ACS with the percentage of the same 

age group reporting a severe disability in the 2005 SIPP. With this adjustment, the results from 

the two surveys appear to be very comparable, increasing the level of confidence that they can be 

used to estimate the number of people who might potentially benefit from improved accessibility 

of automated airport kiosks and Web sites relating to air travel.

The 2005 SIPP estimates can be interpreted as indicating that, while a significant portion of the 

U.S. population (and a majority of the population aged 65 and older) has some type of disability, 

relatively small percentages of the population have each of the specific types of severe 

impairments that are being addressed specifically by the proposed regulatory requirements. 

However, many air travelers with less severe vision, hearing, mobility, or fine motor skill

impairments may also benefit from more accessible automated kiosks and/or carrier/ticket agent 

Web sites. For example, more accessible Web sites may make navigation easier for people with 

motor skill limitations that make using a mouse difficult.

2.2. Use of Electronic Technologies by People with Disabilities

As Internet use became more widespread in the 1990s, a series of Department of Commerce 

studies focused on the existence of a “digital divide,” a term that was used to refer to disparities 

in the rates of Internet access and the extent of online activities among members of various 

socioeconomic groups. The last of these studies (which was conducted in 2004) presented 

estimated Internet use rates for people who reported being blind or having severe vision 

impairments. More recent, but less extensive, information on online access and participation 

rates is available from research sponsored by the Federal Communications Commission (FCC) 

and the Pew Internet and American Life Project.

A Nation Online: Entering the Broadband Age (NTIA 2004)

A 2004 study by the National Telecommunications and Information Administration (NTIA) 

presented information on differences in online access rates among groups with various 

disabilities. For this analysis, the access rates of interest are those for people who are blind or 

who have severe vision impairments:
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Table 2 - Internet Use Rates among Various Populations

2001 2003

Blind/severe vision impairment

Aged 25-60, in labor force 56.2% 63.7%

Aged 25-60, not in labor force 40.3% 40.0%

Over 60 9.6% 23.0%

No disability reported

Aged 25-60, in labor force 67.0% 71.0%

Aged 25-60, not in labor force 47.0% 52.5%

Over 60 26.4% 34.2%

U.S. Population 55.1% 58.7%

Source: NTIA, “A Nation Online: Entering the Broadband Age,” Sept. 2004.

The NTIA estimates suggest that Internet access rates for blind people and those with severe 

visual impairments were lower than for people without disabilities but that the gap between the 

two groups was closing by 2003. It is possible that the Internet access rate for visually disabled 

people has grown even closer to that for the general population since then. However, more recent 

data on Internet access rates for people with specific disabilities could not be located.

Broadband Use and Adoption in America (FCC 2010)

Attention has been focused more recently on the impact of disability status on broadband access 

rates. In a recent FCC working paper, John Horrigan finds a significant gap between Internet use 

rates for disabled and non-disabled users:

9

Collectively, 24 percent of respondents had an affirmative response to one of 

those questions and, for purposes of this report, are classified as people with 

disabilities. Within this group, 42 percent have broadband at home—much lower 

than the 65 percent average. Some 56 percent of those with disabilities are 

Internet users, below the 78 percent average. Nearly half (47 percent) of nonInternet users report having some sort of disability.

However, it is difficult to isolate the impact of disability from that of other socioeconomic 

characteristics that are also associated with lower rates of Internet use, as Horrigan notes:

...people with disabilities and non-adopters overlap quite a bit and in fact share 

many characteristics with non-adopters: They are generally older and have lower 

incomes. For that reason, it is not a surprise that non-adopters include a 

disproportionately high share of people with disabilities. Some of the difference in 

adoption rates is due to individuals’ disabilities and some is due to lower incomes, 

advanced age or other factors associated with low adoption.

 9 John Horrigan, “Broadband Use and Adoption in America,” Federal Communications Commission, OBI Working 

Paper No. 1, February 2010.
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Americans Living with Disability and their Technology Profile (Pew 2011)

A January 2011 Pew Internet and American Life Project report presented survey-based estimates 

on the extent of disabilities in the U.S. population and the impact of disability on the use of 

technology.10 The Pew report estimates on the impact of disability on the use of electronic 

technologies corroborate the FCC report finding of a large gap in the Internet use rates between 

the disabled and non-disabled segments of the population. However, a very small percentage of 

disabled Internet users indicated that their disability caused problems with using the Internet.

Table 3 - Internet Use among Disabled and Non-Disabled Population

Disabled Non-Disabled

High School education or less 61% 40%

HH Income < $30,000/year 46% 26%

Use the Internet 54% 81%

% with use problems 2%

Do not use the Internet 46% 19%

Have broadband at home 41% 69%

Source: Pew Internet and American Life Project, “Americans living with disability and 

their technology profile,” January 21, 2011.

Based on these results, it seems reasonable to infer that on an income- and age-adjusted basis, 

Internet access and use rates for the disabled population are becoming increasingly similar to 

those for the non-disabled population.

2.3. Travel Behavior of People with Disabilities

Relatively few data sources are available to characterize the travel patterns of people with 

disabilities. The most useful of these are a 2003 report by the Bureau of Transportation Statistics 

(BTS) and two surveys sponsored by the Open Doors Organization (ODO).

Freedom to Travel (BTS 2003)

In 2002, the BTS conducted a study on the travel behavior of people with disabilities.11 The 

results presented in the “Freedom to Travel” report indicated that disabled people had a lower 

average propensity to travel by air than did non-disabled people—the average disabled person in 

the BTS study sample was only 78 percent as likely to have traveled on a commercial airline in 

the past year.

 10 Susanna Fox, “Americans Living with Disability and Their Technology Profile,” Pew Internet and American Life 

Project, January 21, 2011. 11 DOT Bureau of Transportation Statistics, “Freedom to Travel,” BTS03-08, 2003.
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Table 4 - Selected Data for 2002 from BTS Freedom to Travel

Disabled Non-Disabled

Average Age 50.7 31.9

% Using in Last Year:

commercial airline 31.5% 40.1%

private/charter airplane 1.4% 1.3%

Source: BTS Freedom to Travel, 2003.

One result worth noting is that the average age of disabled people in the BTS study was nearly 

two decades higher than that of the non-disabled respondents. It is therefore difficult to assess the 

extent to which traveler age may influence the propensity to travel by air, irrespective of the 

person’s disability status. The report also does not present travel frequencies for people with 

varying specific types of disabilities.

The Open Doors Organization/Harris Surveys

A 2002 survey sponsored by the Open Doors Organization showed that about 30 percent of 

adults with disabilities traveled by air at least once during the previous 2 years. Disabled 

travelers reported taking an average of two trips by air during the previous 2 years, which is 

consistent with an estimated 9.4 million trips taken annually by disabled travelers.12 One-third of 

disabled travelers who flew during the past 2 years made at least three trips by air.

The ODO survey was updated in 2005. The percentages of those who traveled by air in the past 2 

years was comparable in both surveys (as well as the percentage found in the 2002 BTS study), 

and the percentage of travelers who reported booking online increased substantially between 

2002 and 2005.

Table 5 - Selected Data from Open Doors Organization/Harris Interactive

2002 2005

% who traveled by air in the past 2 years: 30% 31%

Average number of air trips per year 1 1

% who book online 33% 51%

% who consult Internet for accessibility info 46% 43%

Source: Open Doors Organization/Harris Interactive Surveys, 2002 and 2005.

3. An Overview of the Air Transportation Sector and Current 

Regulatory Structure

This section provides a description and statistical profile of the passenger air travel sector: flights 

and passengers, U.S. and foreign carriers, airports, travel agencies and tour operators (“ticket 

agents”), and regulatory authorities.

 12 The ODO survey collected data on trips. Each round trip would be equivalent to approximately 3.2 flight 

segments, which would imply that travelers with disabilities account for approximately 30 million flight segments 

annually.
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3.1. Flights and Passengers

Airline passengers travel to both domestic and international destinations using both scheduled 

and nonscheduled (charter) service provided by U.S. and foreign carriers. Carrier-specific data 

on the annual numbers of domestic and international departures and passengers boarded for each 

type of flight are available from the BTS T-100 segment database.

Most passenger travel is on scheduled service flights, and seven out of every eight scheduled 

flights are to destinations within the United States. Virtually all domestic flights are on U.S. 

carriers. Foreign carriers may transport passengers between two U.S. airports only on segments 

of flights that originate from or continue on to international destinations. U.S. carriers also

account for a significant majority of international departures, although the share of passengers on 

international flights is divided more evenly between U.S. and foreign carriers because the 

average number of passengers per departure is larger on flights operated by foreign carriers.

Table 6 - Scheduled Passenger Service: Departures and Passengers, 2009

Domestic International Combined

Departures

U.S. Carriers 8,751,178 775,885 9,527,063

Foreign Carriers 2,389 483,944 486,333

Total 8,753,567 1,259,829 10,013,396

Passengers

U.S. Carriers 631,955,369 83,152,598 715,107,967

Foreign Carriers 503,133 66,349,930 66,853,063

Total 632,458,502 149,502,528 781,961,030

Passengers/Departure

U.S. Carriers 72.2 107.2 75.1

Foreign Carriers 210.6 137.1 137.5

Total 72.3 118.7 78.1

Source: BTS T-100 Segment database, 2009.

The number of passengers flown typically rises each year, but enplanements fell in 2008 and 

again in 2009. The Federal Aviation Administration (FAA) Aerospace Forecast for 2010 through 

2030 projected increases of 0.4 percent and 0.9 percent, respectively, from 2009 to 2010 in the 

numbers of passengers flying on domestic and international flights. For 2011 and future years, 

the Forecast projects that annual passenger enplanements will increase by an average of 2.8 

percent annually on domestic routes and 4.2 percent on international routes.13

3.2. U.S. and Foreign Air Carriers

About 230 U.S. and foreign air carriers provide some combination of scheduled and 

nonscheduled passenger air service to U.S. and international destinations from at least one U.S. 

airport. U.S. air carriers operating any aircraft of 60 seats or more must have a certificate under 

 13 Federal Aviation Administration, FAA Aerospace Forecast: Fiscal Years 2010-2030.
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49 USC § 41102 (or an exemption issued by DOT from that section) to provide scheduled 

passenger service. Some carriers that operate fleets consisting only of smaller aircraft may also 

be “certificated carriers.” A relatively limited number of carriers operating small aircraft are 

authorized as “commuter air carriers” under the definition provided in 14 CFR 298.3(b). Foreign 

air carriers must hold permits issued under 49 U.S.C. § 41302 (or an exemption issued by DOT 

from that section) to operate flights that arrive or depart at U.S. airports.

The applicability of some current Part 382 requirements varies not only between U.S. and 

foreign carriers but also among different categories of carriers, based on the seating capacity of 

the aircraft the carrier operates. The requirements proposed in this SNPRM would apply to all 

U.S. and foreign carriers operating flights to and from the United States that provide flightrelated services to customers on automated kiosks at U.S. airports, as well as to all U.S. and 

foreign carriers that market air transportation to the general public in the U.S. on a Web site.

Reporting carriers

In 2012, the roster of reporting carriers, those U.S. carriers that account for at least 1 percent of 

domestic scheduled passenger service revenues, is expected to include six mainline carriers 

(Alaska, American, Delta, Hawaiian, United, and US Airways), three low-cost model major 

airlines (Frontier, JetBlue, and Southwest), and five regional carriers (American Eagle, Atlantic 

Southeast, ExpressJet, Mesa, and SkyWest).

14

Table 7 - Scheduled Passenger Service on U.S. Carriers, 2009

Number of 

Carriers Departures Passengers

Passengers/ 

Departure

Reporting Carriers 18 7,008,602 628,155,438 90

Other U.S Carriers 79 2,517,894 86,952,529 35

Total 97 9,526,496 715,107,967 75

Reporting % of Total 18.6% 73.6% 87.9% --

Source: BTS T-100 Segment database, 2009.

Aircraft size-based distinctions among carriers

Carriers that provide passenger service exclusively using aircraft originally designed with 60 

seats or less are considered small entities for purposes of assessing impact under the relevant 

requirements of the Regulatory Flexibility Act. The regulatory requirements for these carriers are 

somewhat less extensive than for larger carriers.

 14 There were 18 reporting carriers at the end of 2009. Since then, Air Tran has been purchased by Southwest,

Continental and United have merged, Comair no longer must report, and Pinnacle has elected to discontinue 

reporting on a voluntary basis. It is also possible that ExpressJet will discontinue reporting voluntarily if SkyWest 

(which acquired the carrier in 2010) elects to consolidate reporting by the beginning of 2012.
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Table 8 - U.S. Carriers by Size Class, 2009

Group

Seat 

Criterion

Total in 

2009 T-100*

Charteronly**Scheduled 

Service

Contract 

Carriers Other

Large > 60 49 16 33 15 18

Small 30 - 60 12 0 12 6 6

Very Small < 30 38 10 28 1 27

Total 99 26 73 22 51

Note: 17 large carriers and 1 small carrier are reporting carriers.

*Excludes carriers that were no longer operating independently by the end of 2010.

**Six charters offered some scheduled service in 2009; all are very small Alaska or sightseeing tour carriers.

The U.S. domestic airline industry continues to undergo significant consolidation. Of the 117 

U.S. carriers operating at the beginning of 2009, 20 were no longer providing service 2 years 

later. Fourteen of the remaining carriers are wholly-owned subsidiaries that do not independently 

market air transportation services but are treated as separate entities for some reporting and

regulatory compliance purposes.

Mainline and regional airlines

Several U.S. carriers, including 5 of the 14 carriers expected to be reporting carriers by the 

beginning of 2012, operate flights primarily or exclusively on a contract basis, providing service 

primarily for the largest mainline network carriers. Most of these carriers do not sell scheduled 

air transportation services directly to the general public; the flights they operate are listed on the 

contracting carriers’ schedules under code-share agreements. A few small regional carriers (e.g., 

Cape Air and Great Lakes) operate both contract and independently-marketed flights.

Regional carriers—both contract carriers and those that market flights independently—provide 

service to a much larger network of communities than do the mainline and low-cost national 

carriers. The Regional Airlines Association (RAA) estimates that its 68 member carriers provide 

the only scheduled service available at 263 of the 428 U.S. airports in the 48 contiguous States

and at 185 of the 207 airports in Alaska, Hawaii, and Puerto Rico.

15 Regional carriers are 

typically subject to the same reporting and regulatory requirements as other airlines in the same 

size classes.

Foreign carriers

Foreign carriers operating flights to and from the United States are generally subject to the same

regulatory requirements as U.S. carriers with respect to covered flights. There are 130 foreign 

carriers that operate scheduled or charter service to the United States.

16 Of these, 89 market 

scheduled service flights to U.S. passengers.

 15 Regional Airline Association, 2010 Annual Report. 16 Four foreign carriers operate passenger service to and from the United States exclusively with aircraft having 

fewer than 30 seats. These carriers do not have to comply with the requirements that apply only to U.S. and foreign 

carriers which provide passenger service on at least one aircraft that has 30 or more seats.
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Table 9 - Number of Foreign Carriers

Group

Total in 2009 

T-100*

Charteronly*Scheduled 

Service

Contract 

Carriers Other

EU 47 21 26 2 24

Canada 10 2 8 2 6

Total 130 29 101 12 89

*No charter service carrier operated more than three scheduled service flights in 2009.

