Final Regulatory Analysis

Final Rule on

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

Submitted By:

Econometrica, Inc.

7475 Wisconsin Avenue

Suite 1000

Bethesda, Maryland 20814

October 23, 2013
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

ii

Econometrica, Inc. October 23, 2013

Table of Contents

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

Introduction................................................................................................................................... 5

1. Guarantees of Equal Access for People With Disabilities............................................. 6

1.1. Air Carrier Access Act......................................................................................................... 6

1.2. Section 707 of the Americans with Disabilities Act (ADA) Guidelines............................. 6

1.3. Section 508 of the Rehabilitation Act of 1973..................................................................... 7

1.4. W3C Consensus Standards.................................................................................................. 8

2. Passengers With Disabilities Requiring Accommodation in Air Travel ................... 10

2.1. Extent and Severity of Disabilities in the U.S. Population................................................ 10

2.2. Use of Electronic Technologies by People With Disabilities............................................ 12

2.3. Travel Behavior of People With Disabilities..................................................................... 13

3. An Overview of the Passenger Air Transportation Sector ......................................... 14

3.1. Flights and Passengers....................................................................................................... 15

3.2. U.S. and Foreign Air Carriers............................................................................................ 15

3.3. Carrier Employment and Revenues................................................................................... 18

3.4. Travel Agencies and Tour Operators................................................................................. 19

3.5. Airports.............................................................................................................................. 20

3.6. Regulatory Authorities....................................................................................................... 20

4. General Framework for Analysis of Benefits and Costs............................................. 21

4.1. Nature of Benefits Anticipated .......................................................................................... 22

4.2. Types of Compliance Costs Incurred................................................................................. 23

4.3. General Assumptions Used to Estimate Benefits and Costs.............................................. 23

4.4. Components of the Requirement-Specific Evaluations..................................................... 24

5. Evaluation of Rule Requirements for Accessible Kiosks ............................................ 25

5.1. Current Industry Practices and the Need for Regulatory Requirements............................ 25

5.2. Rule Requirements and Alternatives Considered to Address Identified Needs ................ 26

5.3. Discussion of Comments Received ................................................................................... 28

5.4. Compliance Scenarios Evaluated....................................................................................... 37

5.5. Estimated Benefits of Rule Requirements......................................................................... 37

5.6. Estimated Costs of Rule Requirements.............................................................................. 42

5.7. Estimated Net Benefits and Discussion of Results............................................................ 48

6. Evaluation of Rule Requirements for Accessible Web Sites....................................... 49

6.1. Current Industry Practices and the Need for Regulatory Requirements............................ 49

6.2. Rule Requirements and Alternatives Considered to Address Identified Needs ................ 50

6.3. Discussion of Comments Received ................................................................................... 51

6.4. Compliance Scenarios Evaluated....................................................................................... 58
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

iii

Econometrica, Inc. October 23, 2013

6.5. Estimated Benefits of Rule Requirements......................................................................... 60

6.6. Estimated Costs of Rule Requirements.............................................................................. 65

6.7. Estimated Net Benefits and Discussion of Results............................................................ 72

Appendix A: ICT Accessibility Standards.............................................................................. A-1

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

A.2. Evolution of Web Site Accessibility Standards.............................................................. A-2

A.3. WCAG 2.0 Level A and Level AA Success Criteria...................................................... A-3

Appendix B: Carrier Web Site Characteristics and Accessibility........................................ B-1

B.1. Carrier Web Site Characteristics..................................................................................... B-1

B.2. Carrier Web Site Accessibility........................................................................................ B-2

B.3. Screen Reader Parsing of Carrier Web Sites................................................................... B-3

Appendix C: Kiosk Accessibility Standards........................................................................... C-1
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

iv

Econometrica, Inc. October 23, 2013

List of Tables

Table ES1–Present Value of Net Benefits for Rule Requirement (millions) ................................. 2

Table ES2–Unquantifiable Benefits and Costs of Kiosk Accessibility Requirements................... 3

Table ES3–Unquantifiable Benefits and Costs of Web Site Accessibility Requirements.............. 4

Table 1–U.S. Population by Disability Status, 2010 .................................................................... 11

Table 2–Internet Use among Populations with and without Disabilities...................................... 13

Table 3–Selected Data for 2002 from BTS Freedom to Travel.................................................... 14

Table 4–Selected Data from Open Doors Organization/Harris Interactive .................................. 14

Table 5–Scheduled and Nonscheduled Passenger Service on U.S. and Foreign Carriers, 2011.. 15

Table 6–Passenger Service on Reporting and Other U.S. Carriers, 2011..................................... 16

Table 7–Number of U.S. Carriers by Size Class, 2011 ................................................................ 17

Table 8–Number of Foreign Carriers by Size Class and Region, 2011........................................ 18

Table 9–U.S. Carrier Employment and Operating Revenues, 2011............................................. 19

Table 10–Travel Agencies and Tour Operators, 2007.................................................................. 20

Table 11–Passenger Enplanements by Size of Airport, 2011....................................................... 20

Table 12–DOT Enforcement Orders Involving Disability Issues, 2010−2012 ............................ 21

Table 13–Number of Passengers Benefitting from Accessible Kiosks........................................ 39

Table 14–Value of Reduced Transaction Time from Accessible Kiosks..................................... 41

Table 15–Projected Number of Accessible Kiosks Installed........................................................ 43

Table 16–Estimates of Incremental Cost per Accessible Kiosk ................................................... 44

Table 17–Acquisition and Applications Development Costs for Accessible Kiosks by Carrier 

Group ............................................................................................................................................ 46

Table 18–Estimated Compliance Costs for Accessible Kiosks.................................................... 47

Table 19–Present Value in 2017 of Accessible Kiosk Benefits and Costs, 2015–2026............... 48

Table 20–Annual Time Savings per Passenger from Web Accessibility Requirements.............. 62

Table 21–Estimated Number of Travelers Benefitting from Web Site Accessibility .................. 63

Table 22–Monetized Benefits of Carrier Web Site Accessibility Requirements ......................... 64

Table 23–Estimated Costs of Developing and Maintaining Accessible Carrier Web Sites......... 68

Table 24–Costs Associated with Online Service Request Form .................................................. 68

Table 25–Ticket Agent Call Center Programming and Training Costs........................................ 71

Table 26–Present Value in 2016 of Accessible Web Site Benefits and Costs, 2014−2025 

(millions)....................................................................................................................................... 72

Table A-1–Level A Success Criteria in WCAG 2.0................................................................... A-3

Table A-2–Level AA Success Criteria in WCAG 2.0 ................................................................ A-6

Table B-1–Carrier Web Site Element Counts............................................................................. B-2

Table B-2–Accessibility Testing of Carrier Web Site Home Pages........................................... B-3

Table B-3–Carrier Web Site Screen Reader Times.................................................................... B-4

Table C-1–Kiosk Technical Standards ....................................................................................... C-1
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

v

Econometrica, Inc. October 23, 2013

Acronyms and Abbreviations

A4A Airlines for America 

AAI American Aviation Institute 

AAPA Association of Asia Pacific Airlines

ACAA Air Carrier Access Act 

ACI Airports Council International 

ACS American Community Survey

ADA Americans with Disabilities Act

ADAAG Americans with Disabilities Act Accessibility Guidelines

ANA All Nippon Airways

ANPRM advance notice of proposed rulemaking 

ASTA American Society of Travel Agents

ATA Air Transport Association 

ATM automated teller machine 

BBI Burton Blatt Institute, Syracuse University

BLS Bureau of Labor Statistics 

BTS Bureau of Transportation Statistics 

CCD Consortium for Citizens with Disabilities 

CFR Code of Federal Regulations

COAT Coalition of Organizations for Accessible Technology

CUSS common-use self-service 

dB decibels 

DIA Denver International Airport 

DOJ U.S. Department of Justice 

DOT U.S. Department of Transportation

El Al El Al Israel Airlines

EU European Union 

EZ easy 

FAA Federal Aviation Administration 

FCC Federal Communications Commission 

FR Federal Register

HTML hypertext markup language

IATA International Air Transport Association 

ICT information and communication technology

IRFA initial regulatory flexibility analysis 

IT information technology

ITI Information Technology Industry Council 

ITSA Interactive Travel Services Association

NAICS North American Industry Classification System 

NFB National Federation of the Blind 

ODO Open Doors Organization 
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

vi

Econometrica, Inc. October 23, 2013

OMB Office of Management and Budget 

OST Office of the Secretary of Transportation

OTA online travel agent

OTP on-time performance 

PHP hypertext preprocessor

PRA preliminary regulatory analysis 

PV present value 

R&D research and development

SBA U.S. Small Business Administration 

SIPP Survey of Income and Program Participation 

SNPRM supplemental notice of proposed rulemaking 

Spirit Spirit Airlines

URL uniform resource locator

U.S.C. United States Code

USTOA United States Tour Operators Association

W3C Worldwide Web Consortium 

WAI Web Accessibility Initiative 

WCAG Web Content Accessibility Guidelines 

XHTML extensible hypertext markup language
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 1 of 72 Pages

Econometrica, Inc. October 23, 2013

Executive Summary

The U.S. Department of Transportation (hereinafter, DOT or the Department) is issuing a Final 

Rule to ensure that automated airport kiosks and carrier Web sites are accessible to air travelers 

with disabilities. The provisions of this Rule are necessary to ensure nondiscrimination on the 

basis of disability in air travel, as required by the Air Carrier Access Act. Specific requirements 

are as follows:

 Beginning 3 years after the effective date of the Rule, covered carriers (and airports, in 

the case of shared-use kiosks) will be required to ensure that new automated airport 

kiosks installed at a specific airport location are models that comply with the technical 

standards for accessibility set forth in the Rule until at least 25 percent of the kiosks at 

that location are accessible.1

 Large U.S. and foreign carriers will be required to ensure that their primary Web sites 

comply with the Level A and Level AA success criteria and performance requirements 

included in the Web Content Accessibility Guidelines (WCAG) version 2.0 standards. 

Content, forms, and applications relating to a set of core functions, including, but not 

limited to, flight booking and changes, flight status information, and online check-in 

(where available), will need to be compliant within 2 years of the effective date of the 

Rule. The remaining portions of large-carrier sites will need to be compliant within 3 

years of the effective date of the Rule. Carriers will also be required to provide 

(accessible) disability accommodation request forms on their Web sites within 2 years of 

the effective date of the Rule.

 Large travel agents and tour operators (hereinafter referred to collectively as “ticket 

agents”) selling air transportation will be required to provide Web-based discounts and 

other Web-based amenities on request to passengers who contact them offline when the 

agents’ Web sites cannot be used by those passengers because of their disability.

Econometrica, Inc., prepared a preliminary regulatory evaluation for provisions addressing kiosk 

and Web site accessibility that were included in a supplemental notice of proposed rulemaking 

(SNPRM) published on September 26, 2011.2In this final regulatory analysis, we summarize and 

discuss comments received from the public on this preliminary evaluation and indicate how this 

input was incorporated into this evaluation of the revised requirements included in the Final 

Rule. We also provide an updated overview of current industry practices, present the Final Rule 

requirements and describe the changes made from the proposed requirements in response to 

comments received on the SNPRM, identify the parties affected by the Rule, develop estimates 

of monetized benefits and costs (Table ES1), and indicate the nature of additional benefits and 

costs for which no quantitative estimates could be developed.

All quantified benefits and costs attributable to individual requirements were converted into 

current monetary values for each year in the 10-year analysis period beginning with the 2016 

 

1 As discussed below, these standards are based primarily on Section 707 of the U.S. Department of Justice’s 2010 

Americans with Disabilities Act (ADA) Standards, but also incorporate elements of the current Section 508 

requirements for self-contained, closed machines.

2

See 76 FR 59307 (September 21, 2011).
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 2 of 72 Pages

Econometrica, Inc. October 23, 2013

calendar year for Web sites and the 2017 calendar year for kiosks.3In accordance with Office of 

Management and Budget 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.

Table ES1–Present Value of Net Benefits for Rule Requirement (millions)

Estimate Period and Discount Rate Kiosks* Web Sites* Rule Total*

Monetized Benefits

10 Years, 7% discounting $34.8 $75.9 $110.7

10 Years, 3% discounting $42.0 $90.3 $132.3

Monetized Costs

10 Years, 7% discounting $34.9 $79.8 $114.7

10 Years, 3% discounting $36.1 $82.5 $118.6

Monetized Net 

Benefits

10 Years, 7% discounting ($0.1) ($3.9) ($4.0)

10 Years, 3% discounting $5.9 $7.8 $13.7

*Present value in 2016 for Web site requirements and 2017 for kiosk requirements.

Net Benefits of Kiosk Accessibility Requirements

The expected present value (PV) in 2017 of the benefits from 2017 through 2026 accruing as a 

result of the Rule requirements for accessible automated airport kiosks is estimated at $34.8 

million using a 7 percent discount rate. The expected PV in 2017 of costs incurred by carriers 

and airports in 2015 through 2026 to comply with these Rule requirements is $34.9 million over 

the same 10-year period, discounted at 7 percent. The PV in 2017 of net benefits for the 10-year 

analysis period at a 7 percent discount rate is thus –$0.1 million. Using a 3 percent discount rate, 

the PV in 2017 of net benefits for this 10-year period is estimated at +$5.9 million.

There are additional benefits and costs associated with the kiosk accessibility requirements for 

which quantitative estimates could not be developed (Table ES2).

 

3 Affected entities will incur expenditures to comply with the Rule in 2014 through 2016 to meet the requirements 

that are assumed to take effect in 2016 and 2017. These costs were translated into appropriate base-year (2017 for 

kiosks, 2016 for Web sites) present values using discount rates of 7 and 3 percent.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 3 of 72 Pages

Econometrica, Inc. October 23, 2013

Table ES2–Unquantifiable Benefits and Costs of Kiosk Accessibility Requirements

Benefits

Improved access to self-service functions (e.g., baggage tagging or boarding) expected 

to be offered on airport kiosks in the future.

Increased independence and self-sufficiency for travelers with vision- or mobility-related 

disabilities.

Increased sense of inclusion and reduction in the stigma of special treatment.

Less congestion at ticket counters for all passengers.

Potential benefits to other air travelers (e.g., those who have trouble reading English).

Costs

Additional costs to make peripherals and software accessible for airport kiosks that offer 

additional self-service functions in the future.

Sunk costs of inaccessible kiosk development programs in progress.

Occasional increases in kiosk waiting times for other travelers.

The benefit and cost estimates developed for the kiosk accessibility requirements indicate that 

the present value of monetized benefits to travelers with disabilities and cost savings to carriers 

is approximately equal to the present value of the costs that will be incurred by carriers and 

airports to develop, program, install, and maintain accessible airport kiosks. The benefit and cost 

estimates for these requirements are sensitive to the values selected for a large number of 

component assumptions and estimates. Using certain reasonable alternative values for some of 

these component assumptions and estimates, the net benefits calculated may be positive even if a 

7 percent discount rate is used, and may be negative even if a 3 percent discount rate is used. In 

any event, the monetized net benefits of the kiosk accessibility requirements are very small in 

magnitude, indicating that the Department must weigh the unquantifiable benefits and costs to 

determine if the Rule would be in the public interest.

Automated airport kiosks are expected to provide an increasing set of passenger self-service 

opportunities in the next few years. Some of these functions—e.g., baggage tagging and 

boarding—cannot be accomplished online or on a mobile device. This suggests that ensuring 

that automated airport kiosks are accessible will be increasingly important in eliminating barriers 

that air travelers with disabilities would otherwise face while performing a wide array of airportbased transactions.

Net Benefits of Web Site Accessibility Requirements

The expected PV in 2016 of the benefits from the carrier Web site accessibility requirements is 

estimated at $75.9 million from 2016 through 2025 using a 7 percent discount rate. The expected 

PV in 2016 of costs incurred by carriers in 2014 through 2025 to comply with these Rule 

requirements is $79.8 million over the same 10-year period, discounted at 7 percent. The PV in 

2016 of net benefits for the 10-year analysis period is estimated at –$3.9 million using a 7 

percent discount rate. The PV in 2016 of net benefits for this 10-year period is estimated at +$7.8

million using a 3 percent discount rate.

There are additional benefits and costs associated with the Web site accessibility requirements 

for which quantitative estimates could not be developed (Table ES3).
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 4 of 72 Pages

Econometrica, Inc. October 23, 2013

Table ES3–Unquantifiable Benefits and Costs of Web Site Accessibility Requirements

Benefits

Increased independence and self-sufficiency for travelers with vision, hearing, or motor skill 

disabilities.

Potentially improved accessibility for people with other types of disabilities.

Reduced number of service request accommodation problems.

Reduced effort and cost to comply with potential future non-U.S. accessibility 

requirements for multinational Web sites.

Easier Web site maintenance, debugging, and documentation.

Costs

Diversion of scarce Web programming resources from other projects.

Reduced Web site functionality or effectiveness.

Effort required to develop or maintain separate pages, forms, or applications for covered 

and uncovered elements of multinational Web sites (or to make parts of these sites that 

are not subject to the Rule accessible). 

The benefit and cost estimates developed for the Web site accessibility requirements included in 

this evaluation indicate that the present value of monetized benefits to travelers with disabilities 

and cost savings to carriers is approximately equal to the present value of the costs that will be 

incurred by carriers to develop, publish, and maintain accessible Web sites. The benefit and cost 

estimates for these requirements are sensitive to the values selected for a large number of 

component assumptions and estimates. Using certain reasonable alternative values for some of 

these component assumptions and estimates, the net benefits calculated may be positive even if a 

7 percent discount rate is used, and may be negative even if a 3 percent discount rate is used. In 

any event, the monetized net benefits of the Web site accessibility requirements are very small in 

magnitude, indicating that the Department must weigh the unquantifiable benefits and costs to 

determine if the Rule would be in the public interest.

One important consideration is that several foreign government entities have developed or are 

developing Web site accessibility requirements based on the WCAG 2.0 Level A and Level AA 

standards. To the extent that these requirements are adopted or take effect within the time frame 

permitted under the Rule to bring Web sites into compliance, carriers with multinational 

operations (i.e., nearly all of those covered by the Rule) will incur reduced costs to meet pending 

or future Web site accessibility requirements adopted by foreign governments.

The 10-year annualized costs of the requirements for kiosks and Web sites are approximately 

$3.5 million and $8.0 million, respectively, discounted at 7 percent. The Rule is a significant 

regulatory action under DOT’s regulatory policies and procedures (44 FR 11034, February 26, 

1979, as amended May 7, 1979, at 44 FR 28126 and restated in DOT Order 2100.5, issued May

22, 1980).

Section 202 of the Unfunded Mandates Reform Act of 1995 requires that agencies assess 

anticipated costs and benefits before issuing any rule with mandates that would require spending 

of $143 million or more in any one year. The Rule does not impose enforceable duties on State, 

local, or Tribal governments, or on the private sector, of $143 million or more in any one year.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 5 of 72 Pages

Econometrica, Inc. October 23, 2013

Introduction

The U.S. Department of Transportation (hereinafter, DOT or the Department) has developed

additional regulatory requirements that will help to ensure nondiscrimination on the basis of 

disability in air travel. The requirements in the accompanying Rule address widespread problems 

with the accessibility of automated airport kiosks and carrier Web sites to passengers with 

disabilities who need assistance or accommodation in one or more of the following areas:

 Hearing

 Vision

 Mobility

 Fine-motor dexterity

 Cognition

The Department proposed requirements in each of these areas in the supplemental notice of 

proposed rulemaking (SNPRM) published on September 26, 2011. Econometrica, Inc., provided 

a preliminary regulatory analysis (PRA) and initial regulatory flexibility analysis (IRFA) to 

accompany the SNPRM. In the PRA, we concluded that there were significant net benefits from 

the proposed requirements for both airport kiosks and carrier Web sites.