3.3. Airports

The FAA classifies airports into a set of size-based categories based on the annual number of 

passengers boarded (“enplanements”). The proposed requirements in this SNPRM concerning 

automated airport kiosk accessibility will apply only at U.S. airports having 10,000 or more 

annual enplanements. There were 385 U.S. airports with at least 10,000 passenger enplanements 

in 2009. More than two-thirds of domestic and international passengers departed from 29 major 

metropolitan hubs, and another one-fifth departed from 37 medium hub airports. 

Table 10 - Passenger Enplanements by Size of Airport, 2009

Category

Minimum %/# of 

Passengers # of Airports

Passengers 

(millions) % of Total

Passengers 

per Airport 

Large Hub >1% of total 29 491.7 69.3% 17.0 million

Medium Hub >0.25% of total 37 138.0 19.4% 3.7 million

Small Hub >0.05% of total 69 56.7 8.0% 821,000

Non-Hub >10,000/year 250 22.9 3.2% 91,000

Other 

Commercial >2,500/year 180 0.9 0.1% 5,000

Total 565 710.1 100.0% 1.3 million

Source: BTS T-100 Segment database, 2009.

3.4. Travel Agencies and Tour Operators

Travel agencies and tour operators are the two largest industry sectors (in addition to carriers) 

that sell air travel. These sales sometimes are made on a standalone basis and sometimes as part 

of a package that may include accommodations, activities, and ground transportation. Carrier, 

travel agent, and tour operator Web sites also offer packages that do not include any air 

transportation.

According to a recent study, about 17 percent of travel agencies have online ticketing capability. 

The four largest online travel agencies (OTA)—Expedia, Orbitz, Priceline, and Travelocity—

reportedly account for 96 percent of all online sales by travel intermediaries in the leisure travel 

market segment.17

 17 PhoCusWright, The Role and Value of the Global Distribution Systems in Travel Distribution, November 2009.
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Table 11 - Travel Agencies and Tour Operators, 2007

Total Firms

Largest

OTAs

Others 

with 

Online 

Sales 

Offline 

Sales Only

Large 

Businesses 

(SBA 

Definition)

Small 

Businesses 

(SBA 

Definition

Travel Agencies 11,953 4 2,028 9,921 328 11,625

Tour Operators 2,814 0 478 2,336 94 2,720

Sources: Bureau of the Census, Economic Census, 2007; PhoCusWright, The Role and Value of the Global 

Distribution Systems in Travel Distribution, 2009.

However, most travel agencies and tour operators are small businesses with fewer than 20 

employees. The applicable SBA size standards designate travel agencies with no more than $3.5 

million in annual revenues and tour operators with no more than $7.0 million as small 

businesses.

Three large Global Distribution System (GDS) companies—Amadeus, Sabre, and Travelport—

provide the infrastructure to process both online and offline transactions for most travel agencies 

and tour operators. Sabre (Travelocity) and Travelport (Orbitz) also own large OTAs as well. 

GDS companies reportedly processed more than 376 million air transactions in the United States 

in 2008, accounting for 64 percent of all airline passenger revenue.18

For purposes of this regulatory analysis, none of SNPRM requirements would apply to ticket 

agents directly, but carriers would be required to ensure that large ticket agents marketing air 

transportation to the general public in the U.S. make their Web sites accessible and that all ticket 

agents provide certain Web-based amenities to passengers with disabilities who cannot access 

their Web sites due to a disability.

3.5. Regulatory Authorities

DOT enforces the Air Carrier Access Act and other civil rights statutes and regulations that 

apply to carriers, conducts economic licensing of U.S. carriers and foreign carriers operating in 

the United States, establishes regulatory requirements relating to advertising and provision of 

scheduled and nonscheduled passenger service, issues guidelines and letters to codify and clarify 

Department enforcement policy, and enters into consent orders to enforce regulations and impose 

penalties for noncompliance. From 2008 through 2010, DOT entered into 77 enforcement orders 

with U.S. and foreign carriers, travel agencies, and tour operators. Two of these orders involved 

noncompliance with established rules and policies relating to ensuring accessibility of air travel 

to persons with disabilities, and seven others related to failures to comply with the disability 

complaint reporting requirements.

Regulatory authority for matters relating to the air traffic system and airport operations is vested 

in the FAA. The FAA Office of the Associate Administrator for Airports has responsibility for 

all programs related to airport safety and inspections and standards for airport design, 

 18 Ibid.
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construction, and operation, including accessibility of facilities and transportation controlled by 

the airport operator.

4. General Framework for Analysis of Benefits and Costs

The SNPRM being evaluated includes proposed requirements relating to automated airport 

kiosks and to carrier Web sites. Both quantifiable and unquantifiable benefits would accrue from 

adoption of these requirements, which would also entail costs to carriers and airports. Benefits 

and costs would also accrue from the proposed requirements for carriers to ensure that the Web 

sites of their ticket agents are accessible and that agents provide Web-based fare discounts and 

other Web-based amenities upon request to passengers who cannot use their Web sites due to 

their disabilities.

While the methodology used to quantify elements of these benefits and costs has provisionspecific components, the estimates were developed using a common general framework for 

analysis. In this section, we provide a discussion of the nature of benefits that are anticipated, the 

types of costs that would be incurred, and the general assumptions used in developing monetized 

estimates of the benefits and costs associated with the requirements proposed in the SNPRM.

4.1. Nature of Benefits Anticipated

The types of benefits that air travelers with disabilities would potentially derive from the 

proposed requirements include the following:

• Time saved in obtaining information, purchasing tickets, and completing various aspects 

of the check-in process.

• Reduction in the amount of effort and discomfort associated with use of technologies 

related to air travel.

• Decreased expenditures from improved access to discounted or promotional airfares.

• Improved ability to travel without needing to rely on the assistance of others.

The value of the time savings associated with improved kiosk and Web site accessibility has 

been estimated and monetized in this regulatory evaluation, which also suggests the range of 

values that could reasonably be used to quantify the benefits associated with reductions in the 

amount of effort and discomfort associated with the use of technologies related to air travel.

The Department does not have sufficient information to quantify the potential savings on 

airfares, if any, that travelers with disabilities may receive as a result of improved access to 

discounted or promotional airfares on accessible Web sites. In any event, these savings will be 

exactly offset by an equal reduction in carrier revenues from providing passenger service, with 

the result that the net economic benefits of any such savings to travelers and carriers combined 

must necessarily be zero.19

 19 It is possible that the reduction in the effort required to research and book flights and to check in may encourage 

additional people with disabilities to travel by air or those who already travel to do so more often, which would 

represent a net economic benefit. However, the magnitude of this impact is not likely to be large enough to quantify.
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In contrast, the increased independence that would be experienced by travelers with disabilities 

as a result of the proposed requirements represents an important benefit but one for which no 

monetary value can be assigned.

Carriers would also realize benefits from the proposed requirements. The cost-savings associated 

with traveler use of kiosks, rather than other onsite forms of check-in, are well documented.20

There is also evidence that carrier Web sites could be more readily maintained and updated if the 

programming practices required to ensure Web site accessibility are consistently implemented 

and followed, although the associated benefits are more difficult to quantify. For example, the 

W3C Website Accessibility Initiative (WAI) site notes that, “Incorporating accessibility usually 

increases site development time initially. However, in the long term Web accessibility can 

reduce the time an organization spends on site development and maintenance, as follows:

• Reduced time and effort needed to change presentation across a site by defining 

presentation through a style sheet and using proper markup (for example, in XHTML) for 

structure.

• More efficient debugging with automated validation tools by conforming to standards 

and identifying a DOCTYPE. 

• Reduced redesign and translation time and skills.”

The WAI also anticipates costs savings from reduced bandwidth use and server load, easier 

enabling of content on different configurations (e.g., mobile sites), and easier transition to the use 

of advanced Web technologies.21 Comments received in response to the DOJ ANPRM also 

indicated that implementing programming practices to ensure accessibility would make Web 

sites easier to maintain. Similar benefits would be realized by ticket agents that make their Web 

sites accessible at the request of carriers required to ensure accessibility of their agents’ Web 

sites.

Additional benefits may accrue to carriers and to any ticket agents that would be prompted by the 

proposed accessibility requirements to voluntarily develop or expand the mobile versions of their 

Web sites, because this investment may improve their ability to attract more business from the 

important and expanding segment of the air travel market consisting of passengers who prefer to 

research and book flights through Smartphones and other mobile devices.

4.2. Types of Compliance Costs Incurred

Carriers would incur additional capital, implementation, and continuing operations and 

maintenance costs to comply with the proposed requirements. Similar costs would be incurred by 

ticket agents making their Web sites accessible at the request of carriers required to ensure 

accessibility of their agents’ Web sites. Where appropriate, the estimation of these costs 

incorporates a life-cycle analysis that takes into account the schedule on which compliance is 

 20 See, for example, Airport Business, “Analysis: Kiosk Uptime, Revenue,” July 8, 2008. 21 W3C Website Accessibility Initiative, “Developing a Web Accessibility Business Case for Your Organization,” 

available at http://www.w3.org/WAI/bcase/Overview.html.
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projected to occur. For example, the costs for installation of new and replacement accessible 

kiosks are expected to be incurred over a 5-year timeframe.22

4.3. General Assumptions Used to Estimate Benefits and Costs

The following general assumptions were employed to develop monetized estimates of the 

benefits and costs associated with the proposed requirements:

• Quantitative benefits and costs in the preliminary RIA were estimated assuming that the 

effective date was 6 months before the beginning of the first year of the analysis period.

The 2-year period to achieve compliance with the Web site requirements therefore spans 

from 6 months before Year 1 begins to the midpoint of Year 2. The 10-year period 

chosen for the analysis was used to evaluate the benefits and costs of the rule because no 

kiosk or Web site benefits and no kiosk costs would accrue until 6 months after the 

effective date of the rule. In accordance with OMB guidelines, a real discount rate of 7 

percent is used in this primary analysis to compute the present value of net benefits for 

each year in the 10-year analysis period.

23

• This analysis includes costs incurred by foreign carriers.

• The numbers of flights and passengers are assumed to increase annually at the rates 

projected in the FAA Aerospace Forecast for 2010 through 2030 (see Section 3.1 above).

• The value of travel time (and the cost of air travel delay) is estimated at $28.60 per hour 

for all airline travelers.24

• Per-hour costs for applicable categories of carrier, airport, travel agent, and tour operator 

employees were estimated using Bureau of Labor Statistics (BLS) wage rates, increased 

by 43 percent to account for the non-wage components (e.g., fringe benefits, employer 

taxes) of direct labor costs.

25 A mark-up of 100 percent was applied to these direct labor 

cost estimates to account for supervisory and management planning, communication, 

training, and oversight time.

A more detailed description and discussion of the baseline data and assumptions used in 

developing the specific benefit and cost estimates is provided in the relevant parts of Section 5.

 22 It is our understanding from discussions with kiosk manufacturers that while in some cases, the external structure 

of a kiosk may remain in service for as long as 7-10 years, extending the service life of the machine requires 

significant “refreshing” of components, including the motherboards, printers (where applicable), and displays. Thus,

we would expect airlines and/or airports to incur the full replacement cost of a kiosk every 5 years.

23 The present value of Web site revision costs incurred in the 6 months before the beginning of Year 1 were also 

calculated using this discount rate.

24 Economic Values for FAA Investment and Regulatory Decisions, A Guide, Contract No. DFTA 1-02-C00200, 

GRA Inc., Oct. 3, 2007. 25 U.S. Bureau of Labor Statistics, “Employer Costs for Employee Compensation,” June 2009.
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4.4. Components of the Requirement-Specific Evaluations

Sections 5.1 and 5.2 of the regulatory evaluation provide assessments of the projected benefits 

and costs for the specific requirements proposed to ensure accessibility of automated airport 

kiosks and carrier as well as affected ticket agent Web sites, respectively. For each set of 

proposed requirements, we present the following information:

• Current Industry Practices and Need for Additional Regulation. This section presents a 

summary of current industry practices and describes the needs addressed by the Rule. It 

also includes a brief discussion of the technologies currently available to address the 

identified needs of disabled travelers, as well as information on additional or improved 

technologies that can reasonably be expected to become available within the timeframe 

used in this analysis.

• Proposed New Requirements. This section outlines the regulatory requirements being 

proposed by the Department in the accompanying SNPRM and provides information on 

the entities that will be affected.

• Compliance Scenarios Evaluated. This section defines the expected impact on affected 

entities and specifies the most likely ways in which they can be expected to comply with 

the proposed requirements.

• Estimated Benefits of Proposed Requirements. This section presents the methodology 

used to evaluate benefits, estimates for the components that could be evaluated 

quantitatively, and descriptions of the benefits for which no quantitative estimates could 

be developed.

• Estimated Costs of Proposed Requirements. This section presents the methodology used 

to evaluate costs, estimates for the components that could be evaluated quantitatively, and 

descriptions of the costs for which no quantitative estimates could be developed.

• Estimated Net Benefits and Discussion of Results. This section summarizes the benefit 

and cost estimates for the proposed requirements and relevant alternatives considered.

5. Evaluation of Proposed Requirements for Accessible Kiosks

5.1. Current Industry Practices and the Need for Regulatory Requirements

An automated airport kiosk is a self-service transaction machine that a carrier owns, leases, or 

controls and makes available at a U.S. airport to enable customers to independently obtain its 

flight-related services. Use of automated airport kiosks typically reduces check-in waits and, in 

some cases, reduces the fees paid by passengers for checked baggage. However, currently 
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deployed kiosks pose significant obstacles to use by travelers with various types of disabilities.26

Machine heights and installation configurations often make access by passengers in wheelchairs 

difficult or impossible. Traditional automated kiosks also pose some specific challenges to air 

passengers with visual impairments, cognitive disabilities, or problems with motor skills, 

including:

• Touch screens that are difficult, if not impossible, to use by travelers who have limited or 

no visual acuity.

• Buttons, card readers, passport readers, and other hardware controls that are not 

discernible by touch.

• An alternative access method, such as audio, may not be available to travelers who have 

limited or no vision.

Two types of automated kiosks are used at airports: proprietary and shared-use, or Common Use 

Self Service (CUSS), kiosks. Proprietary automated kiosks have been in use since the early 

1990s. They are specifically designed for, and operated by, a single carrier. Shared-use 

automated kiosks are provided by an airport, a carrier, or an independent service provider with 

which any carrier having a compliant data set can collaborate to enable its customers to 

independently access its flight-related services. Early implementation of airline self-service 

technology was driven by individual airlines placing kiosks near their check-in facilities. In 

contrast, shared-use kiosks are typically distributed throughout the terminal, with some located at 

non-airport locations, such as parking garages and nearby hotels. Shared-use kiosks were 

developed as a result of a collaborative effort between individual carriers and the International 

Air Transport Association (IATA) to enable carriers to provide a range of passenger services at a 

shared kiosk. Shared-use kiosks began to be deployed across airports worldwide in significant 

numbers in 2005.

There are several major suppliers of automated kiosk hardware and software, including NCR, 

IBM, and SITA. NCR reportedly had an installed base of approximately 8,400 kiosks in 300 

airports worldwide by the end of 2009; a separate source estimates that the company has about 

80 percent of the U.S. airport market.27 Statistics on the total number of automated air travel 

kiosks installed in the United States could not be located.