The Department received comments on the proposed requirements from a large, diverse group of 

stakeholders, including carrier and ticket agent associations, individual companies, disability 

research and advocacy groups, and members of the public. These comments provided valuable 

input for the Department, which has significantly revised and simplified the final regulatory 

requirements in response to many of the concerns raised by stakeholders.

In this final regulatory analysis, we summarize and discuss comments received from the public 

on this preliminary evaluation and indicate how this input was incorporated into this evaluation 

of the revised requirements included in the Final Rule. We also provide an updated overview of 

current industry practices, present the Final Rule requirements and describe the changes made 

from the Rule requirements in response to comments received on the Rule, identify the parties 

affected by the Rule, develop estimates of monetized benefits and costs, and indicate the nature 

of additional benefits and costs for which no quantitative estimates could be developed.

It is important to note that economic evaluation of regulatory requirements in these areas is 

complicated by the fact that the technologies available to address many of these disabilities are 

continuously evolving. Therefore, regulatory requirements must 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. 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.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 6 of 72 Pages

Econometrica, Inc. October 23, 2013

1. Guarantees of Equal Access for People With Disabilities

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

automated airport kiosks or carrier Web sites. This section provides a brief overview of the 

current statutory and regulatory guarantees of equal access for people with disabilities that are 

relevant for the evaluation of the standards established in this Rule.

1.1. Air Carrier Access Act

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 use 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.

 By training all carrier personnel who come in day-to-day contact with people with 

disabilities, to understand their needs and how they can be accommodated quickly, 

safely, and with dignity.

4

In the accompanying Rule, the 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 Rule 

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

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

1.2. Section 707 of the Americans with Disabilities Act (ADA) 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 

 

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

with a Disability.”
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 7 of 72 Pages

Econometrica, Inc. October 23, 2013

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).5

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

6

Titles II and III both incorporate accessibility standards for automatic teller machines and selfservice fare machines, which are set forth in Section 707 of the 2010 U.S. Department of Justice 

(DOJ) Standards for Accessible Design.

7

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 of the Rehabilitation Act of 1973

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 technologies. The 

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

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

1973.8The 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 in the 

accompanying Rule.

Part 1194.22 of Section 508 covers Federal agency Web-based intranet and Internet information 

and applications. These requirements include 16 specific standards that are designed to ensure 

that Federal agency Web sites can be processed and interpreted by assistive technology, such as 

screen readers. The Access Board has determined that the first 11 of these requirements are 

 

5 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.

6

See 75 FR 56163 (September 15, 2010) for ADA Title II standards; see also 75 FR 56236 (September 15, 2010) 

for Title III standards.

7 U.S. Department of Justice (DOJ), 2010 Standards for Accessible Design, September 15, 2010.

8

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

forums are available at www.Section508.gov.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 8 of 72 Pages

Econometrica, Inc. October 23, 2013

consistent with specific WCAG 1.0 Priority 1 checkpoints. Several of the remaining 

requirements address accessibility issues also covered in the WCAG 1.0 standards.

In July 2010, the Access Board issued an advance notice of proposed rulemaking (ANPRM) that 

solicited comment on revising or “refreshing” the current Section 508 standards. 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. In

December 2011, the Access Board issued a second ANPRM seeking review and comment on the 

text of standards and guidelines under consideration by the Board to supersede the current 

Section 508 requirements. The December 2011 ANPRM specifically proposed to reference the 

WCAG 2.0 Level A and Level AA success criteria and conformance standards as the applicable 

accessibility standard for Web sites, as well as other forms of information and communication 

technology (ICT). The Board indicated its intention to issue a notice of proposed rulemaking 

seeking further public comment after considering the comments on the second ANPRM.9

1.4. W3C Consensus Standards

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

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

W3C Web Accessibility Initiative (WAI) has developed and adopted two sets of consensus Web 

site accessibility guidelines. WCAG 1.0, published in 1998, provided the foundation for a 

significant part of the current Section 508 standards relating to Web site (and other ICT) 

accessibility. WCAG 2.0, published 10 years later on December 11, 2008, represented a 

comprehensive update and revision of these standards.10

WCAG 2.0 was organized around four principles that ensure that Web sites are accessible for 

people with various types of disabilities:

1. Information and user interface components must be presentable to users in ways they can 

perceive.

2. User interface components and navigation must be operable.

3. Information and the operation of user interface must be understandable.

4. Content must be robust enough that it can be interpreted reliably by a wide variety of 

user agents, including assistive technologies.

WCAG 2.0 applies broadly to more advanced technologies than WCAG 1.0. It is easier to use 

and understand, and is more precisely testable with automated testing and human evaluation. The 

performance criteria specified in each section of WCAG 2.0 are widely regarded to be 

 

9

See 76 FR 76640 (December 8, 2011); see also Access Board, “Draft Updated Standards and Guidelines (2011).”

10 Both WCAG 1.0 and WCAG 2.0 have three nested levels of standards that afford increasing levels of 

accessibility. The WCAG 1.0 standards are categorized as Priority Level 1, 2, or 3. The WCAG 2.0 standards are 

specified at the A, AA, and AAA levels. WCAG 1.0 Priority Level 1 and WCAG 2.0 Level A represent the least 

extensive set of requirements.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 9 of 72 Pages

Econometrica, Inc. October 23, 2013

operationally achievable, measurable, and potentially enforceable.11 In contrast, elements of 

WCAG 1.0 (and the current Section 508 standards) that address some of the same accessibility 

issues are difficult to measure and evaluate consistently.

DOJ issued an ANPRM in 2010, indicating that it was considering revising the current ADA 

Title III regulations to establish requirements to ensure that goods, services, facilities, privileges, 

accommodations, or advantages offered by public accommodations via the Internet would be 

accessible to individuals with disabilities. The ANPRM also stated: “The Department is also 

considering revising the ADA Title II regulations to establish requirements for making the 

services, programs, or activities offered by State and local governments to the public via the Web 

accessible.”12

Foreign government Web site accessibility requirements are also typically defined by reference 

to, or are largely based on, WCAG 2.0. Australia, Canada, Hong Kong, and New Zealand 

Government Web sites are or will be required to meet the WCAG 2.0 Level A and Level AA 

Success Criteria and Conformance Requirements. France and Germany have national standards 

that are based on, but not identical to, WCAG 2.0 (Level AA), while United Kingdom 

Government Web sites are required to comply with either WCAG 1.0 or 2.0 at the AA level.13

Official Web sites of European Union institutions are currently expected to follow the WCAG 

1.0 guidelines for accessible Web content, but in March 2012 European Commission 

Standardization Mandate M376 proposed that WCAG 2.0 Level A and Level AA success criteria 

be used as the basis to evaluate accessibility for all covered Web and non-Web electronic 

content.

These WCAG 2.0-based Web site accessibility requirements typically apply to government and 

public organization Web sites and (in some cases) electronic content. However, the Australian 

Human Rights Commission has developed advisory requirements for nongovernment Web sites, 

requiring conformance with WCAG 2.0 on the following schedule:14

 Nongovernment Web sites and Web resources whose development commences after July 

1, 2010, should comply with WCAG 2.0 to a minimum of Level AA conformance.

 Existing nongovernment Web sites or Web resources that undergo substantial change in 

the period July 2010–December 2013 should comply with WCAG 2.0 to a minimum of

Level AA conformance.

 All existing non-government Web sites and Web content should comply with WCAG 2.0 

to a minimum of Level AA conformance by December 31, 2013.

 

11 Guidance, examples, best practices, and resources for complying with the WCAG 2.0 specifications are available 

at http://www.w3.org/standards/webdesign/accessibility.

12 DOJ, “Nondiscrimination on the Basis of Disability: Accessibility of Web Information and Services of State and 

Local Government Entities and Public Accommodations,” Advance Notice of Proposed Rulemaking, DOJ-CRT2010-0005-0001, July	26,	2010.

13 Mark Rogers, “Government Accessibility Standards and WCAG 2.0,” Power Mapper Software Blog, posted 

November 13, 2012.

14 Australian Human Rights Commission, “World Wide Web Access: Disability Discrimination Act Advisory Notes, 

Version 4.0,” October 2010.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 10 of 72 Pages

Econometrica, Inc. October 23, 2013

Therefore, the Department has based its Rule requirements for Web site accessibility on WCAG

version 2.0.

2. Passengers With Disabilities Requiring Accommodation in Air 

Travel

This section provides an overview of the data sources available to estimate the population of 

passengers with disabilities who may reasonably be expected to benefit from the Rule 

requirements. 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. Estimates of the extent of air travel by

people with disabilities are available from two surveys sponsored by the Open Doors 

Organization. These data sources provide a foundation for deriving the numbers of potentially 

affected air travelers requiring accommodation from estimates 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 

The Census Bureau conducts the ACS annually to be able to present a more detailed profile of 

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

2010 ACS results provide more recent estimates of the proportion of the population age 18 to 64

years, as well as 65 and older, respectively, who have serious difficulty seeing or hearing, or 

ambulatory difficulty.

15

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 use wheelchairs or screen readers, for example. In addition, the criteria used to 

develop estimates of the numbers of people with serious hearing or vision difficulties may not be 

the same as those used to define the population of individuals who may require accommodation 

under the ACAA, the ADA, or other Federal accessibility statutes and regulations.

 

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

beginning with the 2008 survey, so estimates from the 2008−2010 ACS cannot directly be compared to 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.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 11 of 72 Pages

Econometrica, Inc. October 23, 2013

The Survey of Income and Program Participation

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

about a variety of household characteristics and finances. The 2010 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 2010 SIPP also specifically asked about 

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

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

Selected results from the 2010 ACS and SIPP are compared in Table 1.

Table 1–U.S. Population by Disability Status, 2010

SIPP ACS

Age Group and Disability Status

Number 

(1,000s)

Percent of 

Group

Number 

(1,000s)

Percent of 

Group

Age 18 to 64* 203,083 191,138

With a disability 32,220 13.4%

Severe disability** 21,545 8.6% 19,048 10.0%

Difficulty seeing 4,295 1.8% 3,209 1.7%

Severe difficulty seeing*** 960 0.4%

Difficulty hearing 3,420 1.7% 3,924 2.1%

Severe difficulty hearing *** 1,030 0.2%

Ambulatory difficulty 11,996 6.1% 9,857 5.2%

Used a wheelchair*** 1,623 0.6%

Age 65 and older 38,599 39,132

With a disability 19,234 49.8%

Severe disability** 14,138 36.6% 14,352 36.7%

Difficulty seeing 3,782 10.1% 2,688 18.7%

Severe difficulty seeing*** 1,050 2.8%

Difficulty hearing 4,152 11.2% 5,904 15.1%

Severe difficulty hearing *** 66 1.5%

Ambulatory difficulty 11,883 30.8% 9,315 23.8%

Used a wheelchair*** 2,014 5.2%

*SIPP estimates are for age 15 and older.

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

***Not included on ACS data collection instrument.

Sources: Census Bureau, “Americans With Disabilities: 2010,” Current Population Reports, P70-131, July 

2012; and 2010 American Community Survey, Table S-1810.

The percentage of the population in each age range reporting any type of disability in the 2010 

ACS and the percentage of the same age group reporting a severe disability in the 2010 SIPP are 

very comparable, which indicates that these estimates can be reliably used to calculate the 

number of people who would potentially benefit from various improvements in the accessibility

of air travel.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 12 of 72 Pages

Econometrica, Inc. October 23, 2013

The 2010 SIPP estimates indicate that a significant portion of the U.S. population (and about half 

of the population age 65 and older) has some type of disability. Smaller percentages of the 

population have each of the types of disabilities that are specifically addressed by the Rule 

requirements.

2.2. Use of Electronic Technologies by People With Disabilities

Federal Government agencies increasingly rely on Web sites, applications, and forms to provide 

information and facilitate transactions with individuals, businesses, and organizations. 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. 

The Pew report estimates on the impact of disability on the use of electronic technologies 

corroborate a 2010 Federal Communications Commission (FCC) report, which found a large gap 

in Internet use rates between segments of the population with and without disabilities. However, 

a very small percentage of Internet users with disabilities indicated that their disability caused 

problems with using the Internet.

Broadband Use and Adoption in America (FCC 2010)

In recent years attention has been focused on the impact of disability status on broadband access 

rates. In a 2010 FCC working paper, John Horrigan found a significant gap between Internet use 

rates for users with and without disabilities:

16

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 noted:

... 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.

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 

 

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

Paper No. 1, February 2010.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 13 of 72 Pages

Econometrica, Inc. October 23, 2013

technology (Table 2).

17 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 segments of the population with and without disabilities. However, a very small 

percentage of Internet users with disabilities indicated that their disability caused problems with 

using the Internet.

Table 2–Internet Use Among Populations With and Without Disabilities

Respondent Characteristic

People With 

Disabilities

People Without 

Disabilities

High school education or less 61% 40%

Household income <$30,000/year 46% 26%

Use the Internet 54% 81%

Percent 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.

2.3. Travel Behavior of People With Disabilities

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

disabilities, and none of these was based on research conducted since 2005. 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, BTS conducted a study on the travel behavior of people with disabilities.18 The results 

presented in the Freedom to Travel report indicated that people with disabilities had a lower 

average propensity to travel by air than did people without disabilities—the average person with 

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

commercial airline in the past year (Table 3).

 

17 Susanna Fox, “Americans living with disability and their technology profile,” Pew Internet and American Life 

Project, January 21, 2011.

18 DOT Bureau of Transportation Statistics, Freedom to Travel, BTS03-08, 2003.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 14 of 72 Pages

Econometrica, Inc. October 23, 2013

Table 3–Selected Data for 2002 From BTS Freedom to Travel

Respondent Characteristic

People With 

Disabilities

People Without 

Disabilities

Average age 50.7 31.9

Percent using commercial airline in the past year 31.5% 40.1%

Percent using private or charter airplane in the past year 1.4% 1.3%

Source: BTS Freedom to Travel, 2003.

One result worth noting is that people with disabilities in the BTS study were nearly two decades 

older on average than the respondents without disabilities. Therefore, it is 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 

specific types of disabilities.

The Open Doors Organization/Harris Surveys

A 2002 ODO survey showed that about 30 percent of adults with disabilities traveled by air at 

least once during the previous 2 years. Travelers with disabilities 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 travelers with disabilities.

19 One-third of travelers with disabilities who 

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

The ODO survey was updated in 2005 (Table 4). 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).

Table 4–Selected Data From Open Doors Organization/Harris Interactive

Survey Result 2002 2005

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

Average number of air trips per year 1 1

Percent of air travelers who booked online 33% 51%

Percent of air travelers who consulted Internet for 

accessibility information 46% 43%

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

3. An Overview of the Passenger Air Transportation Sector

This section provides a description and statistical profile of the following elements of the 

passenger air travel sector: flights and passengers, U.S. and foreign carriers, U.S. airports, jet 

aircraft manufacturers, and regulatory authorities.

 

19 The ODO survey collected data on trips. Each round trip is equivalent to approximately 3.2 flight segments, which 

implies that travelers with disabilities account for approximately 30 million flight segments annually.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 15 of 72 Pages

Econometrica, Inc. October 23, 2013

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 (Table 5). Carrierspecific 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.20

Table 5–Scheduled and Nonscheduled Passenger Service on U.S. and Foreign Carriers, 2011

Data Element Domestic International Combined

Passengers

U.S. carriers 655,901,218 91,659,246 747,560,464

Foreign carriers 419,221 74,735,225 75,154,446

Total 656,320,439 166,394,471 822,714,910

Departures

U.S. carriers 8,781,576 827,002 9,608,578

Foreign carriers 2,714 517,203 519,917

Total 8,784,290 1,344,205 10,128,495

Average Passengers per Departure

U.S. carriers 74.7 110.8 77.8

Foreign carriers* 154.5 144.5 144.6

Total 74.7 123.8 81.2

*Passengers on domestic segments of foreign carrier flights continuing on to or from international 

destinations.

Source: BTS T-100 Segment database, 2011.

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.

The most recent Federal Aviation Administration (FAA) Aerospace Forecast projects annual 

increases averaging 2.0 percent and 3.8 percent, respectively, in the numbers of passengers 

flying on domestic and international flights over the next 10 years.21

3.2. U.S. and Foreign Air Carriers

About 100 U.S. and 150 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. 

 

20 Scheduled passenger service accounts for more than 98 percent of all departures and more than 99 percent of 

passengers enplaned.

21 Federal Aviation Administration, FAA Aerospace Forecast: Fiscal Years 2013–2033.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 16 of 72 Pages

Econometrica, Inc. October 23, 2013

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

under 49 U.S.C. §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 largest aircraft the carrier operates.

Reporting Carriers

As of January 1, 2012, there were 13 U.S. carriers that each accounted for at least 1 percent of 

domestic scheduled passenger service revenues, including 6 mainline carriers (Alaska, 

American, Delta, Hawaiian, United, and US Airways), 4 low-cost model major airlines (AirTran, 

Frontier, JetBlue, and Southwest), and 3 regional carriers (American Eagle, ExpressJet, and 

SkyWest). These “reporting carriers” are required to provide flight-specific Form 234 on-time 

performance (OTP) data to BTS on a monthly basis. Reporting carriers accounted for 84 percent 

of all passengers travelling on U.S. carriers in 2011 (Table 6).

22

Table 6–Passenger Service on Reporting and Other U.S. Carriers, 2011

Carrier Category

Number of 

Carriers Departures Passengers

Average 

Passengers

per

Departure

Reporting carriers 13 6,492,100 630,850,367 97

Other U.S. carriers 87 3,116,478 116,710,097 37

Total 100 9,608,578 747,560,464 78

Reporting carrier 

percent of total 13% 68% 84%

*Source: BTS T-100 Segment database, 2011.

Aircraft Size-Based Distinctions Among Carriers

DOT classifies carriers that provide passenger service exclusively using aircraft originally

designed with 60 seats or less as small carriers (Table 7). Some regulatory requirements for these 

carriers are somewhat less extensive than for larger carriers. For example, carriers are not 

required to provide on-board wheelchairs on aircraft with 60 or fewer seats, nor are they required 

to submit annual disability-related complaint reports to the Department.

 

22 The 2011 air traffic statistics include departures and passengers reported under the codes of both parties to the 

AirTran-Southwest, Atlantic Southeast-ExpressJet, and Continental-United mergers. During the past 3 years, several 

regional carriers (Comair, Mesa, and Pinnacle) have dropped below the 1-percent threshold that triggers the OTP 

data reporting requirements.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 17 of 72 Pages

Econometrica, Inc. October 23, 2013

Carriers that operate passenger service exclusively with aircraft having fewer than 30 seats are 

exempt from additional regulatory requirements, including the requirement that at least half of 

aisle seats in each class of service have movable armrests. These carriers are designated as “very

small” carriers in this regulatory assessment.