IBM, SITA, and other vendors develop, install, and support shared-use kiosks, “middleware,” 

and carrier applications, either as a complete package or on a standalone basis. It is our 

understanding that shared-use terminals are typically purchased and maintained under contracts 

with airport authorities. The middleware installed on these machines provides an interface 

between the machine components and controls (such as the touchpad) and proprietary software 

developed by, or on behalf, of individual carriers. The software demands in a shared-use 

 26 The National Council on Disability reported that, as of 2005, no airline kiosk vendor serving the U.S. market had 

included accessibility among its product features (www.ncd.gov/newsroom/publications/2006/kiosk.htm). 27 Hugo Martin, “Airport kiosks do nearly everything but check luggage,” LATimes.com, December 5, 2009, and 

Mary Jane Credeur, “NCR CEO Forecasts Growth in Self-Service Machines as Customers Cut Costs,” 

Bloomberg.com, January 24, 2011.
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environment are more challenging, because multiple carrier applications have to run on the same 

platform and each must be able to protect against unauthorized access to proprietary data from 

other carrier applications.

IBM is currently marketing a demonstration version of an automated airport kiosk that has a 

variety of accessibility features, including: 28

• A headset jack with volume control.

• IBM Embedded Via Voice® text-to-speech output.

• Layered audio user assistance and system event sound effects.

• An EZ Access® keypad with tactilely discernable keys.

• An on-screen visual focus indicator that highlights the selected content or control.

• Textual equivalents for all graphics.

As noted above in Sections 1.2 and 1.3, accessibility standards for ATMs and fare vending 

machines (section 707 of the 2010 Standards for Accessible Design), which were adopted as part 

of the Department of Justice’s Title II and III regulations (28 CFR Parts 35 and 36) in September 

2010, do not cover automated airport kiosks. The Section 508 standard for self-contained, closed 

products (36 CFR 1194.25) adopted by the Access Board requires electronic information 

products used in or provided to the public by the Federal sector to be accessible, but it does not 

cover airport kiosks.29 Currently, there are no ACAA-based accessibility standards that apply to 

airport kiosks owned, leased, or controlled by carriers. 

5.2. Proposed Requirements to Address Identified Needs

The SNPRM includes a detailed set of proposed requirements to ensure that a sufficient quantity 

of airport automated kiosks ordered after the effective date of the proposed rule would be 

accessible to air travelers with various types of disabilities.30 The proposed technical standards 

would specifically address the following aspects of kiosk design, installation, and operation:

1. Use of assistive technology. Kiosks would have to be accessible to those with visual 

impairments without attaching assistive technologies other than a personal headset or 

audio loop. A telephone handset or an industry standard connector would be provided so 

that users with visual impairments can attach personal headsets or use a handset to listen 

to the speech output during a transaction while maintaining their privacy.

 28 Andi Snow-Weaver, “Innovation that Matters: Accessible IBM Airline Self-Service Kiosks,” presentation at the 

Open Doors Organization Universal Access in Airports Conference, October 20, 2010. Additional information is 

available at http://www-03.ibm.com/able/news/selfservkiosk.html. 29 In 2000, the Access Board published a report with the Trace Center that focused on making information and 

transaction machines accessible by providing guidelines which addressed issues for those with sensory, physical, 

and cognitive disabilities. The Access Board used these guidelines in the development of its Revised Accessibility 

Standards for Technology, which were discussed in its March 22, 2010 ANPRM. 30 The proposed requirements are drawn primarily from Section 707 of the ADA Accessibility Guidelines (ADAAG)

(the legally applicable standards under Titles II and III of the Americans with Disabilities Act), as well as selected 

elements from part 1194.25 of the Section 508 Standards. These proposed requirements are expected to be 

compatible with the anticipated Access Board standards for other types of accessible kiosks. 
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2. Operable parts. Operable parts on new kiosks would have to be tactilely discernable by 

users to avoid unintentional activation. Complying kiosks would also be required to alert 

the user by sound or touch and give the user an opportunity to indicate that more time is 

needed where a timed response is required.

3. Outputs. Speech outputs would be required to be coordinated with the information on the 

visual display so that users with low vision or cognitive disabilities may benefit from 

using the display along with the speech. 

4. Volume control. Where speech output is delivered through a mechanism for private 

listening, the kiosk would need to provide means for controlling the volume. Where 

sound is delivered through speakers on the machine, incremental volume control would 

need to be provided with output amplification up to a level of at least 65 dB. Where the 

ambient noise level of the environment is above 45 dB, a volume gain of at least 20 dB 

above the ambient level shall be user selectable.

5. Captioning. Multimedia content that contains speech or other audio information 

necessary for the comprehension of the content would have to be open- or closedcaptioned.

6. Input controls. At least one tactilely discernible input control would need to be provided 

for each function. Where provided, key surfaces not on active areas of display screens

would need to be raised above surrounding surfaces. Where touch or membrane keys are 

the only method of input, each would need to be tactilely discernable from surrounding 

surfaces and adjacent keys.

7. Clear floor or ground space. Kiosks would have to be installed that would provide a 

clear floor or ground space that meets the 2010 DOJ ADA Standards.

All new kiosk orders initiated 60 days or more after the effective date of the rule would have to 

comply with the proposed requirements. All U.S. carriers and all foreign carriers operating 

flights to and from the United States would need to comply with the proposed standards for kiosk 

accessibility. These requirements would apply only to kiosks installed at U.S. airports with 

10,000 or more enplanements per year.31

The Department is considering an alternative approach that would require all kiosk orders 

initiated 60 days or more after the effective date to comply with the proposed standards until at 

least 25 percent of the kiosks installed at each location in a given airport met these standards. 

This minimum percentage would need to be maintained thereafter as additional new or 

replacement kiosks are ordered and installed at each airport location. The benefits and costs of 

this alternative are compared with those of the baseline proposal in Sections 5.4 and 5.5 below.

 31 Our review of carrier Web site information on kiosk locations indicates that all or nearly all automated airport 

kiosks are located in large, medium, and small hub airports. We were not able to identify any small or very small 

U.S. carriers which market scheduled passenger service that currently offer the option to check in at either 

proprietary or shared-use kiosks. The benefits and costs associated with these proposed requirements would 

therefore be limited to passengers and flights operated by large carriers from large, medium, and small hub airports.
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5.3. Compliance Scenarios Evaluated

The proposed requirements specify that all kiosk orders initiated 60 days or more after the 

effective date of the rule would need to comply with the accessibility standards presented in the 

SNPRM text. From our understanding of the procurement process, it appears to be feasible for 

carriers and airports to meet this deadline. Based on our research and discussions with kiosk 

hardware and software vendors, it typically takes 4 to 6 months to execute a contract for new 

kiosk hardware to be produced and installed at specific airport locations after the technical 

details are specified (and these details can only be known after publication of the final rule). This 

is especially true for shared-use kiosks, which are ordered by airport authorities rather than 

carriers.32

For purposes of this evaluation, we have assumed that airport authorities would not have to “pull 

back” and revise kiosk procurements which had been initiated before the effective date of the 

rule. We therefore assume that all kiosk hardware ordered more than 6 months after the effective 

date of the rule date would comply with the proposed requirements. Installation of these 

accessible kiosks is assumed to begin 1 year to 18 months after the effective date of the rule.

However, it is more difficult to project the interval of time that will be required for compliant 

software applications to be developed, deployed, tested, and made operational on kiosks 

equipped with the accessible hardware features specified in the SNPRM. Our understanding is 

that this development process will not begin concurrently with the development of hardware 

specifications. Instead, hardware and middleware specifications will need to be finalized before 

development of accessible proprietary and shared-use applications can proceed in a productive 

fashion. In addition, an extended standards development process will be required to achieve 

consensus on a single set of shared-use technical standards that meet the proposed accessibility 

requirements. Based on the timetable for other IATA shared-use standards development 

activities, it would be reasonable to anticipate that the standards setting and applications 

development processes will take at least 1 additional year after the finalization of the hardware 

specifications before carriers can install and run fully developed and tested versions of compliant 

applications on accessible kiosk systems.33

For the baseline scenario we have assumed that all of the kiosks placed in service 1 year or later 

after the effective date of the rule would be able to able to accommodate compliant carrier 

applications. However, applications that are fully compliant with the proposed requirements are 

 32 This time interval can be divided into two approximately equal sub-intervals. During the first of these, the 

purchasing entity must develop specifications to supply its existing vendor (in the best case) or incorporate into the 

requirements specified in a solicitation (which typically involves a more extended procurement process). The 

remaining lead time is required for the kiosk vendors to determine how best to incorporate these hardware 

requirements into existing kiosk platforms (again, the best case) or alternatively, to design and implement 

modifications to existing kiosk models that would accommodate the required accessibility features.

33 During the time interval between the installation of new or modified kiosks with accessible hardware components 

and the deployment of carrier applications that support these components, travelers with disabilities will encounter 

“accessible kiosks” that do not work because they do not have the necessary applications installed. This may result 

in increased frustration among travelers with disabilities unless the reasons for this apparent failure to “turn on the 

accessibility features” are adequately publicized.
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not assumed to be deployed for an additional 12 months. At this point, as many as 20 percent of 

the kiosks in service (i.e. an average kiosk service life of 5 years) would be accessible.

As noted, the Department considered an alternative requirement that carriers and airports order 

accessible kiosks only until 25 percent of the units in any given location met the proposed 

standards. The discussion above suggests that this probably would not lead to a substantially 

different end result: the hardware design and production modifications would already be in place, 

and neither software developers nor their clients would have any incentive to remove or disable 

accessibility features from carrier applications.

5.4. Estimated Benefits of Proposed Requirements

The proposed requirements would make it possible for air travelers with certain disabilities, 

including those who use wheelchairs and those with severe vision impairments, to check in more 

quickly and easily when using an accessible automated kiosk, affording them the convenience 

and time savings currently experienced by persons without disabilities who choose to use an

automated kiosk. The number of travelers who can be expected to benefit depends on the number 

of trips taken annually by passengers with disabilities that would be addressed by the proposed 

requirements, the proportion of these passengers who would be able and willing to use accessible 

kiosks to check in, and the speed with which accessible kiosks would become widely available 

after the effective date of the rule. 

The estimated number of air travelers who would potentially benefit annually from the 

availability of accessible automated kiosks is calculated from the following components:

• The estimated number of check-ins annually by all passengers departing from U.S. 

airports, which is equal to the total number of departures (“segments”) divided by the 

average number of segments per one-way trip (1.37) and the average travel party size 

(1.4) to account for connecting flights and combined check-ins by travelers flying as a 

group, respectively.34

• The proportion of the adult population with disabilities that would make it difficult or 

impossible to use a non-accessible kiosk, which was assumed to be measured by the 

percentages of adults who use a wheelchair or other powered mobility assistance device 

and those who are blind or have severe trouble seeing (1.4 percent and 0.8 percent, 

respectively).

35

 34 The parameters used in these calculations are identical to those used in the April 2011 regulatory evaluation that 

accompanied the recently-published final rule on Enhancing Airline Passenger Protections (“EAPP2”). The number 

of trips can also be estimated using the BTS Origin and Destination (O&D) data on ticket purchases instead of the 

T-100 flight segments data. Both approaches yield similar results. 35 See the results presented in Section 2.1 above.
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• An adjustment factor (0.7853) derived from the BTS Freedom to Travel Study that takes 

into account that people with disabilities are somewhat less likely to travel by air in a 

given year than are people who do not have any disabilities.36

• The estimated share of travelers (approximately 20 percent) who are expected to use 

automated airport kiosks to check in during Year 1, based on data from the 2010 SITA 

Airline IT Survey results, which is assumed to remain stable until Year 5 and then decline 

by one percentage point annually thereafter.37

The calculations used to estimate the numbers of passengers who would benefit from the 

availability of accessible kiosks are summarized in the following table.

Table 12 - Number of Passengers Benefitting from Accessible Kiosks

Year 2 Years 1-10

Total check-ins by persons with disabilities

Total passenger flight segments 878,506,084 9,707,020,912

Average segments per one-way trip 1.37

One-way trips taken 641,245,316 7,085,416,724

Average travel party size 1.4

Estimated check-ins by air travelers 458,032,369 5,061,011,946

Percent of population benefitting from accessible kiosks* 2.2%

Ratio of disabled to general population air travel rates 0.7853

Total check-ins by travelers with disabilities 7,913,242 87,437,079

Number of total check-ins performed at accessible kiosks

Share of check-ins at airport kiosks 20% 19%

Percent of locations with accessible kiosks (Sec. 5.5) 35% 77%

Total check-ins using accessible kiosks 547,840 12,410,250

*Percent of adult population who use wheelchairs or have severe vision problems.

Sources: BTS T-100, 2009; ATA, 2008 in DOT, EAPP2 RIA, 2011; Census SIPP, 2005; BTS Freedom to 

Travel, 2002; SITA, Airline IT Trends Survey 2010. 

Under the baseline proposal in the accompanying SNPRM, an average of 1.2 million travelers 

with disabilities would be able to use accessible kiosks in each of the first 10 years after the 

effective date of the rule. There will, however, be a phase-in period during the first 5 years as 

accessible kiosks installations ramp up.

 36 As noted in the discussion in Section 2.3 above, this may be partially or entirely attributable to the fact that people 

with disabilities are older and have lower incomes on average than do people without disabilities, rather than to any 

specific impediment to travel posed by their disabilities.

37 ACI, Airline Business, and SITA, “The Airline IT Trends Survey 2010.” It is important to note that this estimated 

percentage is much lower than the corresponding estimate from the companion survey of airport operators. This is 

because the latter includes only check-ins at airport locations, while the estimate used in this analysis takes into 

account the rapid growth of online and mobile check-in options. Use of these offsite check-in options is projected to 

overtake all types of airport-based check-ins combined by 2013 (Year 1 of the analysis period).
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Air travelers who could use accessible kiosks would benefit from reduced check-in waiting 

times. Quantitative estimates of these benefits were developed for this evaluation. In addition, 

the availability of accessible kiosks will also remove the potential embarrassment some 

passengers with disabilities may feel when needing the assistance of an attendant at the kiosk. 

There also may be complementary benefits in the form of reduced waiting times for non-disabled 

passengers who are required or who choose to use the airline service counters for ticket purchase 

or check-in. Monetized estimates of these benefits were not developed for this evaluation.

For this analysis, we assumed that the time saved by the average passenger with a disability 

using an accessible kiosk would be similar to the time savings (13 minutes on average, relative to 

waiting in line for an agent) enjoyed when an inaccessible ATM or ticketing machine is replaced 

by an accessible machine.

38 The value of time saved per traveler from using an accessible kiosk 

is calculated by multiplying this average amount of time saved by the standard value of time 

($28.60) for air travel passengers specified in the applicable FAA guidance.39

While carriers will incur costs to purchase, install, and maintain accessible kiosks, they can also 

be expected to experience a reduction in per-person check-in costs, as more persons with 

disabilities use accessible kiosks instead of requiring the assistance of gate agents to check in. 

These benefits are calculated using the average carrier savings per passenger when using a kiosk 

to check in instead of going to the counter (estimated at $3.70 per transaction in a recent trade 

publication), multiplied by the number of passengers with disabilities who are projected to use 

accessible kiosks.40

Based on these estimates and assumptions, the combined benefits to air travelers with disabilities 

and to carriers from adoption of the proposed kiosk accessibility requirements are expected to be 

$5.4 million in Year 2 and $122.8 million for the entire 10-year analysis period.

 38 Estimated by a panel of experts for the Initial Regulatory Impact Analysis on the Revised Guidelines for the 

ADA, docket DOJ-CRT-2008-0016.