Table 7–Number of U.S. Carriers by Size Class, 2011

Carrier Group

Number of 

Seats on 

Largest 

Aircraft

Total

Carriers*

CharterOnly**

All 

Scheduled 

Service

Carriers

Contract 

Carriers

Other

Scheduled 

Service 

Carriers

Large >60 43 17 26 11 15

Small 30−60 14 1 13 6 7

Very small <30 45 10 35 0 35

Total 102 28 74 17 57

*Excludes carriers that were no longer operating independently by the end of 2012.

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

Five of the 7 small U.S. carriers and 29 of the 35 very small U.S. carriers that market scheduled 

air transportation directly to the public operate flights exclusively in Alaska or Hawaii, or among 

islands in the Pacific or Caribbean.

In 2012, 12 U.S. carriers required to report T-100 data to BTS were wholly owned subsidiaries.

23

These carriers are treated as separate entities for some reporting and regulatory compliance 

purposes.

Mainline and Regional Airlines

Several U.S. carriers 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 estimates that its member carriers provided the only 

scheduled service available in 2011 at 270 U.S. airports in the 48 contiguous States and at 206 

airports in Alaska and Hawaii.24 Regional carriers are typically subject to the same reporting and 

regulatory requirements as other airlines in the same size classes.

 

23 Two of these—AirTran and ExpressJet—were reporting carriers.

24 Regional Airline Association, 2012 Annual Report, p. 15.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 18 of 72 Pages

Econometrica, Inc. October 23, 2013

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 currently about 

147 foreign carriers that operate scheduled or charter service to the United States (Table 8).

25 Of 

these, 97 market scheduled service flights to U.S. passengers.

Table 8–Number of Foreign Carriers by Size Class and Region, 2011

Carrier Group

Number of 

Seats on 

Largest 

Aircraft

Total 

Carriers*

Charter

Carriers**

All 

Scheduled 

Service 

Carriers

Contract 

Carriers

Other 

Scheduled 

Service 

Carriers

Large >60 113 9 104 8 96

Small 30−60 2 1 1 1 0

Very small <30 32 31 1 0 1

Total 147 41 106 9 97

Canada 14 6 8 2 6

EU 49 23 26 0 26

*Excludes carriers that were no longer operating independently by the end of 2012.

**Includes 2 charter carriers that operated no more than 20 scheduled service flights.

Carriers in Canada and European Union (EU) countries must comply with disability-related 

service requirements that are in many areas comparable to, or more extensive than, those 

required under the applicable provisions of the ACAA.

3.3. Carrier Employment and Revenues

The U.S. Small Business Administration (SBA) has established size-class standards for each 

industry sector that are typically used to assess the impact of proposed regulations on small 

entities under the relevant requirements of the Regulatory Flexibility Act. SBA defines a small 

passenger air transportation company as one that has fewer than 1,500 employees. Small entities 

in other North American Industry Classification System (NAICS) sectors are delineated with 

other employment or revenue thresholds. This section provides data on employment and 

revenues for U.S. carriers.

U.S. air carriers with operating revenues of at least $100 million must report annual employment 

data and quarterly financial data on Form 41. Air carriers with operating revenues of less than 

$100 million are only required to provide Form 41 financial data on a semiannual basis and do 

not report employment data. 

 

25 There are 35 foreign carriers that operate passenger service to and from the United States exclusively with aircraft 

having fewer than 61 seats. These carriers do not have to comply with requirements that apply only to carriers that 

provide passenger service on at least 1 aircraft that has more than 60 seats.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 19 of 72 Pages

Econometrica, Inc. October 23, 2013

Table 9–U.S. Carrier Employment and Operating Revenues, 2011

Type of Carrier

Number of 

Employees

Percent of 

Total 

Employees

Revenues 

(millions)

Percent of 

Total 

Revenues

Mainline 274,701 69.6% 115,819 75.6%

Low-cost 66,857 16.9% 25,929 16.9%

Regional (contract carriers) 50,756 12.9% 10,192 6.7%

Charter 2,550 0.6% 1,191 0.8%

Total 394,864 100.0% 153,131 100.0%

Table 9 shows that the five remaining U.S. mainline carriers (American, Delta, United, Alaska, 

and Hawaii) account for about 70 percent of reported employment and 75 percent of operating 

revenues. Southwest accounted for more than half of low-cost carrier employment and revenues, 

even before its acquisition of AirTran in mid-2011. American Eagle and SkyWest (including its 

ExpressJet subsidiary) accounted for more than half of regional carrier employment and 

revenues. Charter carriers accounted for less than 1 percent of employment and revenues in 

2011.

3.4. Travel Agencies and Tour Operators

Travel agencies and tour operators sell air travel through online and offline channels. 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 2009 study, about 17 percent of travel agencies have online ticketing capability. 

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

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

market segment.26

The most recent Economic Census data indicate that there were 96 ticket agents with 500 or 

more employees in 2007. The Economic Census also provides estimates of the numbers of travel 

agents and tour operators with annual revenues firms of more than $25 million and those with 

$10-25 million in annual revenues (Table 10).

 

26 PhoCusWright, The Role and Value of the Global Distribution Systems in Travel Distribution, November 2009.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 20 of 72 Pages

Econometrica, Inc. October 23, 2013

Table 10–Travel Agencies and Tour Operators, 2007

Sector Total Firms

Firms with 500 

or More 

Employees

Firms with Annual 

Revenues of $25

million or more

Firms with Annual 

Revenues of $10

to $25 million

Travel Agencies 11,803 70 39 67

Tour Operators 2,627 26 22 33

All Ticket Agents 14,430 96 72 100

Source: Bureau of the Census, Economic Census, 2007.

The 2013 SBA standards classify travel agencies and tour operators with no more than $19 

million in annual revenues as small businesses. However, the 2007 Economic Census does not 

report the numbers of travel agencies and tour operators with annual revenues that exceed this 

specific threshold. For this analysis, we have assumed that travel agents and tour operators with 

500 or more employees would have annual revenues in excess of $19 million annually.27

3.5. Airports

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

enplaned. There were 387 U.S. airports with at least 10,000 passenger enplanements in 2011. 

About 70 percent of domestic and international passengers departed from 29 major metropolitan 

hubs, and another 18 percent departed from 35 medium-hub airports (Table 11). 

Table 11–Passenger Enplanements by Size of Airport, 2011

Category

Minimum 

Number of 

Passengers

Number

of 

Airports

Passengers 

(millions)

Percent of 

Total 

Passengers

Average

Number of

Passengers per 

Airport

Large hub >1% of total 29 509.4 70.2% 17,565,573

Medium hub >0.25% of total 35 130.1 17.9% 3,716,396

Small hub >0.05% of total 74 61.0 8.4% 824,182

Non-hub >10,000/year 249 23.7 3.3% 95,155

Other commercial >2,500/year 124 0.6 0.1% 5,181

Total 511 724.8 100.0% 1,418,397

FAA, “Enplanements at Primary and Non-primary Commercial Service Airports,” October 9, 2012.

3.6. Regulatory Authorities

DOT enforces the ACAA 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 

 

27 This is equivalent to assuming that 24 of the 100 ticket agents with between $10 and $25 million in annual 

revenues in 2007 had $19 million or more in revenues. It should be noted that the 2012 Economic Census data, 

which are not scheduled to be available until 2014, are likely to reflect further consolidation in these two industry 

sectors.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 21 of 72 Pages

Econometrica, Inc. October 23, 2013

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. DOT entered into 16 enforcement orders with U.S. and foreign carriers that 

involve disability-related issues during the 3-year period from 2010 through 2012 (Table 12).

Table 12–DOT Enforcement Orders Involving Disability Issues, 2010−2012

Carrier Order Date

Complaint 

Reporting

Response to 

Complaints

Wheelchair 

Assistance

Report 

Filing

Virgin America, Inc. 5/22/2012 1 1

Frontier Airlines, Inc. 4/15/2012 1

Allegiant Air, LLC 2/10/2012 1 1

Spirit Airlines, Inc. 1/20/2012 1 1

Atlantic Southeast Airlines 7/4/2011 1

Icelandair Group 5/13/2011 1

Delta Air Lines, Inc. 2/10/2011 1 1 1

Mesaba Aviation, Inc. 1/4/2011 1 1

JetBlue Airways Corp. 12/17/2010 1 1 1

AirTran Airways 8/14/2010 1 1 1

Compañía Panameña de Aviación 7/15/2010 1

Cayman Airways Limited 6/21/2010 1

Continental Airlines, Inc. 5/9/2010 1

Bahamasair Limited Holdings 2/27/2010 1

TAM Linhas Aéreas, S.A. 1/8/2010 1

Total 7 7 6 5

Percent of Orders 50% 50% 43% 36%

Source: Econometrica review of DOT enforcement orders.

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, 

construction, and operation, including accessibility of facilities and transportation controlled by 

the airport operator.

4. General Framework for Analysis of Benefits and Costs

The Rule contains requirements relating to automated airport kiosks and to carrier Web sites. 

Both quantifiable and unquantifiable benefits will accrue from adoption of these requirements, 

which will also entail costs to carriers and (in the case of kiosks) airports. Benefits and costs will 

also accrue from the Rule requirements for carriers and ticket agents to provide Web-based fare 

discounts and other Web-based amenities upon request to passengers who cannot use their Web 

sites due to their disabilities.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 22 of 72 Pages

Econometrica, Inc. October 23, 2013

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. This section discusses the nature of benefits that are anticipated, the types of costs that 

will be incurred, and the general assumptions used in developing monetized estimates of the 

benefits and costs associated with the Rule requirements.

4.1. Nature of Benefits Anticipated

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

requirements include:

 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.28

In contrast, the increased independence that will be experienced by travelers with disabilities as a 

result of the Rule requirements represents an important benefit, but one for which no monetary

value can be assigned.

Carriers will also realize benefits from the Rule requirements. The cost savings associated with 

traveler use of kiosks, rather than other onsite forms of check-in, are well documented.29 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. As the W3C WAI 

site notes, “Incorporating accessibility usually increases site development time initially. 

However, in the long term Web accessibility can reduce the time an organization spends on site 

 

28 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 will 

represent a net economic benefit. However, the magnitude of this impact is not likely to be large enough to quantify.

29 See, for example, Airport Business, “Analysis: Kiosk Uptime, Revenue,” July 8, 2008.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 23 of 72 Pages

Econometrica, Inc. October 23, 2013

development and maintenance.” The W3C also anticipates cost 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.30 Comments received in response 

to the DOJ ANPRM also indicated that implementing programming practices to ensure 

accessibility will make Web sites easier to maintain.

4.2. Types of Compliance Costs Incurred

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

maintenance costs to comply with the Rule requirements. Where appropriate, the estimation of 

these costs incorporates a life-cycle analysis that takes into account the schedule on which 

compliance is projected to occur. For example, the costs for installation of new and replacement 

accessible kiosks are expected to be incurred over a 5-year time frame.31

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 Rule requirements:

 Quantitative benefits and costs were estimated assuming the Rule becomes effective on 

January 1, 2014. Carriers have 2 years to comply with the Web site accessibility

requirements for core functions and 3 years to comply with these requirements for the 

remaining content on their primary Web sites. Carriers and airports will have 3 years to 

comply with the kiosk accessibility requirements. Therefore, the 10-year period from 

2016 through 2025 was chosen to evaluate the benefits and costs of the Rule

requirements relating to Web sites. Similarly, kiosk-related benefits and costs were 

estimated for the period from 2017 through 2026. Costs incurred before the beginning of 

the analysis period were rolled forward to 2016 (Web sites) or 2017 (kiosks) present 

values using the appropriate discount rate.

 In accordance with Office of Management and Budget (OMB) guidelines, real discount 

rates of 7 and 3 percent were used to compute the present value of net benefits for the 10-

year analysis period.

 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 most recent FAA Aerospace Forecast (see Section 3.1 above).

 

30 W3C, “Developing a Web Accessibility Business Case for Your Organization.”

31 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. This 

regulatory analysis anticipates that carriers and/or airports incur the full replacement cost of a kiosk every 5 years.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 24 of 72 Pages

Econometrica, Inc. October 23, 2013

 The value of waiting time for passengers at the airport is estimated at $23.90 per hour, 

according to the most recent DOT guidance. Time saved while conducting air travelrelated research or transactions online is valued at $18.00 per hour.32

 Per-hour costs for applicable categories of carrier employees were estimated using 

Bureau of Labor Statistics (BLS) mean wage rates, increased by 44.7 percent to account 

for the nonwage components (e.g., fringe benefits, employer taxes) of direct labor costs.33

 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 

Sections 5 (kiosks) and 6 (Web sites).

4.4. Components of the Requirement-Specific Evaluations

Sections 5 and 6 of the regulatory evaluation provide assessments of the projected benefits and 

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

as well as affected ticket agent Web sites, respectively. For each set of Rule requirements, we 

present the following information:

 Current Industry Practices and the Need for Regulatory Requirements. 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 travelers with disabilities, as well as information on 

additional or improved technologies that can reasonably be expected to become available 

within the time frame used in this analysis.

 New Requirements and Alternatives Considered. This section outlines the requirements 

in the accompanying Rule and describes the alternatives considered.

 Discussion of Comments Received on the SNPRM PRA. This section summarizes the 

comments of carrier associations, individual carriers, disability advocacy organizations, 

and other stakeholders and indicates how input from these comments was taken into 

account in this regulatory evaluation.

 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 Rule requirements.

 Estimated Benefits of Rule 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 Rule 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.

 

32 Office of the Secretary of Transportation (OST), “Revised Departmental Guidance for the Valuation of Travel 

Time in Economic Analysis,” September 28, 2011.

33 U.S. Bureau of Labor Statistics, “Employer Costs for Employee Compensation,” June 13, 2013.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 25 of 72 Pages

Econometrica, Inc. October 23, 2013

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

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

5. Evaluation of Rule 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

deployed kiosks pose significant obstacles to use by travelers with various types of disabilities.34

Machine heights and installation configurations often make access by passengers using 

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 and 

host carrier software applications that enable customers to access flight-related services 

independently. Early implementation of airline self-service technology was driven by individual 

airlines placing kiosks near their airport check-in facilities. 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. In contrast to proprietary automated kiosks, shared-use kiosks are typically distributed 

throughout the terminal, with some located at offsite locations, such as parking garages and 

nearby hotels.

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

IBM, and SITA. ARINC, IBM, IER, Materna, SITA, and other vendors develop, install, and 

 

34 The inaccessibility of airport kiosks has been the subject of relatively recent lawsuits against McCarran 

International Airport, JetBlue, and United Airlines. See Coalition of Organizations for Accessible Technology 

(COAT), “Airlines Continue to Evade Accessibility of Check-In Kiosks and Websites,” August 3, 2011, for a 

discussion of the ruling by a California court in the JetBlue lawsuit.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 26 of 72 Pages

Econometrica, Inc. October 23, 2013

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 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:

 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 discernible keys.

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

 Textual equivalents for all graphics.35

As noted above in Sections 1.2 and 1.3, the accessibility standards for automated teller machines 

(ATMs) and fare vending machines (Section 707 of the 2010 Standards for Accessible Design) 

that were adopted as part of the DOJ 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 selfcontained, 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.36 Currently, there are no ACAA-based accessibility standards 

that apply to airport kiosks owned, leased, or controlled by carriers. 

5.2. Rule Requirements and Alternatives Considered to Address Identified 

Needs

The Rule requires all new kiosks installed at any specific U.S. airport location 3 years or more 

after the effective date of the Rule to comply with the accessibility requirements described below

until a minimum of 25 percent of the kiosks in that location are accessible. All U.S. carriers and 

all foreign carriers operating flights to and from the United States will be required to comply 

 

35 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.

36 In 2000, the Access Board published a report with the Trace Center that focused on making information and 

transaction machines accessible by providing guidelines that addressed issues for people 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 the 2010 ANPRM on Information and Communication 

Technology (ICT) Standards and Guidelines, March 22, 2010.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 27 of 72 Pages

Econometrica, Inc. October 23, 2013

with the kiosk accessibility standards. These requirements will apply only to kiosks installed at 

U.S. airports with 10,000 or more enplanements per year.37

The technical standards for accessibility in the Rule specifically address the following aspects of 

kiosk design, installation, and operation:38

 Use of assistive technology. Kiosks will have to be accessible to users with visual 

impairments without attachment of assistive technologies other than a personal headset or 

audio loop. A telephone handset or an industry-standard connector will 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.

 Operable parts. Operable parts on new kiosks will have to be tactilely discernible by

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

users by sound or touch and give them an opportunity to indicate that more time is 

needed where a timed response is required.

 Outputs. Speech outputs will 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. 

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

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

is delivered through speakers on the machine, incremental volume control will need to be 

provided with output amplification up to a level of at least 65 decibels (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 will need to be user selectable.

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

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

 Input controls. At least one tactilely discernible input control will need to be provided 

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

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

the only method of input, they will need to be tactilely discernible from surrounding 

surfaces and adjacent keys.

 Clear floor or ground space. Kiosks to be installed will have to provide a clear floor or 

ground space that meets the 2010 DOJ ADA standards.

 

37 Our review of carrier Web site information on kiosk locations indicates that 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 that currently offer the option to check in at either proprietary or shared-use kiosks. Therefore, the estimated 

benefits and costs associated with these requirements are limited to passengers and flights operated by large carriers 

from large-, medium-, and small-hub airports.

38 As noted above, these requirements are drawn primarily from Section 707 of the ADA Accessibility Guidelines 

(ADAAG) (the legally applicable standards under Titles II and III of the ADA), as well as selected elements from 

part 1194.25 of the Section 508 standards. Appendix C provides a provision-by-provision summary listing of Rule 

requirements and their antecedents in the Section 707 and Section 508 standards. The Rule requirements are 

expected to be compatible with future Access Board standards for other types of accessible kiosks. 
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 28 of 72 Pages

Econometrica, Inc. October 23, 2013

The Department also considered shorter time periods for compliance—setting a “must order” 

date for accessible kiosks at 60 days, 1 year, or 2 years after the effective date of the Rule. As the 

discussion of comments received on the SNPRM below indicates, it does not appear feasible for 

accessible shared-use kiosks and IATA-certified accessible kiosk software applications to be 

developed and available for order within 1 year or less after the effective date. It is possible that 

the 3-year time frame could be shortened if the software standards development process is begun 

promptly after publication of the Rule, rather than being undertaken only after the kiosk 

hardware and machine software (“middleware”) have been developed and prototyped. However, 

the additional monetized benefits of requiring accessible kiosks to be ordered 2 years after the 

effective date or installed 30 months after the effective date would be relatively small.39

5.3. Discussion of Comments Received

The Department received a substantial number of comments about various aspects of the PRA 

evaluation of the proposed requirements for kiosk accessibility. Major issues addressed included 

the timetable for compliance, the advantages and drawbacks of allowing a phase-in period or a 

less-than-100 percent requirement for accessibility, and feasibility and cost concerns with 

retrofitting existing kiosks. The Department also received some specific comments about various 

aspects of the benefit and cost calculations in the PRA. In general, carriers and ticket agents 

indicated that the proposed compliance date would be impossible to meet, that the estimation of 

time savings for people with disabilities from accessible kiosks was overstated, and that 

compliance costs were understated. Disability advocates supported the shortest possible time 

frame for compliance and stressed the unquantifiable benefits of equal access to automated 

airport kiosks. This section summarizes relevant comments and outlines the changes made to the 

Rule and the PRA to take into account these comments. Further discussion of specific issues 

relating to benefits and costs is provided in the following sections, which detail the estimation of 

monetized benefits and costs associated with the kiosk accessibility requirements in the Final 

Rule.