39 Economic Values for FAA Investment and Regulatory Decisions, A Guide, Contract No. DFTA 1-02-C00200, 

GRA Inc., Oct. 3, 2007. 40 Airport Business, “Analysis: Kiosk Uptime, Revenue,” July 8, 2008.
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Table 13 - Value of Passenger Time and Carrier Labor Cost Savings from Accessible Kiosks

Year 2 Years 1-10

Monetary value of passenger time savings

Disabled traveler check-ins using accessible kiosks 547,840 12,410,250

Hourly value of time savings, air travel $28.60 

Average time saved by using kiosk (minutes) 13

Monetary value of time savings per check-in $6.20 

Monetary value of time savings to disabled passengers $3,394,781 $76,902,182 

Value of reduced check-In costs

Per-passenger reduction in carrier costs $3.70 

Estimated reduction in labor costs $2,027,007 $45,917,925 

Total benefits (millions) $5.42 $122.82 

Discounted benefits (millions) $86.16 

*Present values for Year 1-10 benefits calculated using a discount rate of 7 percent.

It would be reasonable to expect that the estimated benefits may be somewhat lower if the 

Department were to require that only 25 percent of all kiosk orders after the effective date of the 

rule had to be compliant with the proposed standards. Waiting times for disabled passengers in 

kiosk queues would be somewhat longer on average than for non-disabled passengers during 

peak check-in periods under this alternative. However, it is not possible to quantify the 

difference between the benefits of this alternative and those estimated for the baseline proposal.

It should be noted that these estimates are preliminary in nature. In the accompanying SNPRM,

the Department is expressly seeking comments on certain inputs for this analysis, including:

• The estimated amount of time that a traveler with a disability would save by using an 

accessible kiosk (and whether the current estimate used needs to be scaled up or down 

due to unique circumstances at airports).

• The percentage of travelers with various types of disabilities who would be able and 

willing to use, and benefit from using, an accessible kiosk.

• The extent to which alternative methods of electronic check-in (online, mobile) may be 

more accessible or efficient for persons with disabilities to utilize, as well as the expected 

trend, if any, over time in the share of disabled travelers who can be expected to use these 

non-airport based check-in methods.

Information on the extent to which the proposed requirements would reduce carrier costs 

associated with gate agent handling of check-ins for disabled travelers is also expressly solicited.

Finally, it should be recognized that there are potentially important categories of benefits for 

which monetary values cannot be estimated from the available data, as well as those that are 

intrinsically qualitative. Among these are the following:
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• Increased independence. Accessible self-service kiosks would provide travelers with a 

greater range of check-in options. Travelers with disabilities could choose to use either 

the self-service option or the check-in counter, depending on the anticipated transaction 

time or individual’s personal preference. Having this choice available clearly has value to 

the traveler, but the monetary value of this choice cannot be quantified.

• Increased sense of inclusion. The availability of accessible kiosks will also remove the 

potential embarrassment some passengers with disabilities may feel when needing the 

assistance of an attendant at the kiosk. 

• Decreased overall waiting time. There may also be complementary benefits in the form 

of reduced waiting times for non-disabled passengers who are required or choose to use 

the airline service counters for ticket purchase or check-in. It was not possible to develop 

monetized estimates of these benefits for this evaluation.

• Less congestion at ticket counter area. Accessible kiosks would lessen the demands on 

customer service agents at the check-in counter. Customer service agents would be freed 

from the routine tasks of check-in and seat assignments and would have more time 

available to address individual ticketing and baggage issues. The net effect would be an 

increased level of customer service to the passengers who need special attention.

• Benefits to travelers with neither severe vision impairment nor disabilities requiring 

wheelchair use. Other travelers both with and without disabilities may benefit from the 

ergonomic design of accessible kiosks. For example, travelers who have difficulty 

reading English may benefit from having the ability to hear the kiosk instructions.

5.5. Estimated Costs of Proposed Requirements

Carriers and airports incur costs to purchase, install, and maintain automated airport kiosks and 

can be expected to continue to do so even in the absence of the requirements proposed in the 

accompanying SNPRM. Therefore, the total costs specifically attributable to complying with the 

proposed requirements are equal to the incremental life-cycle cost per current model kiosk to add 

the required accessibility features, multiplied by the number of kiosks required to be compliant.

The Department does not currently have an estimate of the number of automated kiosks installed 

in U.S. airports, as noted in Section 5.1. Based on the NCR-reported estimates of an installed 

base of 8,400 units worldwide at the end of 2009 and an 80-percent share of the U.S. airport 

market, it is reasonable to estimate there were approximately 11,000 automated kiosks in 

operation at the beginning of 2011. While both NCR and IBM have recently announced contracts 

for new installations, it seems clear that the continuing growth in online and mobile check-in will 

ultimately serve to limit future growth in the size of the airport kiosk market.
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There are varying estimates of the growth rate in recent years, but it appears that no more than 

500 new kiosks are being added to the installed base annually. The cost estimates in this analysis 

assume that the stock of automated kiosks continues to increase at the rate of 500 per year until 

the total installed base reaches 15,000 machines in Year 7. Based on these assumptions and a 5-

year average machine service life (from the 2010 ADA analysis cited above), the growth in the 

numbers of accessible kiosks is computed as follows:

Table 14 - Number of Accessible Kiosks Required/Installed

Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7

Automated airport kiosks

In use at start of year 12,000 12,500 13,000 13,500 14,000 14,500 15,000

Added 500 500 500 500 500 500 0

Replaced 2,500 2,500 2,500 2,500 2,500 2,500 3,000

In use at end of year 12,500 13,000 13,500 14,000 14,500 15,000 15,000

Number of accessible kiosks

Required 12,500 13,000 13,500 14,000 14,500 15,000 15,000

Already installed 0 1,500 4,500 7,500 10,500 13,500 15,000

Installations of accessible kiosks

New 250 500 500 500 500 500 0

Replacements of 

inaccessible kiosks 1,250 2,500 2,500 2,500 2,500 1,000 0

Replacements of 

accessible kiosks 0 0 0 0 0 1,500 3,000

Total installations 1,500 3,000 3,000 3,000 3,000 3,000 3,000

Total installed base 1,500 4,500 7,500 10,500 13,500 15,000 15,000

Percent accessible 12% 35% 56% 75% 93% 100% 100%

Note: Accessible kiosks are assumed to be deployed beginning 12 months after the effective date of the rule.

Carriers and airports will incur incremental compliance costs for accessible kiosks equal to the 

cost differences between a non-accessible kiosk and an accessible kiosk. Incremental hardware 

and software costs will be incurred to develop and produce accessible kiosks. The Department 

does not have any information to determine whether or not these costs would differ between 

proprietary systems owned or leased and operated by individual airlines and shared-use kiosk 

installations, which are shared by multiple airlines at an individual airport and are typically 

owned or leased by local airport authorities.

Based on conversations with kiosk vendors, the bulk of the incremental costs associated with 

making kiosk hardware, middleware, and software applications accessible are fixed—i.e., they 

do not vary appreciably with the number of units sold. For this preliminary analysis, we have 

estimated that these fixed costs would add $750 to the cost of each new or replacement kiosk 
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installed. The variable costs for kiosk hardware modifications (e.g., keypads, audio output jacks) 

represent no more than 10 to 20 percent of this amount.41

Based on a per-unit cost estimate of $750 and the numbers of accessible kiosks projected to be 

installed during Years 1-10, total compliance costs are estimated as follows:

Table 15 - Compliance Costs for Accessible Kiosks

Year 2 Years 1-10

Increase in accessible kiosks 3,000 15,000

Replacements of accessible kiosks 0 13,500

Total accessible kiosks required 3,000 28,500

Incremental cost of accessible kiosk $750 

Total cost of accessible kiosks $2,250,000 $21,375,000 

Discounted cost of accessible kiosks (millions) $15.78 

*Present values of Years 1-10 costs calculated using a discount rate of 7 percent.

Based on these estimates and assumptions, the costs incurred by carriers and airports to comply 

with the proposed kiosk accessibility requirements are expected to be $2.3 million in Year 2 and 

$21.4 million for the entire 10-year analysis period.

Costs would be lower on an undiscounted basis for the 10-year analysis period if the Department 

were to require only 25 percent of kiosks in any given airport location to be accessible. However, 

it is likely that the incremental per-unit cost of purchasing accessible kiosks would be higher 

under this scenario than if all new kiosks were required to be accessible, because the fixed 

hardware and software development costs incurred would be spread over a much smaller number 

of units sold.

The Department is expressly seeking comments on inputs into the analysis, including:

• The incremental cost difference between a new standard automated airport kiosk and a 

new accessible automated airport kiosk. 

• How often automated airport kiosks need to be replaced.

• The current number of automated airport kiosks in the United States owned by airlines 

and the current number owned by airports.

• Whether implementation of a requirement for accessible automated airport kiosks would 

significantly affect the cost, inventory, or delivery of accessible kiosks for any period of 

time after the effective date and, if so, for how long.

 41 This estimate is the midpoint of the range ($303-$1,193) of costs in a TRACE analysis of the modifications that 

would be required to produce an accessible kiosk. However, the modifications assumed in the TRACE analysis do 

not exactly match those that would be required to comply with the proposed standards in the accompanying 

SNPRM. This analysis also assumes that accessible kiosks do not have higher operations and maintenance costs or 

installation costs than standard kiosks and that costs are incurred the year the kiosks are ordered.
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5.6. Estimated Net Benefits and Discussion of Preliminary Results

Taking into account the benefits both to air travelers with disabilities and to carriers from 

adoption of the proposed kiosk accessibility requirements, as well as the incremental costs to 

carriers and airports to purchase and install the required number of accessible kiosks, the present 

value of net benefits from the proposed requirements are expected to be $70.4 million for the 10-

year analysis period using a discount rate of 7 percent and $86.2 million for the same time period 

using a discount rate of 3 percent.

Table 16 - Present Value of Accessible Kiosk Benefits and Costs

Discount Rate Used: 7 Percent 3 Percent

Total benefits (millions) $86.16 $104.85 

Total costs (millions) $15.78 $18.64 

Present value of net benefits (millions) $70.38 $86.21 

The present value of net benefits for the baseline scenario and the alternative 25-percent 

minimum requirement considered by the Department are likely to be similar. While incremental 

hardware costs would be lower if only 25 percent of new or replacement kiosks were required to 

be accessible, most of the costs associated with developing accessible kiosk hardware and carrier 

check-in applications would not be reduced. These fixed costs would simply be spread over a 

smaller number of accessible kiosks being installed. 

Finally, it is not clear that kiosk vendors and purchasers would continue to purchase nonaccessible kiosks once the accessible models become widely available. For example, if the 

shared-use standard is amended to incorporate accessibility considerations, it may actually be 

more costly to support and maintain two sets of carrier automated kiosk applications—one of 

which includes the accessibility features and the other of which does not—than to develop and 

support only a single accessible application. If this turns out to be the case for proprietary checkin applications as well, the requirements in either the baseline scenario or the alternative 

considered by the Department would ensure that all automated airport kiosks will be accessible 

at some future point in time.
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Table 17 - Kiosk Benefits, Costs, and Net Benefits by Year

Year 0 Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10 Years 1-10

Benefits

Disabled traveler 

check-ins using 

accessible kiosks 184,745 547,840 903,868 1,254,388 1,600,772 1,679,115 1,635,282 1,587,677 1,536,124 1,480,439 12,410,250

Benefits to 

passengers 

(millions) $1.14 $3.39 $5.60 $7.77 $9.92 $10.40 $10.13 $9.84 $9.52 $9.17 $76.90

Benefits to 

carriers 

(millions) $0.68 $2.03 $3.34 $4.64 $5.92 $6.21 $6.05 $5.87 $5.68 $5.48 $45.92

Total Benefits 

(millions) $1.83 $5.42 $8.95 $12.41 $15.84 $16.62 $16.18 $15.71 $15.20 $14.65 $122.82

Costs

Increase in 

accessible kiosks 1,500 3,000 3,000 3,000 3,000 1,500 0 0 0 0 15,000

Total costs 

(millions) $1.13 $2.25 $2.25 $2.25 $2.25 $2.25 $2.25 $2.25 $2.25 $2.25 $21.38

Net Benefits $0.70 $3.17 $6.70 $10.16 $13.59 $14.37 $13.93 $13.46 $12.95 $12.40 $101.45
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6. Evaluation of Proposed Requirements for Accessible Web Sites

6.1. Current Industry Practices and the Need for Regulatory Requirements

Air travelers increasingly rely on carrier and travel agent Web sites to research flight schedules 

and airfares, book and change reservations, and, in many cases, check in for flights before 

arriving at the airport. Air travel sites typically offer Web-only fare specials for flights and 

complete tour packages. Those with online booking engines (all but the smallest carriers and 

most of the larger travel agents and tour operators) provide prospective purchasers with the 

ability to search either directly or iteratively for the most attractive combinations of flight dates 

and times, connections, and fares. Many passengers with disabilities, including those with 

mobility impairments or hearing loss, are able to take full advantage of the information and 

services offered. However, travelers with vision-related disabilities, as well as those with motor 

skill disabilities that require the use of pointing devices other than a mouse, currently have much

more limited ability to obtain information or services on most carrier and ticket agent Web sites. 

At present, there are no statutory or regulatory requirements to ensure that carrier and ticket 

agent Web sites are accessible to consumers with these types of disabilities.42

As part of this regulatory evaluation, we conducted an extensive review of U.S. and foreign 

carrier Web sites. A summary of the results from this review is presented in an appendix, which 

also provides some background on the technical aspects of Web sites that are relevant for 

assessing the impact of the proposed requirements in this area. 

Among the air travel Web sites included in our review, only Delta Airlines appears to have a 

specific option that converts its default home page into a version adapted for screen readers and 

other technologies that make it more accessible for users with severe vision impairments. Other 

carrier and ticket agent Web sites afford different degrees of accessibility for air travelers with 

disabilities. Most of the home pages of the carrier Web sites we reviewed had violations of eight 

or more WCAG 2.0 accessibility guidelines and more than 50 separate issues that would need to 

be addressed to meet the Level AA compliance standards.43

Current Department regulations require carriers to offer Web-only fares and other promotions to 

disabled callers who indicate that they are not able to use an inaccessible Web site. However, 

carriers sometimes fail to do so, even when this regulatory requirement is specifically cited

during the course of the reservation request.44

 42 Note that our calculations of monetized benefits based on the requirements for Web sites are based on time 

savings by persons with severe visual impairments only. 43 Similar results have been reported in other research. See, for example, Jonathan Lazar et. al., “Up in the Air: Are 

Airlines Following the New DOT Rules on Equal Pricing for People with Disabilities When Web sites are 

Inaccessible?” Government Information Quarterly, 27(4), 329-336, 2010, and Léonie Watson and Emily Coward, 

“Is your Holiday All-Inclusive? Investigation into the accessibility of travel company websites,” Nomensa, June 

2011, for recent studies of U.S. and U.K. carrier Web sites, respectively.

44 Lazar et. al., op. cit., 2010.
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Mobile Versions of Carrier Web Sites

The Department does not have information on travel-related Web sites that make it possible for 

travelers with some types of disabilities to obtain information or services which are not 

accessible on other carrier or ticket agent sites. However, many of the largest U.S. carriers (9 of 

the 12 reporting carriers that market air travel to the general public) and a larger number of 

foreign carriers have one or more alternative versions of their Web sites designed to be accessed 

and read by browsers installed on mobile phones (including Blackberries, iPhones, and Androidbased smart phones) and, more recently, on tablets such as the iPad. These parallel sites 

eliminate or substantially simplify graphic menus and navigation, video, images, and template 

design features; they also offer access to at least selected parts of the information and 

functionality available on the primary versions of their Web sites.

Because these sites are optimized for less capable browsers and much smaller visual displays, 

they can typically be read much more quickly and efficiently by screen readers and other 

assistive technology. Content on these sites is, at least at present, predominantly text-based,

which reduces the processing capability required to translate visual navigation links, images, and 

electronic forms. Our review of the mobile version of carrier Web sites indicated that a screen 

reader can typically read the home page of a mobile site in 10 to 20 percent of the time required 

to completely read the home page of the primary version of the site. 

Table 18 - Mobile Site Adoption and Comparative Read Times

U.S. Foreign

Carrier sites checked

Reporting (over 1 mil. PAX for foreign) 12 7

Number with mobile sites 9 5

Percent with mobile sites 75% 71%

Non-reporting (< 1 mil. PAX for foreign) 6 7

Number with mobile sites 0 3

Percent with mobile sites 0% 43%

Screen reader read times (seconds)

Average full home page read time 189 171

Average mobile home page read time 30 19

Amount of time saved by using mobile page 159 152

Percent of time saved by using mobile page 84% 89%

Source: Econometrica, Inc., testing using aDesigner, May 12, 2011.

It is important to note that the increased reading speed and improved accessibility of mobile Web 

sites are at least partially attributable to the reduced amount of information and functionality 

offered in these versions. For example, the home page of a mobile site often includes only a text 

menu of selection options, but little actual content. A mobile Web site home page provides an 

attractive alternative for disabled (and nondisabled) site visitors who are seeking specific 

information (baggage fees, gate assignments) or are attempting to perform a common transaction 

(booking a flight, requesting flight status alerts). This option is less attractive for those who are 
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looking at travel Web sites but have less specific objectives for visiting and may be interested in 

scanning through a larger portion of the site’s content in a less directed manner.45

Our review of nine reporting carrier mobile Web sites shows that most offer a set of core 

functions, including the ability to check flight status, check in online, and book or change flights. 

Fewer sites have been expanded to the point where they offer more extensive access to general 

travel information, travel purchase terms and conditions, or the ability to purchase other travel 

services. Of the 12 reporting carriers that market air travel directly to the public, 3 did not appear 

to have mobile versions of their primary Web sites at the time of our review, nor did any of the 

24 other U.S carriers included in our Web site accessibility review.

Table 19 - Mobile Web Site Content for Reporting Carriers

Number Percent

Marketing carriers 12 100%

With mobile sites 9 75%

Mobile Web site content

Flight status 9 100%

Check-in 8 89%

View my itinerary 8 89%

Book/change reservations online 7 78%

Frequent flyer account 7 78%

Flight schedules 6 67%

Contact us/About us 6 67%

Updates & alerts 5 56%

Terms and conditions/Legal/Policies 3 33%

Travel Information (Gates and/or in-flight

services, etc) 3 33%

Sales & offers 3 33%

Car rental 1 11%

Source: Econometrica, Inc., review on May 16, 2011.

Carriers that already have mobile sites will expand them to offer a wider range of information 

and services, while most larger carriers that do not currently have mobile Web sites can be 

expected to develop them in the next few years. It is reasonable to anticipate the core functions 

identified in our review will be among the first capabilities available on new carrier mobile sites.

 45 It is also true that many online visitors to travel Web sites do not own current generation Smartphones that are 

capable of accessing the mobile versions. In the future, there will probably be fewer potential travelers who are able 

and interested in performing online transactions on primary Web sites who will not have a mobile device that can 

access an alternative version. See, for example, the recent SITA white paper, “Five Steps of Air Travel that 

Smartphones will Change by 2020,” New Frontiers paper, 2010. In any event, the URLs of most mobile versions of 

Web sites can be directly accessed on a traditional PC-based browser, such as Internet Explorer, Firefox, or Chrome.
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6.2. Proposed Requirements for Addressing Identified Needs

The Department is proposing to require that all U.S. and foreign carriers which market air travel 

to passengers in the United States ensure that the content on their primary Web sites are 

completely compliant with the WCAG 2.0 Level A and AA performance criteria within 2 years 

of the effective date of the rule.

Two interim benchmarks that would have to be met as well are:

• All new or completely redesigned carrier Web sites published online 180 days after the 

effective date or later would have to meet the WCAG 2.0 Level A and AA standards.

• Access to a set of core functions currently offered on the majority of reporting carrier 

mobile Web sites would have to be provided either through a link from those functions 

on the primary Web site to fully accessible corresponding functions on a mobile site or 

by making those functions accessible on the primary Web site by 1 year after the 

effective date.46

By 2 years after the effective date, carriers would also be required to ensure that their larger 

authorized ticket agents (travel agencies and tour operators) which market air transportation

online to the general public have accessible Web sites. Carriers would not need to ensure that 

travel agencies and tour operators that meet the SBA size standards established to define small 

businesses in these two industry sectors (annual revenues of less than $3.5 million and $7.0 

million, respectively) have accessible Web sites. However, carriers would still be required to 

ensure that these ticket agents make available all Web-based special fares or services upon 

request to customers who indicate that they could not use an agent’s inaccessible Web site due to 

their disability. The Department is also proposing to require carriers to continue to offer these 

special fares and services upon request to individuals who cannot use Web sites that meet the 

WCAG 2.0 Level A and AA standards for accessibility due to their disability and to ensure that 

their ticket agents do the same when customers cannot use the agents’ accessible Web sites due 

to their disability. While this regulatory evaluation includes the costs to ticket agents from the 

proposed requirement for carriers to ensure that their agents make their Web sites accessible, it 

does not address any costs incurred by agents in providing Web-based amenities to passengers 

who cannot access their Web sites due to a disability.

The Department intends to allow carriers to provide “alternative conforming versions” of 

inaccessible Web pages instead of requiring that all pages be accessible. Pages that qualify under 

this provision would have to offer the full information and functionality of the inaccessible 

versions of these pages. For this evaluation, we have assumed that Delta’s dynamicallygenerated Web site pages would meet this requirement, but that very little if any mobile Web site

content would qualify under this standard.

 46 Contract carriers and charter carriers that do not market air transportation directly to the general public would also 

have to comply with the proposed requirements but would not need to provide accessible versions of core functions 

that they do not otherwise offer. For example, the Web sites for many very small U.S. carriers do not offer online 

booking or check-in services.
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6.3. Compliance Scenarios Evaluated

To assess the benefits and costs associated with these proposed requirements, it is first necessary 

to define the ways in which carriers and their ticket agents may be reasonably anticipated to 

achieve compliance with each of the three tiers of standards proposed for air travel Web sites. To 

facilitate the exposition in the remainder of this evaluation, the 6-month, 12-month, and 2-year 

sets of proposed requirements are referred to as Tier 1, Tier 2, and Tier 3 standards, respectively.

For this analysis, we have made the following assumptions:

Tier 1 (6 months after effective date)

All carriers that market air transportation directly to the general public already have Web sites, 

but the proposed Tier 1 requirements would require accessibility for new or “completely revised” 

sites published 6 months or more after the effective date of the proposed rule. Reporting carriers 

appear to undertake significant “facelifts” of their sites at intervals between 2 and 4 years, based 

on review of screenshots of selected carrier home pages viewed using the “Wayback Machine” at 

www.archive.org. Assuming the same revision interval is also true for large carriers, as many as 

half could be expected to undertake complete revisions of their Web sites during the 18-month 

interval between the proposed compliance dates for the Tier 1 and Tier 3 requirements. These 

carriers would have to ensure that their primary sites are fully accessible before having them “go 

live.”

Smaller U.S. carriers appear to overhaul their Web sites less frequently than do larger carriers –

typically once every 4 to 5 years, based on a review of screenshots from www.archive.org. We 

assume that one out of every three small and very small U.S. carriers would completely revise 

their Web sites during the interval between the dates on which the Tier 1 and Tier 3 standards 

would take effect.

The interval of 6 months between the effective date of the rule and the Tier 1 compliance date 

appears to provide sufficient time for carriers to be able to take the proposed accessibility 

guidelines into account when they undertake Web site overhauls that begin after rule 

publication.47 Carriers with Web site overhauls already under way at the time of rule publication 

would be expected to complete these projects and publish their new sites on a date before 

compliance with the Tier 1 standards would be required.

Carriers would not be required to ensure that their ticket agents’ Web sites would meet the 

proposed accessibility standards until 2 years after the effective date of the rule. The largest 

online travel agents and tour operators are likely to incorporate accessibility into site overhauls 

or new site launches expected to take place after the Tier 1 requirements go into effect.

Tier 2 (12 months after effective date)

It is reasonable to anticipate that most large U.S. and foreign carriers will already have one or 

more mobile Web sites by the date of rule publication. Those that do not would have a strong 

incentive to accelerate development and publication of a mobile site by the time the Tier 2 

 47 Web site design timelines available on the Internet are often based on start-to-finish implementation times 

between 4 and 6 months.
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standards would take effect.48 Relatively modest revisions would be required for the core 

functions on these mobile sites to be made compliant with the proposed accessibility standards.

Nearly all small and very small U.S. carriers that market scheduled air transportation directly to 

the public operate flights exclusively in Alaska, Hawaii, or among islands in the Pacific or 

Caribbean. These carriers typically have not developed and published mobile versions of their 

primary Web sites, and they may not do so by the rule publication date. However, the majority of 

these carriers operate relatively simple primary Web sites that do not offer online booking, 

check-in, or flight status updates. Comparatively fewer revisions would be required to make the 

more limited set of core functions currently offered on these small and very small carrier sites 

compliant with the proposed accessibility standards.49

Carriers that publish completely revised primary Web sites after compliance with the Tier 1 

standards is required will already have satisfied the Tier 2 requirements. In addition, some 

carriers that are in the process of overhauling their primary Web sites when the Tier 2 

requirements take effect may have drafts of new Web pages (“beta” versions) available that 

would meet the “alternative conforming version” standard for determining whether a particular 

core function on the primary Web site was accessible.50

Tier 3 (2 years after effective date)

Carriers would be required to have their entire primary sites comply with the full set of proposed 

standards by 2 years after the effective date of the rule. By this time, we have estimated that 

about one-half of the larger carriers and about one-third of smaller carriers would have already 

undertaken overhauls of their primary Web sites that would make them compliant with the Tier 3 

standards. The remaining carriers would either need to retrofit their existing sites or develop 

alternative conforming versions that comply with the proposed accessibility standards.

Retrofitting for accessibility is generally more complicated and costly than building it into new 

designs. Thus, it is possible that those carriers which would not otherwise have redesigned their 

Web sites may be prompted to do so in conjunction with the evaluation and programming 

required to achieve compliance with the WCAG 2.0 Level A and AA guidelines. The 

Department is not able to determine the extent to which carriers with inaccessible Web sites may 

decide to undertake overhauls they would not otherwise have done as an alternative to 

retrofitting the current versions of their primary Web sites to comply with the Tier 3 standards.

Alternative Scenarios Evaluated

In addition to the baseline scenario developed to evaluate the proposed requirements, we have 

also examined the benefits and costs associated with two alternative scenarios:

 48 According to the 2010 SITA Airline IT Trends survey, 70 percent of airlines plan to be able to see tickets on 

passengers’ phones by 2013 (Year 1 of the analysis period), up from 18 percent who currently have this capability.

49 Charter carriers and contract carriers that operate scheduled service flights for marketing carriers are also not 

expected to have to undertake significant revisions to comply with the Tier 2 standards because their Web sites 

typically do not offer most of the core functions included in the proposed requirements.

50 This would be true for the “beta” versions that provide most or all of the information and functionality of the 

current published versions of the same pages.
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• Mobile Site Alternative. It is considerably easier to ensure that mobile versions of Web

pages comply with applicable accessibility guidelines than it is to achieve the same level 

of performance for the same pages of the primary Web site. One possible alternative 

approach would be to exempt a carrier’s primary Web site from meeting the proposed 

accessibility standards, as long as it publishes and maintains a synchronized mobile site 

that is fully accessible and includes all of the core functions and information specified in 

the Tier 2 standards. While the core functions itemized in the Tier 2 standards do not 

include all of the content currently available on some mobile Web sites, it is reasonable to 

anticipate that carriers would make the remaining pages of their mobile sites accessible as 

well.51

• Elimination of Tier 1 and Tier 2 Standards for Small and Very Small Carriers. Small 

and very small carriers typically do not have mobile version of their primary Web sites 

and undertake complete overhauls of their sites less frequently. Under this alternative, 

small and very small carriers would not be required to comply with the Tier 1 and Tier 2 

standards, although their primary Web sites would have to meet the WCAG 2.0 

guidelines by 2 years after the effective date of the rule.

The Department lacks adequate information to evaluate the benefits or costs of some other 

possible alternatives. Among these would be requiring carriers to meet only the WCAG 2.0 

Level A success criteria and ensure that their ticket agents do the same. This alternative was not 

analyzed because we could not determine the extent to which this reduced level of accessibility 

would limit the ability of site visitors with relevant disabilities to access information and services 

of interest. Another alternative of potential interest would be to require all carriers to make the 

core functions in the Tier 2 standards accessible on their primary Web sites by 12 months after

the effective date of the rule. However, we do not have adequate information or technical 

expertise to be able to determine the extent of retrofitting that would be required to make a 

primary Web site partially compliant with the WCAG 2.0 guidelines. We are also unable to 

determine if this option would provide additional benefits from having access to more

information and services than are available on the mobile versions of these pages or instead 

would reduce the projected benefits because of user frustration with navigating sites with a mix 

of accessible and inaccessible pages.

6.4. Estimated Benefits of Proposed Requirements

The proposed requirements would permit travelers with disabilities to benefit from increased 

access to the full range of information and services available to online customers:

• Access to the lowest airfares and other Web-only discounts and promotions, as well as 

expanded capabilities to search for more convenient flight dates, times, and connections.

• More efficient and sometimes less costly ways to conduct routine transactions, such as 

prepaying baggage fees and checking in online.

 51 Under this alternative, the primary Web site would have to have a link to the accessible mobile site that could be 

accessed from any Web pages on which any component of the core set of information and services was offered.
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• Easier access to personal and general air travel information and policies, including trip 

itineraries and flight status inquiries, frequent flyer accounts, and relevant air travel 

policies and restrictions. 

Monetizing the value of these benefits directly is difficult, particularly in light of the documented 

willingness of travelers with vision-related disabilities to persist in accomplishing tasks online 

even when confronted with obstacles posed by inaccessible Web sites and conflicts between 

Web site technologies and screen readers.52 Removing or reducing these barriers to access would 

reduce the amount of time it would take for travelers with disabilities to realize the reduced 

expenditures, more efficient transactions, increased availability of information, and other 

benefits associated with access to air travel Web sites. The estimated benefits to travelers based 

on time saved associated with being able to use accessible air travel Web sites depend on several 

factors, including:

• The number of current and future air travelers who use screen readers and other adaptive 

technologies to access carrier and/or ticket agent Web sites.

• The extent to which these customers would utilize accessible air travel Web sites.

• The amount of time that could potentially be saved annually by the typical traveler who 

benefits from the availability of accessible Web sites.

• The monetary value of each unit of time saved.