5.3.1. Comments About the Compliance Timetable

In the SNPRM, the Department proposed requiring all new orders for automated kiosks installed 

at U.S. airports initiated 60 days or more after the effective date to comply with the proposed 

technical requirements. The Department received a substantial volume of comments about the 

feasibility of meeting this deadline from carriers, kiosk and information technology (IT) firms, 

and disability advocates. In general, advocates supported an even tighter deadline for ordering 

accessible kiosks. For example:

There should be no delay after the effective date of the regulation.

40

 

39 Based on the comments received and interviews with kiosk manufacturers, airport kiosks are typically ordered 3 

to 6 months prior to installation.

40 Burton Blatt Institute, Syracuse University (hereinafter, BBI), “Comments on the 2011 Supplemental Notice of

Proposed Rulemaking on Airline Websites and Kiosks,” January 4, 2012, p. 6.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 29 of 72 Pages

Econometrica, Inc. October 23, 2013

To ensure that accessible kiosks are available as soon as possible, we believe, 

however, that all kiosks ordered 30 days after the effective date of the rule should 

be accessible, not 60 days.41

Only one of these comments addressed the feasibility of ordering kiosks with hardware 

components and software applications that are not currently offered for sale:

If possible, the technical standards should be finalized, published, and provided to 

all interested parties in advance while the provisions make their way through the 

Office of Management and Budget and other steps in the process. This “advance 

notice” of the technical standards would give vendors and other organizations a 

“stable target” for design and more than ample time to develop and test (and 

potentially deploy) accessible kiosks in advance of the actual effective date.... In 

addition, requirements should be worded so that accessible kiosks must appear in

airports shortly after the final rule.42

It should be noted that this recommended procedure assumes that the development of the 

technical requirements adopted in the Final Rule would not alter this “stable target.” However, 

the Trace Center comments include several suggestions for changes in these requirements, 

highlighting the need for the industry to have the final requirements in hand before attempting to 

begin complying with the Rule. Carrier and IT association comments stressed the need to be able 

to review the final requirements before proceeding with development of hardware and software 

solutions:

The Department should start the accessible kiosk compliance period 36 months 

after it adopts a final rule. This additional time is needed because industry will not 

know the accessible kiosk standards until the final rule is published and design of 

a kiosk that meets the final rule standards cannot start until the final rule is issued. 

This length of period is necessary because as recognized by the PRA and based on 

information received from vendors, the accessible kiosk design process alone will 

take a minimum of 12 months (described above) and the procurement process will 

take another 4−6 months.43

 

41 Consortium for Citizens with Disabilities (CCD) Transportation Task Force, Letter providing comments on the 

supplemental notice of proposed rulemaking announced by the U.S. Department of Transportation (DOT) 

concerning DOT’s proposal to revise its rule implementing the Air Carrier Access Act (ACAA) to provide greater 

access of websites and automated kiosks for people with disabilities in air travel, January 9, 2012, p. 2.

42 Trace R&D Center, University of Wisconsin-Madison (hereinafter, Trace Center), “Comments on the Department 

of Transportation SNPRM on Accessible Airline Kiosks,” January 9, 2012, p. 4.

43 Airlines for America, International Air Transport Association, Airports Council International-North America, 

Regional Airline Association, and the Air Carrier Association of America (hereinafter, A4A et al. or “joint carrier 

association comments”), “Comments in the Matter of Supplemental Notice of Proposed Rulemaking Concerning 

Accessibility of Web Sites and Automated Kiosks at U.S. Airports,” January 2012, p. 8.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 30 of 72 Pages

Econometrica, Inc. October 23, 2013

From a product development and manufacturing perspective, 18−36 months 

should be a reasonable amount of time to delay the effective date.44

Econometrica conducted a series of interviews with companies that manufacture, market, and 

develop applications for travel and transportation-related kiosks to establish more precisely the 

time frame in which development of compliant machines and software applications could be 

reasonably expected. The input we received indicates that the lead time required to develop and 

produce compliant hardware and software applications will vary substantially, depending on the 

nature of current carrier or airport systems (proprietary or shared) and applications development 

capabilities (in-house or contracted). Customers who have proprietary kiosks and have 

immediate access to adequate applications programming capabilities may be able to develop and 

deploy compliant machines and applications within 18 months, the low end of the time frame 

suggested in the Information Technology Industry Council (ITI) comments. 

However, carriers and airports with CUSS kiosks are not likely to be able to meet this deadline. 

IATA CUSS standards for both machines and compliant software applications will need to be 

revised—a process that can be expected to take the better part of a year. In addition, we 

understand from several sources that the current marketplace for CUSS developers is limited to 

very few firms, suggesting that carriers and airports without current projects may face delays in 

securing the requisite technical resources. Finally, CUSS software applications must be certified, 

which can add another 3 months to the time required for deployment.

Faced with this disparity, the Department has settled on a 3-year deadline after the effective date 

for installation of accessible kiosks. Meeting this deadline will require some concurrent effort in 

the development of compliant machines and applications, and carriers and airports will need to 

be active participants in the IATA standards development and approval process to achieve 

closure within a time frame that supports the development, prototyping, and marketing of 

accessible kiosks and software applications.

At the same time, allowing a 3-year period before accessible kiosks must be installed will allow 

sufficient time for manufacturers and programmers not already engaged in development of 

accessible solutions to participate in the market. This broadening of the market can be expected 

to mitigate the incremental costs of acquiring and installing accessible kiosks. Based on the input 

we received, shortening the compliance deadline to 2 years or less may restrict the number of 

firms that would be able to supply compliant products. In addition, some airports and carriers 

that deploy CUSS kiosks would not be able to comply with this deadline and would need to seek 

extensions or waivers from the Department.

Ultimately, the Department is persuaded that there is a benefit to travelers with disabilities from 

providing kiosk manufacturers and software programmers with a longer period to develop, 

prototype, test, and deploy accessible kiosks that meet the Rule requirements. 

 

44 Information Technology Industry Council (ITI), Letter providing comments on the Supplemental Notice of 

Proposed Rulemaking, January 9, 2012, p. 6.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 31 of 72 Pages

Econometrica, Inc. October 23, 2013

5.3.2. Comments About Transitional Phase-In Requirements

In the SNPRM, the Department requested comment on whether carriers and airports should be 

allowed to order specified percentages of kiosks after the order deadline that would not meet the 

proposed technical standards for accessibility. In part, this alternative was presented for 

consideration because the proposed order deadline in the SNPRM was only 60 days after the 

effective date. However, the Department was also interested in determining whether a phased-in 

approach would be likely to reduce implementation costs and minimize the potential for market 

shortages. Some carrier comments supported a phased-in timetable with increasing percentages 

of kiosks required in successive years:

The best approach is to require a certain percentage of future kiosk orders to be 

accessible, giving industry enough time to develop a compliant prototype. 

Requiring all kiosks ordered 60 days after the effective date of the final rule 

would ignore industry efforts needed to create a prototype. Creating a low 

percentage of accessible kiosk orders would not be problematic if delayed 36 

months.45

DIA RECOMMENDS that an airport or airline have TEN YEARS following the 

effective date of the rule to bring 100% of existing kiosks into compliance with 

accessibility requirements: 25% by Year 3; 50% within 5 years; 75% within 7 

years; 100% within 10 years. Airlines with dormant accessibility features such as 

microphone jacks should have 5 years to activate such features when new 

programming is required and 1 year when no programming is required.46

Both comments on the docket and our subsequent research indicate that there are not likely to be 

significant cost savings from an extended phase-in period. The unit cost for compliant hardware 

components is expected to be relatively small, and the cost of installing accessible software 

applications on additional machines is likely to be significant.

From a development and manufacturing perspective, the timelines and resources 

required for the development and incorporation of new accessibility solutions will 

be the same, regardless of whether all, or a percentage of, kiosks are required to 

comply with the new rules.... Development resources required to make any 

updates for compliance with new rules will be the same, regardless of how the 

requirements are phased in. From that perspective, no meaningful cost reduction 

will apply to kiosk producers as a result of a phased approach.47

Some of the manufacturer representatives indicated that the costs of installing, supporting, and 

maintaining diverse sets of compliant and noncompliant kiosks in single locations might exceed 

those associated with the “all accessible” approach. Nonetheless, carrier organizations endorsed 

 

45 A4A et al. comments, item 73 on back table.

46 Denver International Airport, “Comments on Proposed Rule Making web sites and kiosks accessible to 

individuals with disabilities,” undated, p. 2.

47 ITI comments, pp. 5 and 7.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 32 of 72 Pages

Econometrica, Inc. October 23, 2013

this approach, in part because of the minimal impact on waiting times from less-than-100-percent 

accessible kiosks:

The impact (on wait time of having fewer than 100% of kiosks be accessible) 

would be negligible because carriers would give a passenger with a disability who 

self identifies priority to accessible kiosks, so the only potential wait time would 

be the time it takes for someone already using the accessible kiosk to finish their 

transaction. In the unlikely event that several disabled passengers were waiting for 

an accessible kiosk, carriers would offer agent assistance.48

Requiring less than 100 percent of kiosks to be accessible creates the need for carriers and 

airports to develop procedures to govern priority use of the accessible kiosks by travelers with 

disabilities in locations with mixed installations of accessible and inaccessible kiosks. Several 

comments suggested different approaches to handling this situation, while some advocacy 

organization comments indicated that avoiding this special treatment was precisely the point of 

requiring accessible kiosks as an alternative to “front-of-the-line” service from carrier personnel:

There is a popular misconception that blind people want or need special 

treatment, and that the best way to provide equal service to disabled passengers is 

to let them cut in line, or give them a special priority line. This is a myth. Blind 

people simply want access to the same equipment at the same time as sighted 

people, and special treatment is viewed as degrading rather than helpful.49

However, the Department recognizes that the issues of identification and priority access 

requirements, which arise from mixed installations of accessible and inaccessible kiosks, have 

been previously addressed in the context of ATMs and fare vending machines.

5.3.3. Comments About Retrofitting Existing Kiosks

The Department did not propose a requirement to retrofit some or all existing kiosks in the 

SNPRM, but it did request comment on the feasibility, benefits, and costs of doing so. A retrofit 

requirement would eliminate the need for passengers with disabilities to identify which locations 

or units were accessible at any given point in time, a benefit stressed in several comments:

Therefore, we urge DOT to apply the graduated retrofitting requirement to 

“kiosks currently in use at every snakeline and cluster and stand-alone units 

behind security in every U.S. airport with 10,000 or more enplanements per year.” 

This will provide comprehensive coverage, so that when 50 percent of kiosks 

currently in use are retrofitted for accessibility, blind passengers will be able to 

use at least half of the kiosks deployed at every class at the check-in counter, at 

the curb, in other clusters throughout the terminal, and in every airport where the 

accessibility rule for kiosks will be applied.50

 

48 A4A et al. comments, item 97 on back table.

49 National Federation of the Blind (NFB), Letter providing comments on the Supplemental Notice of Proposed 

Rulemaking, Non-Discrimination on the Basis of Disability in Air Travel: Accessibility of Web Sites and 

Automated Kiosks at U.S. Airports, January 9, 2012, p. 11.

50 NFB comments, p. 5.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 33 of 72 Pages

Econometrica, Inc. October 23, 2013

To ensure that retrofitting is done proportionately across an airline’s service areas 

and not just in major hubs, the DOT should address the locations of retrofitting 

with the following proposed language: “kiosks currently in use at every snakeline 

or cluster or stand-alone units behind security in every U.S. airport with 10,000 or 

more enplanements per year. 51

Carrier association comments focused on the potentially high costs involved in retrofitting 

existing kiosks:

The SNPRM correctly recognized that it is costly and impractical to retrofit older 

kiosks.

52

The costs for retrofitting an existing kiosk are difficult to quantify. For example, 

some older kiosks (7 years +) may have operating systems not compatible with 

speech technology and may not support software needed for voice guidance. For 

retrofitting of hardware, costs will be incurred through parts and installation of 

equipment. Furthermore, certification costs will vary depending on requirements 

and how they align with existing 3rd party requirements.53

The costs and other drawbacks of retrofitting were also highlighted in the Trace Center 

comments:

Retrofitting existing kiosks can be significantly more expensive than deploying 

accessible kiosks from the start. In addition to losing the economies of scale and 

the lower costs for doing it in a production environment, retrofitting can also 

involve transport of the kiosks back to a warehouse or travel of a technician to the 

kiosk location to carry out the retrofit.54

Several vendor representatives also indicated that retrofitting could involve significant feasibility

issues. Therefore, the Department has determined not to add a retrofitting requirement to the 

Rule.

5.3.4. Comments About Kiosk Accessibility Benefits

Some carriers expected that eliminating the current priority for counter check-in will mean that 

the kiosk accessibility requirements will increase waiting time for travelers with disabilities, not 

reduce it.

 

51 BBI comments, p. 6.

52 A4A et al. comments, p. 9.

53 ITI comments, p. 8.

54 Trace Center comments, pp. 5–6.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 34 of 72 Pages

Econometrica, Inc. October 23, 2013

Even with IBM’s yet unproven technology, access to and use of kiosks likely will 

slow the check-in process for all passengers and undermine the purpose for which 

they were installed.55

A passenger with a disability would not save any time by using an accessible 

automated kiosk because now carriers assist these passengers with an agent,

which involves no or very little time. The Department should exclude these time 

savings benefits.56

It is important to keep in mind that while some travelers who are blind or have motor-skill 

disabilities may take longer than average to complete transactions on kiosks, this is not likely to 

be the case for passengers with other vision problems or those who use wheelchairs or other 

powered mobility devices. It is also not clear that air travelers with these disabilities routinely

seek “front-of-the-line” counter service. Some disabilities (low vision, speech impediments) may 

not be apparent to ticket counter staff. In addition, the “special treatment” currently afforded to 

passengers with some disabilities is not a preferred solution for many of these travelers, as 

explained in the following comment:

Priority access for people with disabilities may seem like a good solution for 

some people. However, this solution will be stigmatizing for many people with 

disabilities. Travelers without disabilities may feel that people with disabilities are 

getting unnecessary special treatment by being able to use a shorter line, etc. This 

is especially true since not everyone who would require an accessible kiosk has a 

disability that is visible or obvious.57

Some comments made the case that reduced waiting time benefits were substantially overstated 

in the PRA:

The PRA assumes that the proposed requirements would make it possible for 

passengers with disabilities to check in more easily and quickly, saving 13 

minutes. This passenger check in time savings would, according to the 

government’s analysis, result in $122 million in benefits, discounted to $86 

million....

The Department offers no evidence or relevant analysis to support this assertion 

that accessible kiosks will save disabled passengers 13 minutes in the check in 

process. One cannot conclude this time savings without comparing it to current 

airline practices. Part 382 requires and current airline practices mandate that ticket 

agents provide personal assistance to disabled passengers, including moving them 

to the front of any check-in line. It defies logic to argue that accessible kiosks will 

 

55 Spirit Airlines (hereinafter, Spirit), “Comments to the Supplemental Notice of Proposed Rulemaking: 

Accessibility of Web Sites and Automated Kiosks at U.S. Airports,” January 9, 2012, p.14.

56 A4A et al. comments, item 95 on back table.

57 Trace Center comments, p. 8.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 35 of 72 Pages

Econometrica, Inc. October 23, 2013

save disabled passengers any time over the current protocol, much less 13 

minutes.58

In this SNPRM, Econometrica states that 100% of analyzed passengers realize the 

13-minute benefit. This is incorrect. Because Econometrica applies this metric to 

all passengers with visual disabilities, it must use an average value to accurately 

present the source material. Multiplying 13 minutes by the 5% realization rate 

results in an average savings of 39 seconds and an overall public benefit far below 

compliance costs.59

The American Aviation Institute (AAI) comment is correct that the DOJ report from which the 

13-minute time saving estimate was obtained indicated in a separate appendix that the estimated 

reduction in waiting time would be applicable only to the 5 percent of ATM and ticketing 

machine users who are waiting at the busiest time periods.

Based on these comments, the monetized value of reduced time spent waiting in line was not 

estimated or included in this final regulatory evaluation. However, data from kiosk 

manufacturers indicated that the reduction in time spent at the counter checking in can be 

quantified. The monetized value of these (more limited) time savings was quantified and 

included in the benefits estimates presented in this evaluation.

The joint carrier association comments also question the existence of potential gate agent cost 

savings:

There will be no cost savings because carriers have agents at check in now that 

serve all passengers. The Department should exclude any cost savings in this 

area.60

This is precisely the point—if these agents do not have to spend time serving passengers with 

disabilities who are able to check in at accessible kiosks, they are available to assist other 

passengers or perform other functions that reduce waiting time for passengers or reduce the 

probability that the flight departure may be delayed. These benefits can be monetized using the 

applicable labor cost of the personnel who now have more time to check in other passengers or 

perform other functions.

5.3.5. Comments About Kiosk Accessibility Costs

Several comments addressed the PRA estimate of the incremental cost of adding accessibility 

features to a kiosk:

Depending on the final requirements from the rule, the hardware-only cost could 

range from $400−$2000 per unit.61

 

58 A4A et al. comments, p. 16.

59 American Aviation Institute (hereinafter, AAI), “Comments in the Matter of Nondiscrimination on the Basis of 

Disability in Air Travel: Accessibility of Web Sites and Automated Kiosks at U.S. Airports (Supplemental Notice of 

Proposed Rulemaking),” January 3, 2012, p. 5.

60 A4A et al. comments, item 51 on back table.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 36 of 72 Pages

Econometrica, Inc. October 23, 2013

The cost difference ranges from a low of $2000 to a high of $20,000, with a 

median cost difference of $9,250 per kiosk.62

The stated fixed cost figure of $750 per kiosk for adding accessibility to a single 

kiosk seems very high especially for orders in bulk.63

Additionally, the PRA failed to address the adverse effects of the expansion of 

automated kiosk footprints.

64

Depending on the final requirements in the rule and the wide range of applications 

that exist, estimated application costs will range between $50,000 and $500,000 

per solution.65

One problem with evaluating these alternative estimates is that per-unit costs depend on the 

number of kiosks ordered. It is not clear how the fixed costs of kiosk and software applications 

development were taken into account in the estimates presented in these comments. In addition, 

the higher estimates of per-unit increases in kiosk costs are not consistent with the information 

we received in a series of interviews with kiosk manufacturers and applications developers.66

However, the ITI comment specifically addressing applications development costs is, in our 

view, sufficient to support the inclusion of an estimate of the initial development and testing 

costs in the regulatory evaluation. The approach used to estimate these costs is discussed in 

Section 5.6, below.

Finally, there was a diversity of views on whether the PRA correctly or incorrectly estimates the 

life cycle of airport check-in kiosks.

The Department’s assumption about the life cycle of a kiosk is correct.... Industry 

practice varies from 2−3 years to 5 years.67

Experience indicates that the typical life cycle for an airport kiosk is 7−10 years.68

...the kiosk service lifespan of 5–10 years....69

The PRA assumption of an average service life of 5 years was retained in the final regulatory 

evaluation.

 

61 ITI comments, p. 7.

62 A4A et al. comments, item 120 on back table. These estimates include nonhardware-related costs.

63 Trace Center comments, p. 7.

64 Spirit comments, p. 13.

65 ITI comments, p. 8.

66 In addition, two proprietary market research reports we reviewed indicated that check-in kiosks currently cost an 

average of $8,000−$10,000 to install. It is unlikely that complying with the accessibility requirements in the Rule 

would cause the cost of each installed kiosk to double.

67 A4A et al. comments, items 71 and 110 on back table.

68 ITI comments, p. 6.

69 Trace Center comments, p. 5.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 37 of 72 Pages

Econometrica, Inc. October 23, 2013

5.4. Compliance Scenarios Evaluated

The Rule requirements specify that all kiosks installed in a specific airport location beginning 3 

years after the effective date will need to comply with the accessibility standards until at least 25 

percent of the machines in that location are accessible. Based on carrier, airport, and kiosk 

manufacturer comments, as well as supplementary research we conducted, it is feasible for 

carriers and airports to meet this deadline.70

It should be noted that somewhat more than 25 percent of the kiosks installed beginning 3 years 

after the effective date will be accessible, because kiosks are not uniformly installed in multiples 

of four in each airport location. In locations with fewer than four (or five to seven) kiosks, more 

than 25 percent of the total machines would need to be accessible. For purposes of this 

evaluation, we have assumed that 40 percent of the total number of kiosks installed after the 

effective date would comply with the Rule requirements for hardware and software accessibility. 

The Department also considered requiring carriers and airports to order only accessible kiosks 3 

years after the effective date. Carriers and airports would incur higher costs to install the 

additional accessible units, while the benefits of having additional accessible kiosks at each 

airport location cannot be quantified. However, kiosk design and software applications costs are 

fixed with respect to the number of units installed. It is possible that the difference in variable 

hardware costs between an accessible and a non-accessible kiosk may be small enough for many

carriers and airports to install only accessible kiosks in some airport locations. If this is the case, 

the 25-percent accessibility requirement may result in nearly as many accessible kiosks being 

installed as would have been the case if all new kiosks were required to be accessible.

5.5. Estimated Benefits of Rule Requirements

Benefits to Passengers With Disabilities

The Rule requirements will make it possible for air travelers with certain disabilities, including

travelers who use wheelchairs and those who are blind or have other vision impairments, to 

check in more quickly and easily when using an accessible automated kiosk, affording them the 

convenience, privacy, and time savings currently experienced by travelers 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 will be 

addressed by the Rule requirements, the proportion of these passengers who will be able and 

willing to use accessible kiosks to check in, and the speed with which accessible kiosks will 

become widely available after the effective date. 

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

of accessible automated kiosks is calculated from the following components:

 

70 This time interval can be divided into two approximately equal subintervals. 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 will accommodate the required accessibility features.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 38 of 72 Pages

Econometrica, Inc. October 23, 2013

 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.

71

 The proportion of the adult population with disabilities that will make it difficult or 

impossible to use an inaccessible 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 other vision problems that cannot be corrected with 

glasses or contact lenses (1.4 percent and 3.4 percent, respectively).

72

 An adjustment factor (0.7853) derived from the 2002 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 without disabilities.73

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

automated airport kiosks to check in during Year 1 of the analysis period, based on data 

from the 2010 SITA Airline IT Survey results. This share of airport kiosk check-ins is 

assumed to remain stable though Year 5 of the analysis period and then decline by one 

percentage point annually thereafter.74

Table 13 summarizes the calculations used to estimate the number of passengers who will benefit 

from the availability of accessible kiosks.

 

71 The parameters used in these calculations are identical to those used in Econometrica, Inc., “Final Regulatory 

Analysis,” April 8, 2011, which accompanied the April 29, 2011, 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.

72 See the results presented in Section 2.1, above. Additional benefits may accrue to people with fine motor skill or 

cognitive disabilities. These benefits could not be quantified because adequate data on the prevalence of these 

disabilities were not available. 

73 As noted in the discussion in Section 2.3, above, this is largely 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.

74 Airports Council International (ACI) Airline Business and SITA, “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 was projected to overtake all types of airport-based check-ins combined in 2013.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 39 of 72 Pages

Econometrica, Inc. October 23, 2013

Table 13–Number of Passengers Benefitting From Accessible Kiosks

Calculation Component 2017 2017−2026

Total passenger flight segments 917,284,061 10,136,333,962

Average segments per one-way trip 1.37 1.37

One-way trips taken 669,550,409 7,398,783,914

Average travel party size 1.4 1.4

Total check-ins by air travelers 478,250,292 5,284,845,653

Percent of population benefitting from accessible kiosks* 4.8% 4.8%

Air travel rate adjustment (see text) 0.7853 0.7853

Total check-ins by travelers with disabilities 18,027,358 199,209,086

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

Percent of locations with accessible kiosks 20% 80%

Total check-ins enabled by accessible kiosks 721,094 29,274,241

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

Under the baseline proposal in the accompanying Rule, an average of 20 million travelers with 

disabilities will be able to use accessible kiosks in each of the 10 years of the analysis period. 

However, there will be a phase-in period during the first 5 years as the current generation of 

kiosks is partly replaced with accessible units.

Air travelers who could use accessible kiosks will benefit from reduced check-in transaction 

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 passengers 

without disabilities 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 the final regulatory evaluation, we used data from carrier and kiosk manufacturer case 

studies indicating that it takes an average of 4 minutes for a passenger to check in at the counter, 

but only 2 minutes to check in using an automated airport kiosk.75 The value of time saved per 

traveler from using an accessible kiosk is calculated by multiplying the average amount of time 

saved by the value of time ($23.90) for reductions in airport waiting time recommended in the 

most recent Department guidance.

76

Benefits to Carriers

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 time, as more people with 

 

75 A 2007 case study, “SITA Airport Services Custom Self Check-in Kiosk,” estimated a transaction time savings of 

2 minutes per passenger from using a kiosk. Clearly, most travelers with mobility-related disabilities (who represent 

the majority of those benefitting from the kiosk accessibility requirements) will be able to realize similar time 

savings, in addition to some reduction in waiting time prior to using the machine.

76 OST, op cit.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 40 of 72 Pages

Econometrica, Inc. October 23, 2013

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

These benefits are calculated using the average hourly rate of ticket agent wages and benefits to 

value the 2-minute-per-passenger reduction in time spent checking in each additional traveler 

who is able to use an accessible kiosk. It should be noted that the estimated reduction in carrier 

costs of $0.88 per passenger obtained from this calculation is well below the cost savings 

estimates reported in manufacturer case studies and trade press articles.77

Based on these estimates and assumptions, the combined benefits to air travelers with disabilities 

and to carriers from adoption of the kiosk accessibility requirements are expected to be $1.2

million in 2017 and $49.0 million for the entire 10-year analysis period (Table 14). The present 

value of these benefits in 2015 is estimated at $34.8 million using a discount rate of 7 percent.

 

77 SITA provides an estimate of $2.50 in per-passenger cost savings in its summary of passenger processing 

solutions on http://www.sita.aero/products-solutions/solutions/passenger-processing. The $3.70 per-transaction cost 

savings estimate used in the PRA was based on Airport Business, “Analysis: Kiosk Uptime, Revenue,” July 8, 2008.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 41 of 72 Pages

Econometrica, Inc. October 23, 2013

Table 14–Value of Reduced Transaction Time From Accessible Kiosks

Calculation Component 2017 2017−2026

Monetary value of passenger time savings

Traveler check-ins using accessible kiosks 721,094 29,274,241

Average time saved by using kiosk (minutes) 2.0 2.0

Total time saved by accessible kiosks (hours) 24,036 975,808

Hourly monetary value of reduced travel waiting time* $23.90 $23.90

Monetary value of time savings per check-in $0.80 $0.80

Monetized value of reduced transaction time to 

passengers using accessible kiosks $574,472 $23,321,812

Value of reduced counter check-in time to carriers

Additional passengers using accessible kiosks 721,094 29,274,241

Average hourly wage rate** $18.17 $18.17 

Average fully loaded labor hourly rate*** $26.29 $26.29 

Per-passenger reduction in carrier costs $0.88 $0.88 

Estimated reduction in labor costs $631,802 $25,649,254 

Total monetized benefits $1,206,274 $48,971,066

Discounted benefits of accessible kiosks (millions)**** $34.77 

*Per updated DOT guidance issued September 28, 2011.

**BLS mean wage rate for computer occupations, NAICS 481000, May 2012.

***Includes benefits and other direct labor costs equal to 44.7 percent of mean wage rate, per BLS May 2013.

****Present value of benefits calculated using a discount rate of 7 percent.

Unquantifiable Benefits

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:

 Increased access to self-service functions that are expected to become more widely 

available on automated airport kiosks in the future. While online and mobile check-in 

options are expected to erode the share of passengers who check in at the airport in the 

future, larger percentages of automated airport kiosks are expected to be deployed to 

handle transactions, such as baggage tagging and boarding, that require the traveler to be 

present at the airport. Travelers with disabilities will have equal access to these 

capabilities as they are deployed more widely. However, it is not possible to quantify 

these potential benefits, because we do not have adequate data on the expected rate at 

which kiosks with these additional capabilities are expected to be deployed.

 Increased independence and self-sufficiency. Accessible self-service kiosks will 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.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 42 of 72 Pages

Econometrica, Inc. October 23, 2013

 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.

 Less congestion at ticket counters. Accessible kiosks will lessen the demands on 

customer service agents at the check-in counter. Customer service agents will be freed 

from the routine tasks of check-in and seat assignments and will have more time available 

to address individual ticketing and baggage issues. The net effect will 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.

5.6. Estimated Costs of Rule 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 Rule. Therefore, the total costs 

specifically attributable to complying with the Rule 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.

A recent proprietary market research report estimated that the top 10 U.S. carriers had 

approximately 9,000 kiosks deployed in U.S. airports in 2011.78 Based on this estimate, we have 

assumed that there are currently about 10,000 automated airport kiosks in operation. 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. 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 will continue to 

increase at the rate of 500 per year until the total installed base reaches 15,000 machines in 2021. 

Based on these assumptions and a 5-year average machine service life, the numbers of accessible 

kiosks installed in each year is computed as presented in Table 15.

 

78 Lee Holman and Greg Buzek, Market Study: North American Self-Service Kiosks, IHL Group, August 21, 2012. 

A preview of the report is available at no charge, and the full report is available for purchase.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 43 of 72 Pages

Econometrica, Inc. October 23, 2013

Table 15–Projected Number of Accessible Kiosks Installed

Calculation Component 2017 2022 2017−2026

Automated airport kiosks

Kiosks in use at start of year 13,000 15,000 15,000

Kiosks added 500 0 2,500

Kiosks replaced 2,500 3,000 27,500

Kiosks in use at end of year 13,500 15,000 15,000

Installations of accessible kiosks

New installations 200 0 1,000

Replacements of inaccessible kiosks 1,000 0 5,000

Replacements of accessible kiosks 0 1,200 6,000

Total accessible kiosk installations 1,200 1,200 12,000

Total installed base of accessible kiosks 1,200 6,000 6,000

Percent of accessible kiosks 9% 40% 40%

Carriers and airports will incur incremental compliance costs for installing each accessible kiosk, 

which are properly measured as the difference in cost between an inaccessible 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 

these costs will 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—in other 

words, they do not vary appreciably with the number of units sold. For the preliminary analysis, 

we estimated that these fixed costs will add $750 to the cost of each new or replacement kiosk 

installed. The variable costs for kiosk hardware modifications (e.g., keypads, audio output jacks) 

were expected to account for no more than 10–20 percent of this amount.

Several stakeholders provided comments indicating that per-kiosk acquisition costs for 

accessible machines were overstated or underestimated in the preliminary analysis. The Trace 

Center indicated that the hardware cost of $750 per kiosk “seems very high especially for orders 

in bulk,” but the Trace Center did not provide an alternative estimate of these costs.79 On the 

other hand, the joint carrier association comments report on the results of a member survey that 

provided median estimates of $7,000 per kiosk to retrofit accessibility and $9,250 to incorporate 

accessibility into a new kiosk. There are two obvious concerns with these estimates:

 

79 It should be noted that the $750 estimate is the midpoint of the range of costs ($303−$1,193) in a Trace Center 

analysis of the modifications that will be required to produce an accessible kiosk. However, the modifications 

assumed in the Trace Center analysis do not exactly match those that will be required to comply with the standards 

in the Rule.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 44 of 72 Pages

Econometrica, Inc. October 23, 2013

 No documentation was provided for the survey, so it is possible that some respondents 

were provided total cost figures for new kiosks, rather than estimating the incremental 

difference in costs between accessible and inaccessible units. This would account for the 

survey results indicating that incorporating accessibility in a new kiosk would be more 

costly than retrofitting an existing unit, which contradicts the statements about the 

relative cost of the two approaches provided elsewhere in the joint carrier comments.

 It is not clear how fixed hardware design and software costs were taken into account in 

these estimates.

Attached to the joint carrier comments were estimates of incremental kiosk accessibility costs 

provided by the IATA Working Group—$2,000 per kiosk for new units and $3,000 for 

retrofitting. These estimates include kiosk design and software development costs, although not 

the hardware costs for input devices and other operable parts. These estimates are somewhat 

higher than, but broadly consistent with, the estimate provided in the preliminary evaluation, 

which separately estimated costs for software development. Table 16 compares all of the unit 

cost estimates.

Table 16–Estimates of Incremental Cost per Accessible Kiosk

Estimate Source Estimate

Trace Center <$750

Preliminary regulatory analysis (with software 

development costs included) $1,171

IATA Working Group (new)* $2,000

IATA Working Group (retrofit)* $3,000

ATA/IATA Survey (retrofit)** $7,000

ATA/IATA Survey (new)** $9,250

*Includes hardware, software, and design costs; does not include input 

devices or operable parts.

**Median estimate.

Another consideration is that the proposed rule called for only accessible kiosks to be ordered 

beginning 2 years after the effective date. The Final Rule ultimately requires at least 25 percent 

of kiosks installed in each airport location to be accessible, so the volume of accessible kiosks 

ordered will be substantially lower than projected in the preliminary evaluation. Consequently, 

the number of units over which fixed kiosk design and software development costs can be spread 

will be smaller, and the per-unit incremental costs of accessible kiosks will be higher.

For this analysis, we developed a revised approach that separately estimates the costs of 

hardware design, parts, and software development costs for four categories of carriers:

 The largest four U.S. carriers (American/US Airways, Delta, Southwest, and United) are 

assumed to have the most extensive portfolio of software applications and thus higher 

software development costs. However, these carriers are expected to order and install the 
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 45 of 72 Pages

Econometrica, Inc. October 23, 2013

largest numbers of accessible kiosks, which can be expected to lower the per-unit cost 

associated with hardware components required to provide accessibility.

80

 The remaining 11 large U.S. carriers are also assumed to support both proprietary and 

shared-use applications, but these applications may be less extensive or less customized 

than those deployed by the four largest U.S. carriers.

 The largest foreign carriers are defined as those with more than 1.5 million U.S. 

enplanements annually—the approximate number of passengers enplaned annually by all 

but the single smallest U.S. carrier covered by the Rule. Foreign carriers are assumed to 

develop and support only shared-use applications.

 Large foreign carriers with between 0.5 and 1.5 million U.S. passenger enplanements 

annually are assumed to develop and support less extensive shared-use applications.81

The projections shown in Table 14 indicate that approximately 12,000 accessible kiosks will be 

ordered and installed over the 10-year analysis period. We assumed that one-half of these units 

would host proprietary applications for a single large U.S. carrier, and the other half would be 

shared-use kiosks hosting applications for multiple U.S. and foreign carriers. The total numbers 

of proprietary and shared-use kiosks were allocated among the four groups of carriers included in 

this analysis. The four largest U.S. carriers were assumed to install 75 percent of the accessible 

kiosks hosting proprietary applications, with the other 11 large U.S. carriers accounting for the 

remaining 25 percent of proprietary kiosks. It is our understanding that airport authorities 

typically purchase and deploy shared-use kiosks, which are leased to carriers who develop 

customized applications. Consequently, the allocation of hardware design and parts costs for 

shared-use kiosks is somewhat arbitrary. For this analysis, we have assumed that equal shares of 

these costs are ultimately borne by each of the four groups of large U.S. and foreign carriers 

described above.

Hardware design, parts, and software applications costs were estimated separately for each of 

these four carrier groups based on cost information provided in comments and industry research:

 The IATA Working Group indicated that new software applications cost between $1 

million and $4 million to develop, test, and deploy. Incorporating accessibility into these 

applications was assumed to increase costs by 20 percent per application.

 The four largest U.S. carriers were assumed to have the most extensive applications, with 

an estimated average incremental cost of $800,000 (20 percent of $4 million) per 

application to incorporate the required accessibility features. The other large U.S. carriers 

and the largest foreign carriers were assumed to incur an average of $400,000 per 

application in additional software development costs. The remaining foreign carriers 

included in this assessment were assumed to incur an average of $200,000 per application 

in additional software development costs.

 

80 Shortly before this evaluation was finalized, DOJ filed an antitrust lawsuit challenging the proposed merger 

between U.S. Airways and American Airlines. This analysis assumed that the merger would be completed.

81 Foreign carriers with fewer than 0.5 million passenger enplanements annually that develop and support shared-use 

applications were assumed to rely on alliance partners for any applications hosted on kiosks in U.S. airports.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 46 of 72 Pages

Econometrica, Inc. October 23, 2013

 U.S. carriers were assumed to incur separate applications development costs for the 

software hosted on proprietary and shared-use kiosks, while foreign carriers were 

assumed to incur these costs only for software on shared-use kiosks.

 The IATA Working Group indicated that kiosk redesign costs could be expected to 

average between $500 and $1,000 per kiosk. This analysis uses the midpoint of this range 

($750) for the per-unit kiosk redesign cost.

 The IATA Working Group estimated that the overall cost of making kiosks accessible 

would be $2,000, which is about $200 larger than the sum of the per-kiosk software 

development and kiosk redesign costs estimated for the largest four U.S. carriers. We 

assumed that this residual amount would be sufficient to cover the variable costs of 

hardware modifications, such as the E-Z access keypad and the headset jack. It is likely 

that kiosks manufacturers would offer better pricing on the (larger) orders from these four 

carriers, we have estimated variable hardware costs at $200 per kiosk for units ordered by 

the four largest U.S. carriers and $300 per kiosk for other large U.S. and foreign carriers.

Using this approach, the incremental costs per kiosk to incorporate accessibility are estimated in 

Table 17 for each of the four carrier groups.

Table 17–Acquisition and Applications Development Costs for Accessible Kiosks by Carrier Group

Calculation Component

Largest 

Four U.S. 

Carriers

Other 

Large U.S.

Carriers

Largest 

Foreign 

Carriers*

Other 

Large 

Foreign 

Carriers** All Carriers

Number of carriers in group 4 11 12 27 54

Number of proprietary kiosks 4,500 1,500 0 0 6,000

Number of shared-use kiosks*** 1,500 1,500 1,500 1,500 6,000

Total number of accessible kiosks 6,000 3,000 1,500 1,500 12,000

Per-application development cost $800,000 $400,000 $400,000 $200,000 $329,630

Number of applications per carrier 2 2 1 1 1.3

Total applications development 

cost $6,400,000 $8,800,000 $4,800,000 $5,400,000 $25,400,000

Average applications cost per 

kiosk $1,067 $2,933 $3,200 $3,600 $2,117

Average kiosk redesign cost $750 $750 $750 $750 $750

Average kiosk hardware cost $200 $300 $300 $300 $250

Total cost per kiosk $2,017 $3,983 $4,250 $4,650 $3,117

*More than 1.5 million passenger enplanements at U.S. airports in 2011.