The estimated amount of time saved from the availability of accessible air travel Web sites is 

based on the following:

• The number of potential beneficiaries is estimated by multiplying the Survey of Income 

and Program Participation (SIPP) estimate of the U.S. population with severe vision 

difficulties (1.78 million in 2009, with the population growing in each subsequent year by 

the forecast FAA growth rates for domestic passengers) by the BTS estimate of the 

percentage of people with disabilities who have traveled by air in the past year (31.5 

percent) and the proportion of persons with disabilities who are online (46 percent in 

2010, according to the 2011 Pew Internet and American Life study, and increasing by 2 

percent in each subsequent year).

• For this analysis, we have assumed that an average of two Web sites are searched prior to 

booking a trip online and that each trip booked online generates two additional visits to 

the site on which the air travel was booked for subsequent transactions and to obtain 

flight-related information. These assumptions are conservative because they do not take 

into account site visits by future travelers who are just “looking around” or are in the 

early stages of planning a trip.

 52 Jonathan Lazar et. al., “What Frustrates Screen Reader Users on the Web: A Study of 100 Blind Users,” 

International Journal of Human-Computer Interaction, 22(3), pp. 247-269, 2007. 
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• For this analysis, we have assumed that, on average, three pages are viewed during each 

visit to an air travel Web site. According to Web analytics provider OneStat.com, more 

than half of all site visitors view only one or two pages per visit.53 For online booking, a 

minimum of five page views are typically required, even if the initial search yields a 

suitable option. In addition, a larger number of page views may be required for air travel 

Web site visitors with vision-related disabilities if the screen reader is not able to translate 

inaccessible menus, links, and other navigation elements. 

• Our review of carrier Web site home pages found that it takes a screen reader, such as 

JAWS or Window-Eyes, an average of 3 minutes to read through a typical carrier Web 

site home page. In contrast, site visitors with broadband connections and without visionrelated disabilities can take advantage of near instantaneous loading of the same page. 

Our review of mobile carrier sites indicated that the typically much more compact home 

pages of these sites usually take 80–85 percent less time (about 20 seconds) for a screen 

reader to convert to speech output than do the primary Web site home pages for the same 

carriers.54

• The Lazar et al. study cited above concluded that the typical blind Web user loses 30.4 

percent of the total time spent online to frustrations associated with inaccessible Web

content and Web site technology conflicts with screen readers. 

The product of these estimates represents the total amount of time saved by travelers with 

relevant disabilities due to using fully accessible air travel Web sites. Each hour of time saved is 

valued at $28.60, which represents the weighted average of the values currently recommended 

for cost-benefit studies of travel time savings accruing to travelers for business and personal 

reasons.55 For this analysis, separate benefits estimates were calculated for the Tier 2 and Tier 3 

standards.

56 Benefits are calculated under the assumption that travelers with disabilities continue 

to visit air travel Web sites that have been made accessible and those that continue to be 

inaccessible in the same proportions as they would have had they all remained inaccessible.57

 53 OneStat.com, “Most people visit 1 or 2 pages during a visit according to OneStat.com,” September 18, 2007. 54 This does not, of course, exactly measure the amount of time a typical user with a vision-related disability would 

spend on the home page. Some visitors would be able to identify the link or menu item of interest quickly and 

proceed to the next page or site before the entire home page is translated. Others will need to hear the entire page 

translated and then review content or information on that page before deciding where to go next. For this 

preliminary evaluation, we have not attempted to determine which of these two countervailing factors is 

quantitatively more significant.

55 Economic Values for FAA Investment and Regulatory Decisions, A Guide, Contract No. DFTA 1-02-C00200, 

GRA Inc., Oct. 3, 2007.

56 We did not compute separate benefits estimates for visitors to new or completely revised carrier Web sites that 

would need to comply with the Tier 1 standards. In any event, incremental benefits would accrue only until the Tier 

2 and Tier 3 standards take effect, so this omission does not materially affect the estimated total benefits to persons 

with disabilities from the availability of accessible Web sites.

57 This “no-migration” assumption was used to develop preliminary estimates of the amount of time saved. A more 

reasonable expectation is that there will be substantial shifts in Web site visitation habits among travelers with 

vision-related disabilities as more new or completely revised accessible air travel Web sites are published. In this 

case, the ultimate future benefits from achieving complete accessibility of all air travel Web sites will be realized 

more rapidly than estimated in the “no-migration” scenario. However, because all covered air travel Web sites 

would be required to meet the proposed accessibility standards within 2 years of the effective date of the rule, the 
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While carriers will incur costs to develop, publish, and maintain accessible Web sites, they can 

also be expected to experience a reduction in the number of calls to customer service 

representatives from persons with disabilities who are unable to conduct transactions or locate 

information online. These benefits are calculated using the average savings per avoided call 

(estimated at $5.50 per call in a market research study), multiplied by an assumed share of 50 

percent of the passengers with disabilities who are projected to use accessible Web sites.58

The estimated benefits for each tier of standards were computed as shown in the following 

tables:

Table 20 – Annual Time Savings from Proposed Tier 2 and Tier 3 Requirements

Tier 2* Tier 3**

Amount of time currently spent on inaccessible Web sites

Number of sites visited per year 4 4

Number of pages viewed per site 6 6

Average minutes spent per page 3 3

Annual hours spent on travel Web sites 1.2 1.2

Time saved by accessible and mobile Web site availability

Percent of time saved by accessibility 30.4%

Percent of time saved by mobile version 85%

Annual time saved per site visitor (hours) 1.0 0.4

*Assumes 1/2 of total page views are of pages made accessible in Tier 2 standards.

** Benefits accrue only for pages that have not already been made accessible.

 quantitative significance of this simplifying assumption on the discounted present value of estimated benefits is 

relatively small.

58 Forrester Research, “Need To Cut Costs? Improve The Web Site Experience,” December 1, 2008.
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Table 21 - Estimated Benefits from Proposed Tier 2 and Tier 3 Requirements

Year 2 Years 1-10

Estimated number of beneficiaries

Blind/severe visual impaired, aged 15+ 2,001,197 22,112,151

% traveling by air in past year 31.5%

% visiting online travel sites 54% 61%

Total site visitors who benefit 340,404 4,280,547 

Time saved per person annually* 1.2 1.3

Value of time saved per hour $28.60

Total benefits to site visitors (millions) $11.71 $159.78

Estimated benefits from call center savings

% of site visitors who call due to disability 50%

Total number of avoided calls 170,202 2,140,273 

Cost savings per avoided call $5.50

Total cost savings from avoided calls

(millions) $0.94 $11.77

Total benefits (millions) $12.64 $171.55 

Discounted benefits (millions)** $122.11 

*The 10-year analysis period estimate of 1.3 hours time saved annually is equal to 

the weighted average of 0.5 hours in Year 1 (one-half of the Tier 2 estimate shown in 

Table 20), 1.2 hours in Year 2 (all of the Tier 2 estimate, plus one-half of the Tier 3 

estimate from Table 20), and 1.4 hours in each of Years 3 through 10 (reflecting the 

combined savings from full compliance with the Tier 2 and Tier 3 requirements).

**Present values of Year 1-10 benefits calculated using a discount rate of 7 percent.

Based on these estimates and assumptions, total benefits from the proposed Tier 2 and Tier 3 

standards are estimated at $171.6 million for Year 1 through Year 10. The present value of 

benefits realized during the entire 10-year analysis period is estimated at $122.1 million using a 

discount rate of 7 percent.

The timetable under which the estimated benefits would be realized is somewhat complicated:

• The benefits calculated for the Tier 1 requirements begin to accrue 6 months after the 

effective date of the rule (i.e. the beginning of Year 1 in this preliminary analysis) as the 

first overhauled carrier Web sites that meet the proposed accessibility standards are 

published. These benefits increase in the second year after the effective date of the rule as 

more sites are made accessible to comply with the Tier 1 requirements. However, the 

incremental benefits of the Tier 1 standards would be much smaller once compliance 

with the Tier 2 standards is required (1 year after the effective date of the rule), and no

incremental benefits would accrue from this provision once compliance with the Tier 3 

standards is require (2 years after the effective date of the rule).

59

 59 It should be noted that the benefits from the Tier 1 requirements would continue to accrue if the Tier 3 standards 

were postponed or eliminated. At some point in time all (or nearly all) active carriers and ticket agents would be 

expected to undertake a Web site overhaul that would trigger the Tier 1 requirements. The annual benefits realized 

under either the Tier 1 or Tier 3 standards would be equal from that point forward, since all carrier and ticket agent 
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• The benefits from the Tier 2 requirements begin to accrue 12 months after the effective 

date of the rule, assumed to be halfway through Year 1 in this preliminary analysis. In 

addition to the time saved by accessibility, travelers with disabilities will realize 

additional benefits from compliant mobile Web sites that offer more rapid access to the 

core functions most commonly used by air travelers.

• Benefits from the Tier 3 requirements begin to accrue 2 years after the effective date of 

the rule, assumed to be halfway through Year 2 in this preliminary analysis. However, the 

incremental benefits from the Tier 3 requirements are limited to the time saved while 

viewing pages that have not already been made accessible as a result of primary Web site

overhauls (Tier 1) or provision of core functions on accessible mobile Web sites (Tier 2).

Notwithstanding these timing issues, the annualized benefits estimated in Table 19 for (Tiers 2 

and 3 combined) would be fully realized in the third and each successive year of the 10-year 

period used in this analysis. Benefits in the first year after the effective date of the rule are 

expected to be minimal, because relatively few carriers that undertake primary Web site

overhauls which would be subject to the Tier 1 standards would be able to have these compliant 

sites available by 12 months after the effective date of the rule. The impact of the timeline 

considerations discussed above is therefore limited primarily to the benefits estimates for the 

second year in the 10-year analysis period. Consequently, we did not attempt to estimate the 

incremental benefits from the Tier 1 standards that would be realized in the first 2 years after the 

effective date of the rule. Adopting this simplifying assumption does not have a material impact 

on the overall benefits estimates.

Additional Benefits from Accessible Web Sites

In addition to the monetary value of the time saved from Web site accessibility, there is a 

separate and distinct value associated with the reduced amount of frustration experienced by 

users during the time that they continue to spend on air travel Web sites. Although we did not do 

so for this preliminary evaluation, the value of this benefit could potentially be monetized. 

Travelers with disabilities will also benefit from an increased sense of independence as a result 

of being able to conduct a standard transaction or obtain travel information without assistance, 

although it is not possible to estimate a monetary value for this benefit.

Carriers and ticket agents may also benefit from adding travelers with disabilities to their 

passenger base and reducing direct customer service assistance costs associated with researching 

and booking flights, conducting post-purchase transactions, and responding to flight and general 

travel information requests.

This preliminary analysis estimates the amount of time saved only for people who are blind or 

have severe difficulty seeing. Additional benefits may be realized by those with less severe 

vision impairments, as well as those who find navigating and finding information on current 

Web sites difficult for other reasons (such as those who cannot use a mouse). Notwithstanding 

 Web sites covered by the proposed accessibility requirements would have been overhauled at least once since the 

Tier 1 standards took effect. In this analysis we have treated these benefits as accruing under the Tier 3 standards for 

simplicity.
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the conservative nature of these estimates, the monetized benefits of the proposed requirements 

are substantial—more than $14 million in the first year after air travel Web sites become fully 

compliant with the WCAG 2.0 accessibility standards.

Impact on Estimated Benefits for Possible Regulatory Alternatives

As noted above, most carriers’ mobile Web sites do not provide the full range of information and 

functionality that is available on the same carriers’ primary Web sites. Even on pages that 

provide core information and services, the primary Web pages may offer additional search and 

results display options, more extensive sets of navigation menus and links to other pages, and 

more embedded multimedia content. However, the information and functionality that is provided 

on mobile sites can be accessed much more rapidly.60

It is not possible to quantify the impact on the benefits to travelers with disabilities that would 

result from permitting carriers and ticket agents to provide accessible links to fully accessible 

mobile Web sites instead of requiring that they make the primary versions of their Web sites 

fully accessible. Site visitors with disabilities who value the information or functionality that 

would not be available on a carrier’s accessible mobile site would realize fewer benefits under 

this alternative set of possible requirements. Those who would be interested in performing 

particular tasks or locating specific information available on the mobile site may be made better 

off under this alternative, especially because the scope and capabilities of mobile Web sites and 

the proportion of travelers using mobile devices as their primary means of Internet access are 

both expected to expand significantly in the next few years.

Benefits that would be realized if only the Tier 2 requirements were adopted can be estimated. 

The monetized value of benefits in this scenario is estimated at $120 million for Years 1-10 of 

the analysis period . The present value of benefits realized during the 10-year analysis period 

from the Tier 2 requirements alone is estimated at $86 million using a discount rate of 7 percent. 

These estimates are $40 million and $28 million lower, respectively, than the undiscounted and 

discounted benefits estimated for the baseline scenario evaluated.

Exempting small and very small carriers from the proposed Tier 1 and Tier 2 requirements can 

be expected to have a modest, transitory impact on benefits. While these carriers account for 

only a small percentage of the passengers on all scheduled departures, in many cases, they serve 

communities that are not serviced by any of the larger carriers (most operate routes exclusively 

in Alaska, Hawaii, or islands in the Pacific or the Caribbean). Under this alternative, residents of 

these communities with vision-related disabilities would not be able to use the relevant carrier 

Web sites until they are made fully accessible under the proposed Tier 3 standards 2 years after 

the effective date of the rule.

Unquantifiable Benefits

As noted in the discussion above, there are potentially important categories of benefits for which 

monetary values cannot be estimated from the available data, as well as some that are 

intrinsically qualitative, including:

 60 In addition, some of the navigation elements, links, and content on primary web pages may be included for 

reasons (e.g., search engine optimization) that do not provide measurable direct benefits to site visitors.
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• Improved accessibility for people with other disabilities. Making Web pages meet 

WCAG 2.0 AA standards would help users with disabilities other than severe vision 

impairment. A Web site with a cleaner layout and less content per page may be more 

readily usable by travelers with less severe vision disabilities, cognitive disabilities, or 

epilepsy.

• Increased air travel by persons with disabilities. Making carrier Web sites accessible 

may remove a barrier to travel for independent people with severe vision impairments, 

making it somewhat more likely they will travel and increasing the number of trips 

purchased.

• Reaching more consumers without disabilities. A growing segment of the population 

uses a mobile platform, such as a tablet or Smartphone, as the primary means of Internet 

access. Implementing or expanding a mobile Web site to ensure accessibility would 

improve a communication channel that is relevant for existing and potential new 

customers without disabilities.

• Decreased carrier customer service costs. When a traveler is away from a computer, a 

complete, easy-to-navigate mobile Web site is less likely to result in calls to the carrier 

and in-person requests for information or customer service.

• Passenger convenience. Air travel requires many passengers to leave home hours before 

their scheduled flight; typically, their primary means of Internet access en route to and at 

the airport is a mobile phone. Similarly, on the return leg of their journey, mobile phones 

are likely to serve as passengers’ main form of access to the Internet. By having a fully 

functional mobile Web site, carriers will increase the ability of their passengers to check 

flight status, check in, and perform other functions that make air travel easier and more 

convenient.

• Better internal understanding of Web sites. A detailed Web site inventory would 

improve the publisher’s ability to understand and clean up existing errors and 

performance issues. For example, our review of carrier Web sites turned up many 

instances of broken links, circular references, and, in one case, hidden links to gray 

market pharmacy Web sites.