**Between 0.5 and 1.5 million passenger enplanements at U.S. airports in 2011.

***Numbers and costs were assumed to be equally divided among four carrier groups.

These costs are assumed to be incurred on the following timetable:
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 47 of 72 Pages

Econometrica, Inc. October 23, 2013

 Kiosk design and software development costs will be incurred equally in the 2 years 

preceding installation of the first accessible kiosks.82

 Hardware costs will be incurred as the kiosks are installed.

 A second generation of accessible kiosks begins to be installed in the 6th year of the 10-

year analysis period. Costs associated with kiosk design and applications development 

will be incurred in the 2 years preceding the first installation of these kiosks.

Based on these component estimates and assumptions, Table 18 presents the estimated total 

compliance costs for the Rule requirements for accessible kiosks.

Table 18–Estimated Compliance Costs for Accessible Kiosks

Calculation Component 2017* 2017−2026

Proprietary accessible kiosks acquired 600 6,000

Shared-use accessible kiosks acquired 600 6,000

Total accessible kiosks acquired 1,200 12,000

Total redesign cost** $4,500,000 $9,000,000

Total hardware cost $300,000 $3,000,000

Total applications cost** $12,700,000 $25,400,000

Total cost of accessible kiosks $17,500,000 $37,400,000 

Discounted cost of accessible kiosks (millions)*** $34.88 

*Includes pre-acquisition costs incurred in 2015 and 2016.

**Redesign and applications development costs are assumed to be incurred equally in each of 

the 2 years before the 5-year acquisition cycle.

***Present value of 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 kiosk accessibility requirements are expected to be $17.5 million through 2017 and 

$37.4 million for the 10-year analysis period from 2017 to 2026. The present value of these costs 

in 2017 is estimated at $34.9 million using a discount rate of 7 percent, assuming that the first 

round of kiosk redesign and software applications costs are incurred equally in 2015 and 2016, 

the 2 years before the beginning of the analysis period.

Kiosk acquisition costs would be higher for the 10-year analysis period if the Department were 

to require 100 percent of kiosks installed 3 years after the effective date of the Rule to be 

accessible.

83 However, the per-unit cost of purchasing accessible kiosks would be lower under 

this scenario, because the kiosk redesign and software development costs incurred would be 

spread over a larger number of units sold.

 

82 The first year after the Rule becomes effective is assumed to be largely devoted to development of specifications 

and standards. It should be noted that the kiosk manufacturers will initially incur the hardware design costs, which 

will then be recovered from carriers over a 5-year stream of accessible kiosk orders.

83 Based on an average cost of $250 per kiosk, the variable hardware costs for all 30,000 new and replacement 

kiosks installed from 2017 through 2026 would be $7.5 million, or $4.5 million more than in the baseline scenario in 

this evaluation.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 48 of 72 Pages

Econometrica, Inc. October 23, 2013

Unquantifiable Compliance Costs

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:

 Additional costs associated with peripherals and software for new self-service 

functions. As noted above in the discussion of benefits, larger percentages of automated 

airport kiosks are expected to be deployed to handle transactions, such as baggage 

tagging and boarding, that require the traveler to be present at the airport. Kiosk 

manufacturers, carriers, and airports may incur additional hardware and software costs to 

support these capabilities. However, we do not have adequate data on the expected rate at 

which kiosks with these additional capabilities are expected to be deployed.

 Sunk costs of inaccessible kiosk development programs in progress. Carriers that have 

new hardware acquisition or software development programs in progress may determine 

that these programs no longer provide a positive return on investment before compliance 

with the accessibility standards is required.

 Occasional increases in kiosk waiting times for other travelers. Travelers who are 

familiar with kiosks may occasionally experience longer waiting times initially as new 

users become familiar with kiosk features and applications.

5.7. Estimated Net Benefits and Discussion of Results

Taking into account the benefits both to air travelers with disabilities and to carriers from 

adoption of the 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 in 2017 from the Rule requirements is expected to be –$0.1 million for the 10-year 

analysis period using a discount rate of 7 percent and $5.9 million for the same time period using 

a discount rate of 3 percent (Table 19).

Table 19–Present Value in 2017 of Accessible Kiosk Benefits and Costs, 2015–2026

Estimated Present Value

7 Percent

Discount Rate

3 Percent

Discount Rate

Total monetized benefits (millions) $34.77 $42.02 

Total monetized costs (millions) $34.88 $36.13 

Monetized net benefits (millions) ($0.12) $5.89 

The benefit and cost estimates developed for the kiosk accessibility requirements indicate that 

the present value of monetized benefits to travelers with disabilities and cost savings to carriers 

is approximately equal to the present value of the costs that will be incurred by carriers and 

airports to develop, program, install, and maintain accessible airport kiosks. The benefit and cost 

estimates for these requirements are sensitive to the values selected for a large number of 

component assumptions and estimates. Using certain reasonable alternative values for some of 

these component assumptions and estimates, the net benefits calculated may be positive even if a 

7 percent discount rate is used, and may be negative even if a 3 percent discount rate is used. In 

any event, the monetized net benefits of the kiosk accessibility requirements are very small in 
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 49 of 72 Pages

Econometrica, Inc. October 23, 2013

magnitude, indicating that the Department must weigh the unquantifiable benefits and costs to 

determine if the Rule would be in the public interest.

6. Evaluation of Rule Requirements for Accessible Web Sites

6.1. Current Industry Practices and the Need for Regulatory Requirements

Air travelers increasingly rely on carrier 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. 

The share of passengers conducting these transactions online is increasing rapidly. For example, 

a 2010 Airline Business/SITA airline survey indicated that the share of passengers checking in 

online was expected to increase from 21.6 percent in 2010 to 35.5 percent in 2013.84

Carrier sites also typically offer Web-only fare specials for flights and complete tour packages. 

Those with online booking engines (including all large carriers and an increasing share of 

smaller carriers) provide prospective purchasers with the ability to search 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 

some 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 Web 

sites. At present, there are no statutory or regulatory requirements to ensure that carrier Web sites 

are accessible to consumers with these types of disabilities.

We conducted an extensive review of the characteristics and accessibility of U.S. and foreign 

carrier Web sites in May 2011 to support the PRA that accompanied the SNPRM. A summary of 

the result from this review was provided in the PRA. An updated version of this summary is 

included in this evaluation for reference in Appendix B. The appendix also provides some 

background on the technical aspects of Web sites that are relevant for assessing the impact of the 

Rule requirements in this area. 

Among the carrier Web sites included in our review, only Delta Airlines appeared 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 Web sites afforded different degrees of accessibility for air travelers with disabilities. 

Most of the home pages of the carrier Web sites we reviewed had violations of 8 or more WCAG 

2.0 accessibility guidelines and more than 50 separate issues that will need to be addressed to 

meet the Level A and Level AA compliance standards.85

 

84 Airline Business/SITA, op. cit., 2010.

85 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 Websites 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,” Bristol, England: 

Nomensa, June 2011, for recent studies of U.S. and United Kingdom carrier Web sites, respectively.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 50 of 72 Pages

Econometrica, Inc. October 23, 2013

Current Department regulations require carriers to offer Web-only fares and other promotions to 

callers with disabilities 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.86

6.2. Rule Requirements and Alternatives Considered to Address Identified 

Needs

The Rule requires all large U.S. and foreign carriers that market air travel to the general public in 

the United States to ensure that the content on their primary Web sites is completely compliant 

with the WCAG 2.0 Level A and Level AA performance criteria within 3 years of the effective 

date of the Rule. Web pages, forms, and applications relating to core functions, such as booking 

a flight, checking in online, getting flight status information, and accessing frequent flyer 

accounts, will need to be compliant with these standards within 2 years of the effective date of 

the Rule.

Carriers will also be required to ensure that their authorized ticket agents make available all 

Web-based special fares or services upon request to customers who indicate that they cannot use 

a ticket agent’s Web site due to their disability.

87

These requirements are different in some important respects from those proposed in the SNPRM:

 The first of the three “tiers” of requirements proposed in the SNPRM was that new or 

substantially overhauled Web sites would have been required to be accessible 6 months 

after the effective date. This requirement has been dropped in the Rule.

 Pages, forms, and applications supporting core functions would have had to be available 

in an accessible form on either the carrier’s primary Web site or the carrier’s mobile 

version of its Web site within 1 year after the effective date under the proposed rule. The 

Rule requires that these functions be accessible on the primary Web site within 2 years of 

the effective date.

 All content, forms, and applications were to be accessible on the primary Web site 2 

years after the effective date of the proposed rule. The Rule extends the compliance 

deadline to 3 years after the effective date.

 Carriers will be required to include (accessible) disability accommodation request forms 

on their Web sites.

 Small carriers that do not operate any aircraft originally designed with more than 60 seats 

and carriers that do not market air transportation to the general public in the United States 

will not be required to ensure that their Web sites are accessible. Small carriers would 

 

86 Lazar et al., op. cit., 2010.

87 This regulatory evaluation does not include any costs incurred by ticket agents in providing Web-based amenities 

to passengers who cannot access their Web sites due to a disability.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 51 of 72 Pages

Econometrica, Inc. October 23, 2013

have been required to have accessible Web sites under the requirements in the proposed 

rule.

 The Final Rule does not require ticket agent Web sites to be accessible. The proposed 

requirements for Web site accessibility in the SNPRM would have applied to all ticket 

agents with annual receipts in excess of the 2011 SBA size-class thresholds for small 

business ($3.5 million annually for travel agents and $7.0 million for tour operators). 

In addition to the proposed requirements in the SNPRM and the requirements adopted in the 

Final Rule, the Department requested an evaluation of the impact of some alternative 

accessibility compliance timetables. Specifically, we were asked to evaluate the feasibility, 

benefits, and costs of the following options:

 Requiring all carrier Web sites to comply with the WCAG 2.0 Level A and Level AA 

guidelines and success criteria 1 year after the effective date.

 Requiring all carrier Web sites to be compliant with the WCAG 2.0 Level A and Level 

AA standards 2 years after the effective date.

6.3. Discussion of Comments Received

The Department received a substantial number of comments about various aspects of the PRA 

evaluation of the proposed requirements for Web site accessibility. Major issues addressed 

included the timetable for compliance, the nature and extent of the benefits and costs, and the 

data and procedures used to quantify these benefits and costs. In general, carriers and ticket 

agents indicated that the tiered compliance requirements would be difficult to meet and would 

increase compliance costs, that the estimation of time savings for people with disabilities from 

accessible Web sites was overstated, and that compliance costs were understated. Disability 

advocates supported the shortest possible time frame for compliance and stressed the 

unquantifiable benefits of equal access to online air travel-related information and services. This 

section summarizes relevant comments and outlines the changes made to the PRA to take into 

account these comments. Further discussion of specific issues relating to benefits and costs is 

provided in the following sections, which detail the estimation of monetized benefits and costs 

associated with the Web site accessibility requirements in the Final Rule.

6.3.1. Comments About Compliance Timetable

Several comments indicated that the proposed compliance timetable in the SNPRM was not 

feasible for carriers with large, complex Web sites:

Converting airline websites to meet any accessibility standard is a major 

undertaking. Carriers need additional time to plan, design, incorporate, and test 

websites after the final rule. We therefore recommend the Department provide a 

2-year compliance period for all of the four options suggested above.88

 

88 A4A et al. comments, p. 15.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 52 of 72 Pages

Econometrica, Inc. October 23, 2013

With at least a two year period before the first effective date, airlines can build a 

common WCAG 2.0 Level AA standard into core website functions and avoid 

costly retrofit of existing pages.89

More time is needed after adoption of a final rule to ensure the Department can 

provide this necessary guidance before airlines are required to be fully compliant 

with whatever standard is adopted. A longer implementation will result in better 

accessibility because airlines will have a longer time to work out issues, lower 

costs, and not create any significant disadvantage for passengers with 

disabilities.90

El Al is particularly concerned about the timeframe for implementation of the 

Web site accessibility requirements, particularly the changes that the Department 

has proposed to be implemented one year after the effective date of the final rule. 

As the Department has learned over the years, the ability of a carrier to comply

with the Department’s Web site regulations is dependent, particularly for smaller 

carriers, upon the ability and willingness of outside vendors to make changes in a 

Web site to meet a regulatory deadline. Carriers are similarly dependent upon 

software companies and their rollout schedules to meet regulatory deadlines, thus 

forcing carriers to purchase an old version of a particular platform to meet a 

compliance date even if a new version of the platform would improve compliance 

with the new regulation. Lastly, it is axiomatic that, the tighter the regulatory 

deadlines within which to comply with a regulation involving significant amounts 

of reprogramming, the greater will be the cost of compliance and more technical 

obstacles will stand in the carriers' way.

91

The longest time frames suggested in the SNPRM comments and those submitted in response to 

the DOJ ANPRM comments were 18 months for new pages and 36 months for existing pages. 

Others indicated that these targets could be accomplished in 12 and 24 months, respectively. 

Requiring compliance of all pages, forms, and applications relating to core functions within 24 

months—the timetable required in the Final Rule for large U.S. and foreign carriers—is 

generally recognized as feasible in the carrier comments. 

In contrast, disability advocates believe that the compliance time frame should be much shorter:

The proposed rule gives carriers one year to make pages providing core air travel 

services accessible, but we believe this is unnecessarily long. Newegg.com, an ecommerce business, made its entire retail/transactional path fully accessible in 

less than six months, illustrating that the technology already exists to accomplish 

 

89 AAI comments, p. 1.

90 Spirit comments, pp. 9−10.

91 El Al Israel Airlines (hereinafter, El Al), “Comments in the Matter of Nondiscrimination on the Basis of 

Disability in Air Travel: Accessibility of Web Sites and Automated Kiosks at U.S. Airports,” January 9, 2012, p. 3.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 53 of 72 Pages

Econometrica, Inc. October 23, 2013

the task in a rather short period of time. We suggest shortening the timeline for 

existing pages that offer core services from one year to 180 days.92

The Newegg.com site is not necessarily a valid benchmark, because it is substantially less 

complicated than existing airline Web sites.

93 In addition, Web developers will have to be able to 

work with a variety of airline-specific database and transaction functions.

Carrier associations, individual carriers, and ticket agent representatives all indicated that a 

single deadline to meet all of the Web site accessibility requirements was much more feasible 

than having to develop multiple interim solutions:

AAPA submits that the 2-year implementation deadline be applied to all 

enhancements rather than breaking the implementation deadline to different 

phases. This would allow carriers the flexibility to conduct their respective project 

plan and management based on their resources and objectives.94

ANA envisions that it could complete all of the necessary measures within 2 

years, the proposed accelerated 1-year timeframe for implementing changes to 

“core” web pages (i.e., associated with changing or booking a reservation) is not 

feasible; these are in fact the most complicated of the tasks to be performed, and 

deferring work on other pages would not enable their enhancement to occur any 

faster. Preferably, the 2-year deadline should apply to all enhancements, and not 

just to non-core pages.95

The tiered implementation timelines for new sites, booking pages, and older sites 

is not feasible. Hence, ITSA would urge the Department to impose one single 

implementation date, as opposed to a phased-in requirement.96

Based on this input, the Department has modified the staged compliance deadlines in the Rule. 

Web content, forms, and applications relating to core functions would have to be compliant 

within 2 years of the effective date. The Department expects that most primary Web sites of 

covered carriers will be completely compliant within 2 years. However, an additional year was 

added for non-core functions to accommodate carriers with atypically large or complex Web 

sites.

 

92 NFB comments, p. 3.

93 A recent review by Web site accessibility experts found that accessibility problems remain, even on online retail 

sites, including those that were the subject of previous accessibility settlements or negotiations. See Donald Evans, 

Preety Kumar, and Jim Thatcher, “The Current State of Accessibility among the Top On-line Retail Sites,” last 

updated November 30, 2011.

94 Association of Asia Pacific Airlines (hereinafter, AAPA), “Comments in the Matter of Nondiscrimination on the 

Basis of Disability in Air Travel: Accessibility of Web Sites and Automated Kiosks at U.S. Airports (Supplemental 

Notice of Proposed Rulemaking),” January 9, 2012, p. 5.

95 All Nippon Airways (hereinafter, ANA), “Comments in the Matter of Nondiscrimination on the Basis of 

Disability in Air Travel: Accessibility of Web Sites and Automated Kiosks at U.S. Airports,” January 9, 2012, p. 5.

96 Interactive Travel Services Association (hereinafter, ITSA), Letter providing comments on the Department’s 

September 26, 2011, Supplemental Notice of Proposed Rulemaking, January 9, 2012, p. 4.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 54 of 72 Pages

Econometrica, Inc. October 23, 2013

6.3.2. Comments About Benefit Estimates

The joint carrier association comments indicated that the PRA overstated the search time 

savings:

This time savings assumption is incorrect and the Department provides only

anecdotal evidence to support this faulty assumption. The PRA states that this 

time savings is based on Econometrica, Inc staff reviewing carrier websites with a 

screen reader such as JAWS or Window-Eyes. This is hardly a structured or 

objective study, which is reflected in the conflicting results....

Table 21 inexplicitly adds the tier two and tier three time savings before 

multiplying by the other factors. This is an invalid estimate because the PRA 

overstates the time savings by failing to net out time already saved under the tier 2 

requirements. It does not make sense to add the tier two and tier three values in 

Table 21, when the Lazar study focused on general website screen reader 

problems; the Lazar study did not factor in the benefit or time savings already 

claimed for meeting the tier two requirements.97

We believe that the PRA time savings for both primary and mobile Web site homepages were 

developed using reasonable sources and tools. The joint carrier association comments do not 

provide an alternative estimate or evidence that the PRA estimate was incorrect. Also, the time 

savings from Tier 2 accessibility were in fact netted out of the Tier 3 benefits, as was explained 

in the PRA. However, we have developed a single set of benefit estimates to analyze the impact 

of the Rule.

Another comment argued that the PRA overestimates the number of passengers with low vision 

who would benefit from accessible Web sites:

This estimate assumes that all visually impaired passengers benefit from 

accessible websites, even if they never visit airline sites and book via telephone, 

ticket counter, or travel agency. Econometrica assumed that all blind/severe visual 

impaired passengers (2,001,197) who travel by air (31.5%, from Table 4) and who 

are online (54% in 2012, from Table 3) benefit. This overstates benefits since 

many Internet-connected passengers will book directly with live agents at call 

centers or agencies with no discernible difference in benefits.98

In addition to booking flights, Internet-connected passengers use carrier Web sites to obtain 

information before booking and conduct other transactions (such as online check-in). These 

passengers also benefit from accessible Web sites. In addition, the information gained online 

may significantly reduce the amount of time required to book with live agents at call centers. 

It is worth pointing out that recent industry studies indicate that the proportion of air travelers 

who book flights and conduct other transactions online is increasing rapidly. For example, a 

 

97 A4A et al. comments, pp. 19−21.

98 AAI comments, p. 9.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 55 of 72 Pages

Econometrica, Inc. October 23, 2013

recent PhoCusWright study indicated that 84 percent of discretionary travelers (i.e., those who 

travel more than 3 times per year and who select their own destinations) book flights online.99

6.3.3. General Comments About Cost Estimates

A large number of comments suggested that the PRA underestimates the overall costs of 

converting existing Web sites, especially for the “very large” and “largest” categories:

The PRA costs are significantly underestimated and must be corrected before 

proceeding with this rulemaking. For tier three compliance costs, the PRA 

estimates a $225,000 cost per “largest” carrier web site.... However, based on a 

survey of A4A airlines, the cost to comply with the tier three standards for the 

“largest” airline web sites ranges from $241,000 to $1.9 million per carrier with a 

median cost of $1.1 million.100

DOT’s cost estimates for airline compliance continue to be unreasonably low. 

While DOT cites changes in website technology that may streamline WCAG 2.0 

compliance, DOT does not account for new capability in airline websites that 

have significantly increased the number of pages and back-end databases that 

must be altered for compliance. DOT identifies this complexity in the SNPRM, 

stating “carriers offer an ever-expanding array of services on their Web sites 

today.” DOT must incorporate comment from carriers in this rulemaking with 

current estimates for WCAG 2.0 Level AA compliance. We believe that previous 

industry estimates of $300,000 to $1 million per airline continue to be realistic 

starting points for compliance costs.101

Bringing Spirit’s Web site into compliance with WCGA 2.0 Level AA Criteria 

Standards will cost $412,800. That is four times the PRA’s cost estimate for a 

large website.102

El Al is concerned that the Department has significantly understated the actual 

costs of compliance that will be incurred by the airlines in meeting the 

Department’s proposed regulation. El Al’s preliminary analysis of the costs that it 

may be required to incur to comply with this proposed Web site accessibility

standard could be as high as $2 million, a significant expenditure for a company 

that operates a total of only 38 aircraft and provides less than 10% of its total 

worldwide service to the United States.103

DOT has drastically underestimated the costs that the proposed regulations would 

impose on ANA, and presumably on other carriers.... ANA expects that 2500 

content pages on its website, and 350 dynamic booking engine pages, would need 

 

99 Carroll Rheem, “Empowering Inspiration: The Future of Travel Search,” PhoCusWright study for Amadeus, 

February 2012.

100 A4A et al. comments, pp. 21−22.

101 AAI comments, p. 9.

102 Spirit comments, p. 4.

103 El Al comments, p. 4.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 56 of 72 Pages

Econometrica, Inc. October 23, 2013

to be updated. ANA expects that the initial process of reviewing the WCAG 

requirements and the current features of its website to which they would need to 

be applied would by itself require at least 6 months and at least $250,000. Further, 

ANA estimates that actually implementing the changes would require at least an 

additional 12 months (2 months for coordination, 8 months for production and 

development, and 2 months for testing) and would cost $6 million (of which $5.5 

million would be needed for revisions to the booking engine and $500,000 would 

be needed for other elements of the website; considerably more time and effort 

would be required to ensure the compliance of dynamic pages). In support of this 

project, ANA expects that more than 20 employees would need to be devoted to 

this project, either full- or part-time. Additionally, ANA estimates that ensuring 

ongoing compliance of both the content pages on its website as well as the 

booking engine would cost more than $1.5 million per year.104

However, it is not clear which of these reported cost estimates, if any, are specified in terms of 

the incremental costs of building accessibility into new or overhauled primary Web sites, rather 

than retrofitting existing Web sites. For example, IT experts estimate that accessibility

requirements increase development and programming costs by 5 to 7 percent. If this is correct, 

the ANA estimate implies that overhauling a large carrier Web site could cost as much as $100 

million, which does not appear to be reasonable.

In addition, it should be noted that the range of estimated costs provided in various carrier and 

association comments is very large. For example, the median cost estimate from the A4A survey

is larger than the top end of the range of previous industry estimates cited in the AAI 

comments.105 However, the cost estimates in the final regulatory evaluation have been revised to 

take into account information provided in these comments. 

Some comments also specifically indicated that the PRA underestimates the ongoing annual 

costs of updating and maintaining accessible Web sites:

The PRA estimates the ongoing annual web site maintenance costs to be $912,600 

for the largest carriers (39 total) as each website was assumed to incur $23,400 in 

annual maintenance expense. ... Based on a survey of A4A airlines, the corrected 

“largest” carrier web site annual maintenance cost would range between $76,000 

and $575,000 with a median cost of $326,000 per carrier.

106

The analysis contained in the Preliminary Regulatory Analysis (at 54) has 

understated, in Table 24, the ongoing annual site maintenance costs for large, 

small, and the smallest carriers. This understatement came about because the 

calculation of the total hours required for the large, small, and smallest entity

 

104 ANA comments, pp. 4−5.

105 No explanatory detail on the survey methodology or results was provided in the A4A comments, nor was a copy

of the survey questionnaire and instructions attached.

106 A4A et al. comments, item 31 on back table.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 57 of 72 Pages

Econometrica, Inc. October 23, 2013

failed to include the 0.2 hours for “each site page” that was properly calculated 

for the largest entities.107

Because no supporting documentation was provided for the A4A survey, it is not possible to 

determine whether the cost estimates provided include amounts that would have been spent on 

Web maintenance functions in the absence of accessibility requirements. However, the annual 

maintenance cost estimates used in the final regulatory evaluation have been revised to respond 

to this concern. In addition, the revised estimates no longer rely on the calculations that 

contained the error noted in the Virgin comment.

Finally, the joint carrier association comments argue that the PRA underestimates the number of 

pages on large carrier Web sites:

As discussed further in our cost/benefit comments, the Departments’ estimates 

grossly underestimate the scope and impact of the proposal. Given the 

clarification that the proposal applies, at a minimum to all webpages that contain 

the carrier’s name in the URL, 900 pages for the largest sites is understated 

between a factor of 10 and 100. Also, 1,500 hours to modify the largest websites 

is off by a factor of 35. Marco Marten is quoted in the SNPRM comment period 

extension as describing a 50 to 300 webpage project as “small.” 108

It is correct that some of these sites have a very large number of pages. However, the sites we 

reviewed either generate these pages dynamically (e.g., populating a single page using a serverside database) or use common templates to create a large number of similar pages. The per-page 

costs of ensuring this content meets the accessibility requirements are much lower than for other 

types of pages. However, the compliance cost estimates in this regulatory evaluation are 

developed from overall site revision cost estimates for different categories of carrier Web sites, 

rather than being calculated on a fixed cost plus per-page charge basis.

6.3.4. Comments About Cost Impact on Ticket Agents

Travel agent and tour operator association comments indicated that the PRA underestimates the 

number of pages and costs of making the booking system accessible on ticket agent Web sites:

Of the 328 large agencies estimated by DOT to be impacted by this part of the 

rule, four (4) companies (Expedia, Orbitz, Priceline and Travelocity) according to 

PhoCusWright, account for 96 percent of all online leisure sales. The remaining 

324 large agencies account for just 4 percent of travel agency online leisure sales. 

These agents will be required to upgrade their online booking tool and website to 

meet DOT’s accessibility standards. This group will be significantly impacted by

the rule, as they will not have the resources of the large Online Travel Agents. 

They also must compete with four major OTAs that account for 96 percent of all 

leisure online sales, while at the same time they compete with the 1,277 agencies 

 

107 Virgin America Airlines, “Comments in the Matter of Nondiscrimination on the Basis of Disability in Air Travel: 

Accessibility of Web Sites and Automated Kiosks at U.S. Airports,” January 9, 2012, p. 2.

108 A4A et al. comments, p. 22.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 58 of 72 Pages

Econometrica, Inc. October 23, 2013

that have online booking engines that are not subject to the economic burden of 

this rule.109

Many of USTOA’s members have more than double the number of impacted 

pages than assumed under the PRA, in particular members that operate separate 

brands, each with its own Web site. In this regard, USTOA submits that a more 

realistic estimate is 2,490 impacted pages for the “largest” tour operators, 830 

impacted pages for “large” tour operators, 330 impacted pages for “small” tour 

operators, and 275 covered pages for the “smallest” tour operators....

The PRA acknowledges that costs for training (other than for conformance 

evaluation and certification) were not included in the estimate. PRA at 49−50. 

Additionally, the maintenance costs of checking to ensure that a Web site 

complies with the new standards each time it is updated, which the PRA states 

may “make updating the Web site more time consuming,” were not included. 

Similarly, the cost of requiring “[e]xisting and new personnel ... to undergo extra 

training before starting work on a covered air travel Web site” were excluded. Id. 

USTOA estimates all of these excluded costs will likely average $27,000 per tour 

operator each year, reflecting the cost of equipping internal Web design and 

maintenance teams with the knowledge and skill sets necessary to maintain 

accessible pages. As a consequence, the ongoing maintenance costs over a ten 

year period are further increased by at least $25 million.110

The Department has decided not to require the travel agent and tour operator Web sites to 

comply with the accessibility requirements for reasons set forth in the Rule preamble. However, 

ticket agents with annual revenues that exceed the limit set forth in the applicable SBA small 

business size class standards ($19.0 million for both travel agents and tour operators in 2013) 

will be required to disclose and offer Web-based discount fares to prospective passengers who 

contact the agent through other channels (e.g., by telephone or at the ticket counter) and indicate 

they are unable to use an agent’s Web site due to a disability.

6.4. Compliance Scenarios Evaluated

The benefits and costs associated with Web site accessibility requirements depend on the time 

frame during which carriers may be reasonably anticipated to achieve compliance and the extent 

to which compliance can be achieved as part of a Web site overhaul or redesign that would have 

taken place in the absence of the Rule. Accordingly, we collected data on the frequency with 

which large and small carrier Web sites have been substantially redesigned or overhauled in 

 

109 American Society of Travel Agents (hereinafter, ASTA), “Comments in the Matter of Nondiscrimination on the 

Basis of Disability in Air Travel: Accessibility of Web Sites and Automated Kiosks at U.S. Airports,” January 6, 

2012, pp. 4−5.

110 United States Tour Operators Association (hereinafter, USTOA), “Comments in the Matter of Nondiscrimination

on the Basis of Disability in Air Travel: Accessibility of Web Sites and Automated Kiosks at U.S. Airports,”

January 9, 2012, pp.13−14.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 59 of 72 Pages

Econometrica, Inc. October 23, 2013

recent years. Estimates of the time required for site overhaul were provided in the SNPRM 

comments, as well as in comments in response to the previous DOJ ANPRM.

Frequency of Site Overhaul

All carriers that market air transportation directly to the general public currently maintain publicfacing Web sites. Nearly all reporting carriers appear to have undertaken significant “facelifts” of 

their sites every 1 to 2 years, based on review of screenshots of selected carrier home pages 

viewed using the “Wayback Machine” at www.archive.org.

111 Several other large carriers 

(Allegiant, Spirit, and Sun Country) have made systematic revisions to their Web sites within the 

past year. Accordingly, it is appropriate to assume that most large carriers will undertake 

complete overhauls of their Web sites during the 2-year interval in 2014 and 2015 before the 

accessibility standards become effective. Incorporating accessibility into these comprehensive 

revisions will substantially reduce compliance costs for most large carriers.

Smaller U.S. carriers appear to overhaul their Web sites somewhat less frequently than do larger 

carriers. Of the 18 sites reviewed on www.archive.org, 4 (22 percent) had not been overhauled 

during the past 3 years. In the PRA, we found that the majority of these carriers operate 

relatively simple Web sites that do not offer online booking, check-in, or flight status updates. 

However, a recent review indicates that online booking engines have been added to a significant 

number of these Web sites during the past 15 months. In fact, all 7 small carriers and half of the 

30 very small carriers that market scheduled air transportation to the general public offer the 

capability to book flights online. Given the recent addition of these new capabilities and the 

relatively small number of passengers on small carriers who market air transportation to the 

general public in the United States, the Department has decided not to require small carrier Web 

sites to comply with the accessibility requirements in the Rule.

Time Window for Sites That Can Be Made Compliant

Carriers that develop and launch new versions of their Web sites before the effective date will 

incur lower compliance costs than those that will need to retrofit existing Web sites. Therefore, it 

is reasonable to expect that the ability to realize these savings may result in delayed launches of 

some new sites in the first year after the Rule is published.112 Similarly, some carriers that would 

have otherwise undertaken full-scale Web site revisions 2 years after the effective date of the 

Rule will be likely to accelerate this timetable to avoid having to retrofit current Web pages. 

 

111 Among reporting carriers, only the AirTran and Southwest Web sites had retained the same home page structure 

and “look and feel” for more than 2 years at the time this review was conducted.

112 Web site design timelines available on the Internet are often based on start-to-finish implementation times of 

between 4 and 6 months. However, given the complexity of large carrier Web sites, we assumed that sites 

overhauled within 1 year of the effective date of the Rule will need some supplemental work to achieve full 

compliance with the standards.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 60 of 72 Pages

Econometrica, Inc. October 23, 2013

Consequently, it would be reasonable to assume that no large carriers will undertake substantial 

retrofitting of current Web pages. For the remaining sites, compliance with the accessibility 

requirements would be accomplished as part of the next major site overhaul.113

Alternative Compliance Time Frames Considered

The Department explored the feasibility of requiring large-carrier compliance with the applicable 

accessibility standards within 12 months. However, several of the carrier and association 

comments on the SNPRM indicated they would not be able to develop Web site components 

(particularly booking engines) that comply with the Level A and Level AA accessibility

standards within this compressed time frame. Per-carrier costs of retrofitting current Web sites 

on an accelerated time frame would be expected to be two to four times larger than those 

estimated in this evaluation for integrating accessibility into the next major revision or overhaul.

The Department also considered requiring carriers to bring their entire primary Web sites into 

compliance with the Level A and Level AA standards within 2 years of the effective date of the 

Rule. Under this alternative, a few large carriers may be required to undertake retrofitting of 

portions of their current Web sites. Because the core functions on these Web sites will be 

accessible within 2 years of the effective date, the benefits to users of accessible Web sites will 

not be substantially diminished by extending the compliance date for remaining portions of large 

carriers’ primary Web sites to 3 years after the effective date.

6.5. Estimated Benefits of Rule Requirements

Benefits to Passengers With Disabilities

The Rule requirements will permit travelers with disabilities to benefit from increased access to 

the full range of information and services available to online customers, including:

 More consistent 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 

purchasing preferred seating, pre-paying baggage fees, and checking in online.

 Easier access to personal and general air travel information and policies, including trip 

itineraries and flight status inquiries, frequent flyer accounts, and relevant carrier policies 

and restrictions.

In addition, the Rule would enable travelers with disabilities to request disability 

accommodations online.

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 

 

113 This is the approximate percentage of large carrier Web sites that did not appear to have undergone a major 

overhaul within the past 3 years. Because this percentage was very low, we did not explicitly estimate the additional 

increment of cost that these limited number of carriers would incur to retrofit certain pages on their Web sites.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 61 of 72 Pages

Econometrica, Inc. October 23, 2013

Web site technologies and screen readers.114 Removing or reducing these barriers to access will 

reduce the amount of time it will take for travelers with disabilities to realize the reduced 

expenditures, more efficient transactions, increased availability of information, and other 

benefits associated with access to carrier Web sites. The estimated benefits to travelers with 

disabilities in the form of time saved from being able to use accessible carrier Web sites depend 

on several factors, including:

 The number of current and future air travelers who use screen readers, other assistive 

technologies, and user-controlled browser settings to access carrier Web sites.

 The extent to which these customers will use accessible carrier Web sites.

 The amount of time that could 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.

For this analysis, we assumed that each air traveler with a disability who could use (and therefore 

benefit from) accessible carrier Web sites would visit an average of six sites per trip: four during 

the planning and booking phase of the trip, one to obtain flight information and/or check in, and 

one to check or sign up for flight status updates.115 Each of these visits was assumed to take an 

average of nearly 10 minutes, the average time spent by visitors to the top five travel company 

sites in April 2012.116

Based on these assumptions and estimates, air travelers with disabilities who would be able to 

use accessible carrier Web sites would save an average of 17.3 minutes per trip (Table 20).

 

114 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. 

115 Of course, some individual travelers may use carrier sites more extensively than others or use different services.

116 Nielsen Top 10 U.S. Online Brands and Travel Websites,” April 2012. Travel search on such sites as Google and 

Yahoo! was not included because these sites do not provide services and functionality that are comparable to those 

of carrier Web sites.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 62 of 72 Pages

Econometrica, Inc. October 23, 2013

Table 20–Annual Time Savings per Passenger From Web Accessibility Requirements

Calculation Component Number

Number of Web site visits per trip

Trip planning and booking 4

Flight information or check-in 1

Flight status information 1

Total number of site visits per trip 6

Average minutes spent per site 9.5

Minutes per trip spent on carrier Web sites 57

Percent of time saved by accessibility 30.4%

Minutes saved by accessibility 17.3

Time saved per traveler (hours)* 0.29

*Applies only to travelers using online booking and other core Web site functions.

The number of potential beneficiaries who would realize these time savings is calculated using 

the following assumptions and estimates:

 Potential beneficiaries include people with vision difficulties (8.1 million adults in 2010), 

with severe hearing problems (1.1 million adults), and using a wheelchair (3.4 million 

adults). The population of potential beneficiaries increases in each subsequent year by the 

forecast FAA passenger growth rates for U.S. carriers.

117

 Some people with these disabilities have limitations that are not completely addressed by

the Web site accessibility requirements. Others have disabilities that do not limit the 

utility of current inaccessible Web sites. There are also some people with other 

disabilities (such as fine-motor-skill limitations or certain cognitive disabilities) who may 

also benefit from accessible Web sites. For this analysis, we assumed that 50 percent of 

the people in each of the three disability categories listed above will benefit from the 

availability of accessible carrier Web sites.

 Not all people with disabilities addressed by the Web site accessibility requirements 

travel by air in a single year, and not all who do so would use the Web sites of carriers 

that are covered by the Rule. The number of people who would actually use accessible 

carrier Web sites to plan and book air travel within a year was estimated by taking into 

account:

o The BTS estimate of the percentage of people with disabilities who have traveled 

by air in the past year (31.5 percent)

o The proportion of people with disabilities who are online (54 percent in 2010, 

according to the 2011 Pew Internet and American Life study), adjusted by the 

proportion of people who book travel online (81 percent). The share of travelers 

with disabilities is assumed to increase by 2 percent each year, consistent with the 

observed increase in the online rates of people with disabilities over the past 10 

years.

 

117 These estimates are presented and discussed in Sections 2.1 and 3.1, above.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 63 of 72 Pages

Econometrica, Inc. October 23, 2013

Using these estimates and assumptions, the total number of beneficiaries is calculated as 

presented in Table 21.

Table 21–Estimated Number of Travelers Benefitting From Web Site Accessibility

Calculation Component 2016 2016−2025

People with vision problems* (age 15 or older) 9,113,005 101,026,243

People with severe hearing problems (age 15 or older) 1,236,579 13,664,664

People using wheelchairs (age 15 or older) 3,798,871 41,978,952

Total people with selected disabilities 12,540,000 156,669,859

Assumed share potentially addressed by standards 50% 50%

Total people potentially benefitting from accessibility 7,074,228 78,334,930

Percent traveling by air annually 31.5% 31.5%

Percent traveling on covered carriers 94.8% 94.8%

Percent visiting online travel sites 55% 61%

Total number of passengers who benefit 1,161,736 15,057,067 

*Vision problems not correctable with glasses or contact lenses.

Based on these estimates and assumptions, an estimated 1.2 million passengers with disabilities 

would benefit in 2016, the first year in the 10-year analysis period. Approximately 15.0 million 

people with disabilities would benefit from the availability of accessible carrier Web sites over 

the entire 10-year analysis period.