• Reputation. In addition to the more tangible benefits of a well-developed mobile Web 

site, providing this capability is increasingly regarded as a sign of a modern, successful 

company. Carriers’ corporate images may be improved by rolling out well- designed 

mobile Web sites to meet the proposed accessibility requirements.
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6.5. Estimated Costs of Proposed Requirements

Carriers and ticket agents may benefit from adding travelers with disabilities to their passenger 

base and reducing direct customer service assistance costs associated with researching and 

booking flights. However, complying with the likely requirements for Web site accessibility will 

cause carriers (and their agents) to incur costs associated with making it possible for visuallyimpaired users to read Web sites using commercially-available software. Carriers and their 

agents will face direct, indirect, and opportunity costs for increasing Web site accessibility. 

There are direct costs associated with programming and site redesign for greater accessibility, 

indirect costs related to program management and training, and potential opportunity costs in 

applying technical resources toward accessibility rather than other Web-based business strategies 

(e.g., social networking).

Compliance costs for ensuring Web site conformance with applicable accessibility standards will 

depend on several factors:

• The number and complexity of pages included on the current Web site

• The type of technology used (e.g., HTML, PHP, asp.net)

• The extensiveness of the revisions required to achieve conformance

• The current Web site development and maintenance staff or contractor’s level of 

expertise and training in accessibility issues.

Based on our review of the W3C Website Accessibility Initiative (WAI) site and other online 

programming guides, it is clear that the time involved to “retrofit” existing Web pages is much 

larger than that associated with ensuring new pages comply with accessibility guidelines. In fact, 

many experts regard many of the requirements to ensure accessibility as merely good 

programming practices that should be more consistently followed by Web developers in any 

event.61

This preliminary analysis includes compliance cost estimates for one-time revisions of the 

current carrier and ticket agent Web sites. Work required to revise non-accessible sites would 

include, but not be limited to, the following tasks:

• Review and assessment of current Web site features that require remediation

• Development of a compliant site design template and style sheet

• Revision or alternative programming of JavaScript-based menus and navigation

• Creation of alternative displays for site graphics, images, and video material

• Development of alternative versions of forms and scripts

• Conformance verification, evaluation, and certification.

The training and expertise in accessibility issues of carrier and ticket agent Web development 

teams for affected carriers and ticket agents will vary, but no provision for training or outside 

 61 See, for example, the technical factors listed by W3C in the Website Accessibility Initiative site section on 

building a business case for accessibility, available at http://www.w3.org/WAI/bcase/tech.html.
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consultants (other than for conformance evaluation and certification) is included in these 

estimates.

Separate compliance cost estimates were developed for mobile Web sites (to meet the Tier 2 

requirements) and primary Web sites (to meet the Tier 3 standards). Actual Tier 3 costs will be 

somewhat lower than estimated here, to the extent that carriers are able to incorporate 

accessibility into overhauled sites covered by the interim Tier 1 standards instead of having to 

retrofit their existing primary sites. However, the quantitative significance of this factor is 

limited by the relatively short time period between the dates on which compliance with the Tier 1 

and Tier 3 standards would be required.

Tier 2 Compliance Costs

Because most mobile Web sites are smaller and less complex than primary Web sites, 

substantially fewer revisions would be required to make these sites fully compliant with the 

WCAG 2.0 accessibility standards. For this preliminary analysis, we developed estimates of the 

costs for making typical mobile sites fully accessible, based on the assumption that carriers 

would find it easier to make the entire mobile site conformant instead of limiting the revisions to 

the pages containing information or services included in the proposed list of core functions. 

Estimated costs would be only slightly lower if the revisions were limited only to pages relating 

to these core functions.

Compliance costs were calculated using the following assumptions and estimates:

• The typical mobile site for a very large or large carrier is assumed to have one-third as 

many pages as the primary Web site. Mobile sites for small and very small carriers are 

assumed to have one-half as many pages as the primary versions of these carriers’ Web 

sites.62

• The fixed time costs for conformance evaluation and certification and for overall site 

layout and revision of the home page are assumed to be 20 percent of the hours required 

to perform the same functions for primary Web sites of the same size. The incremental 

cost of reviewing and revising each additional page is assumed to be 50 percent of the 

time required to revise a page on the primary Web site.

• Per-hour programming costs, including corporate or contractor overhead, are assumed to 

be $150 per hour for revisions of very large and large carrier mobile sites and $120 per 

hour for revisions of small and very small carrier sites.

Based on these preliminary assumptions and estimates, the costs to make mobile Web sites fully 

accessible are calculated as follows:

 62 Reporting carriers are classified as very large carriers; other U.S. carriers are classified according to the number of 

seats on the largest aircraft used to provide passenger service. Foreign carriers were apportioned into the four size 

classes based on the annual number of passengers flown to and from the United States.
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Table 22 - Estimated Web Site Revision Costs to Comply with Tier 2 Requirements

Carrier Size Class

Very Large Large Small Very Small

Average number of pages 300 100 60 30

Programming/review hours required*

Conformance 

evaluation/certification 60 40 30 20

Site layout and home page 60 40 30 20

Each site page 0.5 0.5 0.5 0.5

Total hours required 270 130 90 55

Cost per hour 

(programming/overhead) $150 $150 $120 $120

Cost per site $40,500 $19,500 $10,800 $6,600

Number of sites requiring revision**

U.S. carriers 12 6 6 27

Foreign carriers 15 36 36 2

Total number of sites 27 42 42 29

Total revision costs

U.S. carriers $486,000 $117,000 $64,800 $178,200

Foreign carriers $607,500 $702,000 $388,800 $13,200

Total Tier 2 revision costs $1,093,500 $819,000 $453,600 $191,400

Total costs (millions) $2.56

Discounted costs (millions)*** $2.65

*Assumes all covered carriers provide accessible mobile sites in lieu of making full versions 

accessible to comply with the Tier 2 requirements.

**Excludes contract carriers and charter carriers which do not market air transportation to the 

general public.

***Assumes 50 percent of compliance costs are incurred in Year 0 and 50 percent in Year 1. The 

Year 0 costs are rolled forward to Year 1 using a 7 percent inflation rate.

Estimated compliance costs associated with the Tier 2 requirements are relatively small—about 

$2.6 million divided among 140 U.S. and foreign carriers. This estimate does not include any 

costs that may be incurred by contract carriers or charter carriers. These carriers typically publish 

very small Web sites that provide limited information and functionality in the specified core 

function areas.

It should be noted that this estimate also does not include additional costs for carriers to plan, 

design, and develop the layout and content of new mobile Web sites that may be launched 

between the rule publication date and the date on which compliance with the Tier 2 standards 

would be required. While it is true that carriers could avoid offering the required core functions 

on an accessible mobile site by ensuring that these capabilities are fully accessible on their 

primary Web sites, it is unlikely that the latter option would be less costly. In addition, 

developing and publishing a mobile site is likely to be necessary, as an increasing share of both 

disabled and non-disabled air travelers use mobile devices as their primary means of accessing 

the Internet.
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Tier 3 Compliance Costs

Costs for carriers to make their primary Web sites compliant with the Tier 3 requirements were 

calculated using a similar approach. The average number of pages to be revised was extrapolated 

from the results of our carrier Web site review. The fixed and per-page time requirements for site 

revisions are preliminary estimates and depend on the extensiveness, programming, and 

accessibility of the carriers’ current sites. We found substantial cross-carrier variation in current 

Web site technology across these dimensions. Per-hour programming costs for each carrier size 

class were assumed to be identical to those used in the estimation of mobile site revision costs.63

Based on these preliminary assumptions and estimates, the costs to make primary Web sites fully 

accessible are calculated as follows:

 63 The Air Transport Association said in its comments to the 2004 NPRM that at least some air carriers would 

require a significantly higher number of hours to comply with the standards in that NPRM. Similarly, the Interactive 

Travel Services Association (ITSA) argued that compliance for travel agencies would be far more technically 

complex than DOT had anticipated and estimated the cost of basic Web site compliance with the Section 508 

standard to be $200,000-$300,000 per company with millions more in ongoing maintenance costs. However, it is not 

clear that estimates from 2004 are still relevant for estimating compliance costs in 2012 and beyond. Web sites of 

that era were only beginning to transfer all of the formatting control to Cascading Style Sheets (CSS), which make 

maintenance and updating of Web pages much easier and less time-consuming. Use of CSS is now nearly universal. 

The programming tools available in Web design software were also much less well-developed. Finally, the 2004 

NPRM proposed compliance with the current Section 508 standards. In comments submitted in response to the 

questions raised in the DOJ ANPRM, Concerned Web Developers noted that “The current Section 508 does not 

acknowledge the evolution of the web beyond static HTML; it does not support application development for the 

web; it does not acknowledge the rampant use of multimedia on the web... WCAG [2.0] is a more robust and more 

current set of guidelines, and is better-supported.” (Concerned Web Developers. DOJ-CRT-2010-0005-0297.1.pdf, 

available on www.regulations.gov).
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Table 23 - Estimated Web Site Revision Costs to Comply with Tier 3 Standards

Full Site

Largest Large Small Smallest

Average number of pages 900 300 120 60

Programming/review hours required

Conformance 

evaluation/certification 300 200 150 100

Site layout and home page 300 200 150 100

Each site page 1 1 1 1

Total hours required 1,500 700 420 260

Cost per hour 

(programming/overhead) $150 $150 $120 $120

Cost per site $225,000 $105,000 $50,400 $31,200

Number of sites requiring revision

U.S. carriers* 12 37 12 38

Foreign carriers 15 36 36 2

Travel agencies 8 10 88 222

Tour operators 4 6 12 72

Total number of sites 39 89 148 334

Total revision costs

U.S. carriers* $2,700,000 $3,885,000 $604,800 $1,185,600

Foreign carriers $3,375,000 $3,780,000 $1,814,400 $62,400

Travel agencies $1,800,000 $1,050,000 $4,435,200 $6,926,400

Tour operators $900,000 $630,000 $604,800 $2,246,400

Total Tier 3 revision costs $8,775,000 $9,345,000 $7,459,200 $10,420,800

Total costs (millions) $36.00

Discounted costs (millions)** $36.04

*Includes contract carriers and charter carriers which do not market air transportation to the general 

public.

**Assumes 25 percent of compliance costs incurred in Year 0, 50 percent in Year 1, and 25 percent in 

Year 2. The Year 0 costs are rolled forward to Year 1 using a 7 percent inflation rate.

These preliminary estimates show that under reasonable assumptions about the amount of time 

and resources that would be required the compliance costs for retrofitting the primary versions of 

carrier and ticket agents Web sites to comply with the proposed Tier 3 requirements would be 

about $36.0 million. U.S. and foreign carriers would incur an estimated $17.4 million in costs to 

make their existing primary Web sites fully compliant with the WCAG 2.0 accessibility 

standards. Travel agencies and tour operators would incur an estimated $18.6 million in costs to 

meet the Tier 3 requirements.

Carriers and ticket agents are also likely to incur ongoing costs in connection with maintaining 

and updating their primary Web sites to ensure that accessibility is not degraded as a result of 

any changes. Our estimates of these costs are as follows:
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Table 24 - Ongoing Annual Site Maintenance Costs

Full Site

Largest Large Small Smallest

Percent of pages replaced/added 20%

Average number of pages/year 180 60 24 12

Percent of retrofit time for new pages 20%

Programming/review hours required

Conformance 

evaluation/certification 60 40 30 20

Site layout and style sheet 60 40 30 20

Each site page 0.2

Total hours required 156 80 60 40

Cost per hour 

(programming/overhead) $150 $150 $120 $120

Maintenance cost per site $23,400 $12,000 $7,200 $4,800

Number of sites

U.S. carriers* 12 37 12 38

Foreign carriers 15 36 36 2

Travel agencies 8 10 88 222

Tour operators 4 6 12 72

Total number of sites 39 89 148 334

Annual costs

U.S. carriers* $280,800 $444,000 $86,400 $182,400

Foreign carriers $351,000 $432,000 $259,200 $9,600

Travel agencies $187,200 $120,000 $633,600 $1,065,600

Tour operators $93,600 $72,000 $86,400 $345,600

Total ongoing annual costs $912,600 $1,068,000 $1,065,600 $1,603,200

Annual cost (millions) $4.65

Total costs, Years 1-10 (millions)** $39.52

Discounted costs (millions)** $28.12

*Includes contract carriers and charter carriers which do not market air transportation to the 

general public.

**Ongoing costs begin to be incurred halfway into Year 2.

U.S. and foreign carriers would incur an estimated $2.0 million annually in costs to ensure that 

their primary Web sites remain fully compliant with the WCAG 2.0 accessibility standards as 

new pages are added and existing pages are revised. Travel agencies and tour operators would 

incur an estimated $2.6 million annually in costs to ensure that their primary Web sites remain 

fully compliant with the WCAG 2.0 accessibility standards as new pages are added and existing 

pages are revised.

As with the benefits analysis, there are potentially important categories of costs for which 

monetary values cannot be estimated from the available data, as well as those that are 

intrinsically qualitative, including:
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• Use of resources. Carriers will need to devote resources to creating or updating Web

pages to ensure regulatory compliance. It is possible that these resources could otherwise 

be used to provide more or better functionality on their Web sites.

• Loss of creativity/options. Ensuring all elements of an air travel Web site adhere to 

WCAG standards may reduce the carrier options in creatively presenting Web content 

and may stifle innovation.

• Maintenance costs. Each time a Web site is updated, the new content would have to be 

checked to verify that it complies with the proposed standards. This may make updating 

the Web site more time consuming. Existing and new personnel may also have to 

undergo extra training before starting work on a covered air travel Web site.

• Point of diminishing returns. The cost of removing 80 percent of the accessibility 

guideline violations may be a small fraction of the cost of fixing the remaining 20 

percent.

• Enforcement costs. The Department would have to invest resources in acquiring and 

maintaining the ability to monitor and review covered air travel Web sites, conduct 

testing and verification periodically, and work with site publishers to understand and 

remedy identified violations of the proposed accessibility standards.

6.6. Estimated Net Benefits and Discussion of Preliminary Results

The present value of net benefits from the proposed Web site accessibility requirements is 

expected to be $55.3 million for the 10-year analysis period using a discount rate of 7 percent 

and $74.7 million for the same time period using a discount rate of 3 percent. The estimated net 

benefits of the proposed requirements would be even larger if the values of improvements in 

access for people with disabilities other than blindness or severe visual impairments could be 

estimated and included in the regulatory evaluation.

Table 25 - Present Value of Accessible Web Site Benefits and Costs

Discount Rate Used: 7 Percent 3 Percent

Total benefits (millions) $122.11 $147.27 

Tier 2 compliance costs (millions)* $2.65 $2.60 

Tier 3 compliance costs (millions) $36.04 $36.01

Ongoing site maintenance costs (millions) $28.12 $33.94 

Total costs (millions) $66.81 $72.55 

Present value of net benefits (millions) $55.30 $74.72

*Assumes all covered carriers and ticket agents opt to provide accessible mobile sites in lieu of 

making full versions accessible to comply with 12-month requirements.

The preliminary benefit and cost estimates developed for the baseline scenario and for the two 

alternatives included in this evaluation indicate that any of them would generate monetized 

benefits to travelers with disabilities that would substantially exceed the costs that would be 

incurred by carriers and ticket agents to develop and publish accessible Web sites. The net 

benefits of the first regulatory alternative—requiring accessible links to fully accessible mobile 

sites—are somewhat higher than those for the baseline scenario. However, the benefit and cost 

estimates for both sets of requirements are sensitive to a large number of component assumptions 
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and estimates. Using certain reasonable alternative values for some of these component 

assumptions and estimates, the net benefits calculated for the baseline scenario would exceed 

those estimated for the alternative set of possible accessibility requirements.

There are potentially significant differences in the unquantifiable benefits that would be realized 

in the baseline scenario (which would require primary Web sites to be fully accessible) and the 

alternative approach that would permit carriers and ticket agents to meet the proposed 

requirements by providing accessible links to fully accessible mobile Web sites. For example, 

requiring full versions of Web sites to be compliant eliminates the need to determine whether or 

not the mobile version, or other accessible alternative, provides equivalent coverage and is 

updated as frequently. This would reduce the extent of future internal and regulatory monitoring 

that would be required to determine whether a carrier or ticket agent is in compliance. On the 

other hand, allowing compliance by means of a link to an alternative accessible Web site may 

prompt carriers and ticket agents to develop mobile sites more quickly, which would provide 

additional benefits to disabled travelers in the form of larger reductions in the amount of time 

typically required to navigate and conduct transactions on mobile Web site pages.
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Table 26 - Web Site Benefits, Costs, and Net Benefits by Year

Year 0 Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10

Years 0-

10

Benefits

Number of site visitors 

who benefit 318,868 340,404 362,896 386,380 410,895 436,480 463,176 491,024 520,069 550,355 4,280,547

Benefits to 

passengers (millions) $4.65 $11.71 $14.37 $15.30 $16.27 $17.29 $18.34 $19.45 $20.60 $21.80 $159.78

Benefits to carriers 

and ticket agents 

(millions) $0.88 $0.94 $1.00 $1.06 $1.13 $1.20 $1.27 $1.35 $1.43 $1.51 $11.77

Total Benefits 

(millions) $5.53 $12.64 $15.37 $16.37 $17.40 $18.49 $19.62 $20.80 $22.03 $23.31 $171.55

Costs (millions):

Tier 2 costs $1.28 $1.28 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $2.56

Tier 3 costs $9.00 $18.00 $9.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $36.00

Ongoing 

maintenance costs $0.00 $0.00 $2.32 $4.65 $4.65 $4.65 $4.65 $4.65 $4.65 $4.65 $4.65 $39.52

Total costs $10.28 $19.28 $11.32 $4.65 $4.65 $4.65 $4.65 $4.65 $4.65 $4.65 $4.65 $78.08

Net Benefits -$10.28 -$13.75 $1.32 $10.72 $11.72 $12.75 $13.84 $14.97 $16.15 $17.38 $18.66 $93.47
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Appendix: Carrier Web Site Characteristics and Accessibility

As part of the preliminary RIA, Econometrica conducted an extensive review of the 

characteristics and accessibility of a large, diverse sample of U.S. and foreign carrier Web sites.

In this appendix, we first provide an introduction to some of the technical aspects of Web sites 

and Web page coding and then present a description and discussion of results from this review.

A.1. Web Site Technology and Accessibility

Web Site Basics

Web sites are a collection of individual, related, linked Web pages. Web pages are electronic 

documents consisting of media content (such as text, images, and video) and computer code that 

determines how the content is rendered on a monitor. Web browsers, such as Firefox and Internet 

Explorer, process the computer code and display the Web page content. Web browsers have a 

large number of optional add-ons, extensions, and plug-ins that expand browser capabilities to 

read and run specific computer code and to display a larger range of media content.

Increases in personal computing power and telecommunications speed, along with new Web 

browsers, sophisticated programmers, dynamic Web site content and design, and new media 

formats, have overwhelmed efforts to develop and maintain Web site technology standards. 

Differences in browsers, Web site code, and media content can result in some Web sites being 

partially inoperable unless opened with a specific browser or unless a specific add-on, extension, 

or plug-in is installed.

The evolution of Web sites into more visually complex displays with complex navigation options 

has provided benefits for air travelers generally and especially for consumers who are deaf or 

hard of hearing. However, these features pose additional challenges for airline passengers with 

visual or cognitive disabilities, and carrier and ticketing agent Web sites often provide these 

passengers with a phone number for customer assistance and ticket purchase.

Among the largest network and low-cost U.S. carriers, only Delta appears to have a specific 

option that converts its default home page into a version adapted for screen readers and other 

technologies that make it more accessible for individuals who are blind and those with severe 

vision impairments. The full versions of other carrier Web sites currently afford different degrees 

of accessibility for consumers with various types of disabilities.

Mobile Web Site Technology and Accessibility

An increasing number of users access Web content through Smartphones, tablets, and other 

mobile devices, many of which have hardware and software limitations that reduce the use of 

advanced technology on Web sites accessed through these devices. To address these limitations, 

an increasing number of organizations that publish Web sites operate abbreviated parallel Web 

sites (typically with URLs in the form of either mobile.nameofcompany.com or 

m.nameofcompany.com, instead of www.nameofcompany.com) that eliminate or substantially 

simplify graphic menus and navigation, video, images, and template design features but offer 

access to all or selected parts of the information and functionality of the full versions of their 

Web sites.
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Some of these simplified mobile sites are accessible; most could be made accessible with a small 

fraction of the amount of conformance assessment, design, and programming work that would be 

required to render a full Web site accessible. Nine of the twelve reporting carriers that market air 

transportation and the four largest online travel agencies (OTAs) publish versions of their Web 

sites for mobile phone users. Some, like the mobile.aa.com site, render substantial portions of the 

full Web site in line-by-line text form with minimal graphics. Others are more skeletal, offering 

access only to online booking, flight schedules, flight status updates, and a limited amount of 

travel information (e.g., checked baggage policies and fees). Not all provide direct access to the 

sections that provide information on accommodation of travelers with special needs.

Web Site Technology and Accessibility Standards

Making Web site content accessible to persons with disabilities is based on the same principles 

used by Web browsers to display content. A program processes the computer code and media 

content to render the information on a Web site in an accessible manner. One can consider a Web 

browser itself a program that makes Web content accessible, albeit not for all disabilities. 

The first Web sites were documents written in hypertext markup language (HTML). An HTML 

document consists of text interspersed with “tags,” code that defines the display properties of the 

text. For example, the tags <B> and </B> surround text that should be bold when displayed. 

Early Web browsers interpreted the HTML tags and displayed the Web page content. The 

concept of tagging content remains important to current Web site technology, and it is 

fundamental to making Web content accessible to persons with disabilities, but advances in 

technology, computing power, and content have made Web site technology increasingly 

complex.

Making Web sites accessible requires specific and comprehensive use of tags to determine how 

to present the Web site information in an accessible form. For example, a table on a Web site 

should be tagged as a table, with each header, row and each cell also tagged. This allows the 

table to be presented, row by row and cell by cell, with headers properly indicated. Other 

examples of accessibility elements are providing alternate text descriptions for images and 

navigation that allows for keyboard input. Both of these modifications can also be implemented 

using tags. 

Like Web site technology standards as a whole, Web site accessibility standards have struggled 

to keep pace with advances in technology, telecommunications, and computing power. At the 

same time, such advances have increased the potential and actual accessibility of Web sites. 

Often complex, non-accessible content can be creatively reprogrammed or reformatted as 

accessible content without changing how it is displayed in a standard Web browser.

A.2. Carrier Web Site Characteristics

The costs associated with providing accessibility to the full versions of carrier Web sites depend 

on their extent and complexity. Over the past several years, corporate Web sites have grown 

substantially larger—both in terms of the number of pages and of the average page size (i.e., 
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amount of content displayed).64 Using Xenu’s Link Sleuth site evaluation tool, we inventoried 

the total number of HTML pages in a broad spectrum of carrier Web sites, including:65

• All 12 reporting carriers that market scheduled passenger service to the general public.

• The other six U.S. carriers that market scheduled passenger service on at least one aircraft 

with more than 60 seats.

• All six U.S. carriers that market scheduled passenger service on at least one aircraft with 

between 30 and 60 seats (but none with more than 60 seats).

• Eleven of the twenty-seven U.S. carriers that market scheduled passenger service 

exclusively on aircraft with less than 30 seats.

• Twelve foreign carriers that had 1 million or more passengers depart from U.S. airports in 

2009.

• Twelve foreign carriers that had fewer than 1 million passengers depart from U.S. 

airports in 2009.

For each of these Web sites, Xenu’s Link Sleuth tool was used to tabulate:

• The total number of pages, measured as the number of HTML or related types of files, 

accessible on the site.

• The total number of images in .jpg and similar formats for which alt text captions might 

potentially need to be included.

• The number of downloadable documents in PDF format.

• The number of links to external URLs or other elements.

The results of these tabulations are presented in the table below:

 64 See, for example, WebSiteOptimization.com, “Average Web Page Size Quintuples Since 2003,” available at

http://www.websiteoptimization.com/speed/tweak/average-web-page/. 65 Xenu’s Link SleuthTM checks a Web site by visiting the home page, compiling a list of links on that page, then 

visiting each of those pages; it repeats the process until all pages in a Web site are cataloged. Xenu’s Link SleuthTM

was designed to find broken links in a Web site, but the process also produces many useful statistics. See 

http://home.snafu.de/tilman/xenulink.html.
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Table A-1 - Carrier Web Site Element Counts

Carrier Category

Web Site Element Counts

Pages Images PDFs

External 

Links

Domestic

reporting carriers 914 759 26 1,025 

other large carriers (> 60 seat aircraft) 303 604 16 388 

small carriers (30-60 seat aircraft) 58 93 23 140 

very small carriers (only < 30 seat 

aircraft) 71 112 4 60 

Foreign

carriers with > 1 million U.S. 

passengers/year 1,414 267 29 1,863 

carriers < 1 million U.S. 

passengers/year 792 530 44 1,284 

Source: Econometrica, Inc., site testing using Xenu’s Link Sleuth, April-May 2011.

The most notable results of these tabulations include:

• The average numbers of pages for reporting carrier Web sites is more than 3 times larger 

than estimated in the May 2010 preliminary options analysis.

• The largest foreign carrier sites are bigger than the sites of most U.S. carriers.

• Most sites have links to relatively few downloadable documents.

• Large U.S. and foreign carrier sites typically have several hundred links to URLs and 

content hosted on other sites.

A.3. Carrier Web Site Accessibility

Another determinant of the costs that would be incurred in complying with the proposed 

requirements is the extent and diversity of accessibility issues that would need to be addressed. 

To characterize the potential scope of the revisions that would potentially be required, we 

reviewed the home pages of each carrier in the six groups described above using the Qompliance 

add-in for the Firefox browser. The following tabulations were compiled from the site-specific 

reports generated by Qompliance:66

• The total number of issues identified that represent definite or potential violations of 

WCAG 2.0 Level A and Level AA standards.

 66 Qompliance is a Firefox Extension that gives Firefox users direct access to Deque’s Worldspace, a Web content 

Accessibility tool. Worldspace is a Web-based enterprise tool that automates testing for Accessibility (Section 508 

and WCAG), Privacy, Quality, and Security. See https://addons.mozilla.org/en-US/firefox/addon/qompliance/.
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• The number of different WCAG 2.0 guidelines violated.

• The number of issues identified that represent violations only of Level AA-specific 

standards.

Table A-2 - Accessibility Testing of Carrier Web Site Home Pages

Carrier Category

Average Number of Violations (WCAG 

2.0 A/AA Level)

Total 

Issues

Total 

Guidelines

AA Level 

Issues

Domestic

reporting carriers 80 11 12 

other large carriers (> 60 seat aircraft) 116 12 31 

small carriers (30-60 seat aircraft) 59 9 6 

very small carriers (only < 30 seat aircraft) 46 8 15 

Foreign carriers with > 1 million U.S. passengers/year 67 9 7 

carriers < 1 million U.S. passengers/year 78 9 20 

Source: Econometrica, Inc., site testing using Qompliance add-in on Firefox 3.6 browser, April-May 2011.

These results indicated that the home pages of U.S. carriers in all size classes, as well as foreign 

carriers, have significant numbers of accessibility issues, most of which involve violations or 

potential violations of Level A standards. Small U.S. carrier sites have lower average numbers of 

total accessibility issues that would need to be addressed, but the required revisions would still 

involve a substantial number of different WCAG 2.0 guidelines.

A.4. Mobile Versions of Carrier Web Sites

Companies increasingly publish multiple versions of their public Web sites to optimize the 

experiences of users who access the Internet using various types of tools, including traditional 

Web browsers, mobile browsers, and screen readers. We attempted to locate and access any 

extant mobile versions of the Web sites published by carriers in each of the six categories 

included in our review. Of the 12 reporting carriers that market air transportation to the general 

public, 9 offer alternative versions designed specifically for mobile device access. As the 

following table shows, the extent and type of content varies significantly across these nine sites:
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Table A-3 - Mobile Web Site Content for Reporting Carriers

Number Percent

Marketing carriers 12 100%

With mobile sites 9 75%

Mobile Web site content

Flight status 9 100%

Check-in 8 89%

View my itinerary 8 89%

Book/change reservations online 7 78%

Frequent flyer account 7 78%

Flight schedules 6 67%

Contact us/About us 6 67%

Updates & alerts 5 56%

Terms and conditions/Legal/Policies 3 33%

Travel Information (gates, in-flight services, etc) 3 33%

Sales & offers 3 33%

Car rental 1 11%

Source: Econometrica, Inc., review on May 16, 2011.

All nine sites provide the ability to check flight status; all but one allow travelers to check in or 

access their itineraries; and all but two allow users to book or change flights and access their 

frequent flyer accounts.

Very few other U.S. carriers (but the majority of foreign carriers) included in our review have 

mobile versions of their Web sites at present.

A.5. Screen Reader Parsing of Full and Mobile Versions of Carrier Web Sites

Because mobile versions of Web pages are designed to display content more compactly, they 

typically contain fewer images and provide simpler navigation. These adaptations also 

substantially reduce the amount of time that it takes for a screen reader to translate the page into 

audio output. To quantify the extent of this difference, we utilized the aDesigner application to 

estimate the amount of time that it would take for a typical screen reader to read all the contents 

of each carrier home page included in this review.67

 67 Home pages of carrier Web sites are typically among the most complicated to render in fully accessible form, 

since they include the online booking engines and links to the remaining pages on the site.
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Table A-4 - Carrier Web Site Screen Reader Times

Carrier Category

Screen Reading Time (seconds)

for Home Page

Full 

Version

Mobile 

Version

% of Full 

Version

Domestic

reporting carriers 199 30 15%

other large carriers (> 60 seat aircraft) 231 no site **

small carriers (30-60 seat aircraft) 116 no site **

very small carriers (only < 30 seat aircraft) 185 no site **

Foreign carriers with > 1 million U.S. passengers/year 225 25 11%

carriers < 1 million U.S. passengers/year 144 18 12%

Source: Econometrica, Inc. site testing using Xenu’s Link Sleuth and aDesigner, April-May 2011.

As noted previously, nine of the 12 reporting carriers that market air travel to the general public 

have mobile Web sites. Eight of the 12 larger foreign carriers and seven of the smaller ones 

included in our review also maintain mobile versions of their Web sites. The screen reading 

times for both U.S. and foreign carrier mobile site home pages are substantially lower than for 

the full Web site home pages. However, it should be noted that the mobile versions of home 

pages generally serve solely as menus to direct users to the content available, rather than acting 

as destinations for site visitors.