The time savings estimated for these passengers is valued at $18.00 per hour, the rate used for 

valuing nonair intercity travel time improvements in the most recent DOT guidance.118

Cost Savings to Carriers

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 people with disabilities who are unable to conduct transactions or locate 

information online. These benefits are calculated based on an average savings per avoided call of 

$3.43, the average of five estimates of direct and supervisory labor costs reported in two analyses 

of call center costs.

119 For this analysis, we assumed that the number of calls from passengers 

with disabilities who are projected to use accessible Web sites would be reduced by 50 percent.

 

118 Air travel time savings are valued at a higher rate, reflecting the larger proportion of air travel that is for business 

purposes. Because travelers with disabilities are more likely to be over 65 or unemployed, the lower hourly rate 

associated with other forms of intercity travel was used in this analysis. See the discussion in OST, op cit.

119 Average of Barry and Company low ($1.39) and high ($4.75) and Strategic Contact large ($3.72), medium 

($3.33), and small ($4.97) contact center labor costs per call. See Jeffrey Barry, “Managing Your Cost per Call,” F. 

Curtis Barry & Co., 2012; and Lori Bocklund and Brian Hinton, “Cost Structure and Distribution in Today’s 

Contact Centers,” Strategic Contact, March 2008. The PRA estimated cost savings of $5.50 per avoided call was 

cited from a Forrester Research study by Megan Burns with Moira Dorsey and Angela Beckers, “Need To Cut 

Costs? Improve The Web Site Experience,” December 1, 2008.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 64 of 72 Pages

Econometrica, Inc. October 23, 2013

Monetized Benefits of Web Site Accessibility

Based on these component estimates and assumptions, monetized benefits accruing to passengers 

with disabilities and carriers from accessible carrier Web sites were calculated as presented in 

Table 22.

Table 22–Monetized Benefits of Carrier Web Site Accessibility Requirements

Calculation Component 2016 2016−2025

Total number of site visitors who benefit 1,161,736 15,057,067 

Hours saved per person annually 0.3 0.3

Value of time saved per hour $18.00 $18.00

Total benefits to site visitors $6,039,167 $78,272,655

Estimated benefits from call center savings

Percent reduction in calls from accessible site users 50% 50%

Total number of avoided calls 580,868 7,528,533 

Cost savings per avoided call $3.43 $3.43

Total cost savings from avoided calls $1,993,539 $25,837,926

Total monetized benefits $8,032,706 $104,110,581

Present value of benefits in 2016 (millions)* $75.92 

*Present value of benefits calculated using a discount rate of 7 percent.

Total benefits are estimated at $8.0 million during 2016 and $104.1 million for the 10-year 

analysis period from 2016 through 2025. The present value in 2016 of benefits realized during 

this period is estimated at $75.9 million using a discount rate of 7 percent.

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 carrier Web sites. Although we did not do so 

for this 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 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 analysis estimates the amount of time saved only for people who are blind or have severe 

difficulty seeing. Additional benefits may be realized by people 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 people who cannot use a mouse). Notwithstanding the 

conservative nature of these estimates, the monetized benefits of the Rule requirements are 

substantial—beginning at approximately $8 million in the first year after most carrier Web sites 

become fully compliant with the WCAG 2.0 accessibility standards.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 65 of 72 Pages

Econometrica, Inc. October 23, 2013

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:

 Increased independence and self-sufficiency. Accessible Web sites will provide 

travelers with a greater range of trip planning, booking, and information. Having this 

expanded set of choices available clearly has value to travelers with disabilities, but the 

monetary value of this choice cannot be quantified.

 Improved accessibility for people with other disabilities. Making Web pages meet 

WCAG 2.0 AA standards will 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.

 Reduced problems with service accommodation requests. The Rule requires large 

carriers to provide an accessible online service accommodation request form. Requests 

submitted in this fashion will provide both passengers and carriers with a standardized 

electronic record of the request, which may reduce the number of problems that arise in 

handling these requests and ensuring that the requested services are provided.

 Reduced effort and cost for international carrier Web sites to comply with future nonU.S. accessibility requirements. As noted above in Section 1.4, many foreign 

governments have adopted, or are in the process of adopting, Web site accessibility 

requirements based on the WCAG 2.0 standards. Carriers that have Rule-compliant Web 

sites will be able to comply with these requirements without having to revise the portions 

of their Web sites that market transportation to the general public in the United States.

 Easier Web site maintenance, debugging, and documentation. Several of the WCAG 

2.0 standards require use of coding procedures that will improve Web developers’ 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.

It is worthwhile to reiterate that many foreign government entities have developed or are 

developing Web site accessibility requirements based on the WCAG 2.0 Level A and Level AA 

standards. To the extent that these requirements are adopted or take effect within the time frame 

permitted under the Rule to bring Web sites into compliance, carriers with multinational 

operations (i.e., nearly all of those covered by the Rule) will incur reduced costs to meet pending 

or future Web site accessibility requirements adopted by foreign governments.

6.6. Estimated Costs of Rule Requirements

Carriers 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 to 

incur costs associated with making it possible for visually impaired 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 
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 66 of 72 Pages

Econometrica, Inc. October 23, 2013

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).

Determinants of Compliance Costs

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 (hypertext markup language), PHP (hypertext 

preprocessor), 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 WAI site and other online programming guides, it is clear that 

the time involved to “retrofit” existing Web pages is much longer 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.120

The analysis presented in the PRA included compliance cost estimates for one-time revisions of 

the current carrier and ticket agent Web sites. Work required to revise inaccessible sites will 

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.

While the PRA acknowledged that the training and expertise in accessibility issues of carrier and 

ticket agent Web development teams for affected carriers will vary, no provision for training or 

outside consultants (other than for conformance evaluation and certification) was included in the 

cost estimates.

Web Site Accessibility Compliance Cost Estimates

Carrier associations and individual carriers provided a wide range of compliance cost estimates, 

from a low of $241,000 (the lowest estimate in the A4A survey) to an ANA estimate of $6 

million. No documentation was provided for the A4A survey, and it is not clear that the survey 

instructions asked respondents to estimate incremental costs, or those above and beyond the 

 

120 See, for example, W3C, “Technical Factors in Developing a Web Accessibility Business Case for Your 

Organization.”
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 67 of 72 Pages

Econometrica, Inc. October 23, 2013

costs associated with a normal Web site overhaul. The high-end estimate of $1.9 million from 

the A4A survey is suspect on these grounds. Similarly, the ANA estimate is not plausible—the 

20 full-time and part-time employees ANA estimates would be required to overhaul its Web site 

are charged at a cost of $300,000 each.

The cost estimates in the PRA were built up from detailed data and assumptions about the 

number of pages on carrier Web sites, the number of hours required for various components of 

the revision process, and the number of carriers in each Web site size category. Based on the 

comments, it appears that this detailed approach may not be necessary to derive reasonable 

estimates of initial compliance costs.

For this analysis, we reviewed the estimates of compliance costs provided in several industry 

comments, as well as the observation in many of the comments that the largest portion of the 

costs are associated with revising the content and functionality associated with online booking 

engines and other online transaction processes. Based on this review, we adopted the following 

per-site costs for three categories of carriers:

 $500,000 per site for large carriers (including foreign carriers with more than 0.5 million 

U.S. enplanements in the 2011 T-100 data) offering scheduled passenger service.121

 $250,000 per site for all other carriers with online booking engines.122

 $50,000 per site for carriers that do not offer online booking (i.e., large U.S. charter 

carriers).123

Carriers will also 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. This regulatory 

evaluation incorporates estimated annual costs equal to 10 percent of the initial site revision costs 

for each year in the 10-year analysis period. 

Based on these preliminary assumptions and estimates, the costs to make primary Web sites fully

accessible are calculated as presented in Table 23.

 

121 This is more than double the per-site estimate for the largest carriers in the PRA, and slightly larger than the 

estimate provided by Spirit in its comments.

122 This is slightly larger than the per-site cost estimate used for the largest carriers in the PRA. It is also close to the 

low end of the range reported by A4A members, all of which are included in the largest group in this regulatory 

evaluation.

123 This per-site cost estimate was used for small U. S. carriers in the PRA. Note that this group does not include any 

contract carriers. These carriers would not have to ensure that their Web sites are accessible under the requirements 

published in the Rule because they do not market transportation to the general public.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 68 of 72 Pages

Econometrica, Inc. October 23, 2013

Table 23–Estimated Costs of Developing and Maintaining Accessible Carrier Web Sites

Calculation Component

Largest 

Carriers*

Other

Carriers 

With Online 

Booking

Other Carriers 

Without 

Online 

Booking**

All Carriers

Covered by 

Rule

Number of U.S. carrier sites 15 0 17 32

Number of foreign carrier sites 39 57 0 96

Total number of covered carrier sites 54 57 17 128

Average pre-launch cost per site $500,000 $250,000 $50,000 $328,906

U.S. carrier pre-launch costs $7,500,000 $0 $850,000 $8,350,000

Foreign carrier pre-launch costs $19,500,000 $14,250,000 $0 $33,750,000

Total pre-launch costs $27,000,000 $14,250,000 $850,000 $42,100,000

Average annual maintenance cost per 

site $50,000 $25,000 $5,000 $32,891

U.S. carrier annual maintenance costs $750,000 $0 $85,000 $835,000

Foreign carrier annual maintenance 

costs $1,950,000 $1,425,000 $0 $3,375,000

Total annual maintenance costs $2,700,000 $1,425,000 $85,000 $4,210,000

Total costs $84,200,000

Present value of costs in 2016 

(millions)*** $78.26

*Large U.S. and foreign carriers with more than 0.5 million U.S. scheduled service enplanements annually.

**Large U.S. charter carriers. Foreign charter carriers typically do not market to the general public in the United 

States.

***Assumes 50 percent of initial revision costs are incurred in 2014 and the remainder in 2015. Annual 

maintenance costs begin in 2016. Present value of costs calculated using a discount rate of 7 percent.

Under reasonable assumptions about the resources that will be required to comply with the Rule 

requirements, large carrier Web site accessibility costs are estimated at $84.2 million over the 

10-year analysis period. Approximately half of these estimated costs will be incurred in 2014 and 

2015, prior to the beginning of the analysis period. The present value of compliance costs in 

2016 is estimated at $78.3 million using a discount rate of 7 percent.

Costs Associated With Developing Online Service Request Forms

Carriers will also incur costs to develop and publish the online service accommodation request 

forms required by the Rule. For this analysis, preliminary estimates of the average hours of 

developer time per carrier that would be required to complete each identified component task 

were developed as shown in Table 24. The costs of these labor hours were valued at the mean 

wage rate for software developers and programmers in the air transportation sector (NAICS 

481000), adjusted to account for the additional cost of benefits and other direct labor costs, and 

aggregated for all U.S. and foreign carriers that would need to comply with this requirement.

Table 24–Costs Associated With Online Service Request Form

Cost Calculation Element Value

Hours per carrier
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 69 of 72 Pages

Econometrica, Inc. October 23, 2013

Initial form design/approval 16

Develop/code form 8

Integrate into Web site/test 4

Program database to collect data 4

Add service referral links 4

Revise service handling procedures 24

Total hours per carrier 60

Average hourly wage rate* $38.13

Employment cost multiplier** 1.45

Average fully loaded labor hourly rate $55.17

Request form cost per carrier $3,674

Number of covered U.S. carriers*** 15

Number of covered foreign carriers 96

Total number of covered carriers 111

Total online service request form costs $407,839

Present value of costs in 2016 (millions)**** $0.44

*BLS mean wage rate for software developers and programmers, NAICS 481000, 

May 2012.

**Accounts for benefits and other direct labor costs (44.7 percent of mean wage 

rate, per BLS May 2013).

***Large U.S. charter carriers typically do not market air transportation online.

****Costs are assumed to be incurred in 2015.

Costs incurred to develop and publish online service request forms, collect request data, and refer 

requests for appropriate service handling are estimated at $0.4 million. These costs are expected 

to be incurred in 2015, the year prior to the beginning of the 10-year analysis period.124

Equivalent Service Costs Incurred by Large Ticket Agents

Ticket agents that market air transportation to the general public in the United States would not 

be required to ensure that their Web sites are accessible. However, the Rule requires ticket agents 

with annual revenues that exceed the limit set forth in the applicable SBA small business size 

class standards ($19.0 million for both travel agents and tour operators in 2013) to disclose and 

offer Web-based discount fares to prospective passengers who contact the agent through other 

channels (e.g., by telephone or at the ticket counter) and indicate they are unable to use an 

 

124 The Department has used the labor hours estimated in this analysis for carriers to create and publish online 

service request forms to estimate the data collection, reporting, or recordkeeping burden under the applicable 

requirements of the Paperwork Reduction Act. Hours required to add service referral links and revise service 

handling procedures were not included in these burden estimates because these activities do not involve data 

collection, reporting, or recordkeeping. OMB and DOT requested Paperwork Reduction Act burden estimates for the 

Rule provision requiring notice to users that embedded or linked third-party content, forms, or applications may not 

be accessible. The incremental burden of developing the disclaimer notice and adding the appropriate links to the 

disclaimer is likely to be very modest—estimated at 4 to 8 labor hours per carrier on a standalone basis. However, 

the time required to develop the disclaimer notice and add code to ensure its display when required is included in the 

overall estimates of the costs associated with developing and maintaining accessible sites in this analysis.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 70 of 72 Pages

Econometrica, Inc. October 23, 2013

agent’s Web site due to a disability.

125 Large ticket agents will incur two types of costs to ensure 

that call center and ticket counter employee interactions with prospective travelers comply with 

this requirement:

 Call center and counter computer displays will require new programming to ensure that 

ticket agent employees are informed of applicable Web-based fares and promotions if a 

prospective passenger indicates that he or she is unable to use the Web site because of a 

disability.

 Sales/travel agents and reservation/ticket agents or clerks will need to be trained on the 

new requirements.

For this analysis, these costs were estimated as follows:

 Ticket agents were assumed to require an average of 80 hours of programming time to 

ensure that their call center and ticket counter computer displays inform employees of 

applicable Web-based fares and promotions when required.

 The fully loaded hourly cost of these hours was calculated as the product of the mean 

wage rate for travel agent software developers and programmers and the average private 

sector employment cost multiplier (1.447) to account for benefits and other labor costs.126

 About 70 percent of all travel agency workers are sales/travel agents and 

reservation/ticket agents or clerks. Weighted by the numbers of employees in these three 

occupational categories, the mean hourly wage rate for workers who will require training 

was $18.52 in May 2012.

 Each employee is assumed to require one-half hour of training on the Rule requirements.

These cost calculations are shown in Table 25:

 

125 Carriers have been required to disclose and offer Web-based discount fares to prospective passengers who

contact the agent through other channels and indicate they are unable to use an agent’s Web site due to a disability

under the ACAA rule that took effect in May 2009.

126 Industry-specific employment data were not available for the tour operator sector, so the wage rate for travel 

agent software developers and programmers was used for all ticket agent programming hours.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 71 of 72 Pages

Econometrica, Inc. October 23, 2013

Table 25–Ticket Agent Call Center Programming and Training Costs

Cost Component Value

Average programming hours per ticket agent 80

Average hourly wage rate* $41.57

Employment cost multiplier** 1.45

Average fully loaded labor hourly rate $60.15

Programming cost per ticket agent $4,812

Number of large travel agents 70

Number of large tour operators 26

Total number of covered ticket agents 96

Total ticket agent programming cost $461,966

Number of ticket agent employees in firms with 500 

or more employees 62,173

Percent employed as sales/travel agents or 

reservation/ticket agents/clerks 70%

Total number of employees requiring training 43,673

Average training time per employee (hours) 0.5

Average hourly wage rate*** $18.52

Employment cost multiplier** 1.45

Average fully loaded labor hourly rate $26.79

Total cost of employee training $585,071

Total ticket agent equivalent service costs $1,047,037

Present value of costs in 2016 (millions)**** $1.12

*BLS mean wage rate for software developers and programmers, NAICS 

561510, May 2012.

**Includes benefits and other direct labor costs (44.7 percent of mean 

wage rate, per BLS May 2013).

***Weighted average of BLS mean wage rates for travel agents, customer 

service representatives, and ticket/reservation clerks.

****Costs are assumed to be incurred in 2015.

Initial Rule compliance costs for large travel agents and tour operators are estimated at $1.0

million. Large ticket agents may also incur some continuing costs to ensure that call center and 

ticket counter employees have adequate information and training to comply with this Rule 

requirement. However, these costs could not be estimated for this analysis.

Unquantifiable Compliance Costs

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:

 Diversion of Web development resources. Carriers will need to devote resources to 

creating or updating Web pages to ensure regulatory compliance. These resources could 

otherwise be used to provide more or better functionality on their Web sites.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page 72 of 72 Pages

Econometrica, Inc. October 23, 2013

 Reduced Web site functionality or effectiveness. Ensuring all elements of a carrier Web 

site adhere to WCAG 2.0 standards may reduce the carrier’s options in creatively 

presenting Web content and may limit the adoption of innovative content and techniques.

 Enforcement costs. The Department will have to invest resources in acquiring and 

maintaining the ability to monitor and review covered carrier Web sites, conduct testing 

and verification periodically, and work with site publishers to understand and remedy 

identified violations of the accessibility standards.

6.7. Estimated Net Benefits and Discussion of Results

The present value of net benefits in 2015 from the Web site accessibility requirements is 

expected to be slightly negative (–$3.9 million) for the 10-year analysis period using a discount 

rate of 7 percent and slightly positive (+$7.8 million) for the same time period using a discount 

rate of 3 percent (Table 26). The estimated net benefits of the Rule requirements would be 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 26–Present Value in 2016 of Accessible Web Site Benefits and Costs, 2014−2025 (millions)

Estimated Present Value

7 Percent 

Discount Rate

3 Percent 

Discount Rate

Total monetized benefits $75.92 $90.28 

Web site accessibility costs $78.26 $81.00 

Online service request costs $0.44 $0.42 

Ticket agent equivalent service costs $1.12 $1.08 

Total monetized costs $79.82 $82.50 

Present value of monetized net benefits ($3.90) $7.78 

The benefit and cost estimates developed for the Web site accessibility requirements included in 

this evaluation indicate that the monetized benefits to travelers with disabilities and cost savings 

to carriers are approximately equal to the costs that will be incurred by carriers to develop and 

publish accessible Web sites. It should be noted that the benefit and cost estimates for these 

requirements are sensitive to a large number of component assumptions and estimates. Using 

certain reasonable alternative values for some of these component assumptions and estimates, the 

net benefits calculated may be positive even if a 7 percent discount rate is used, and may be 

negative even if a 3 percent discount rate is used. In either event, the monetized net benefits 

provided by this Rule are very small, indicating that the Department must weigh the 

unquantifiable benefits and costs to determine if the Rule would be in the public interest.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page A-1

Econometrica, Inc. October 23, 2013

Appendix A: ICT Accessibility Standards

The World Wide Web has continually evolved since the first Web pages were published 20 years 

ago. Early sites were primarily text-based, but images, multimedia, and applications were 

developed and incorporated into Web sites within a few years. Responding to the accessibility 

challenges posed by these developments, the W3C finalized the WCAG 1.0 recommendations in 

May 1999. Shortly thereafter, the Access Board published the current Section 508 standards, 

which include accessibility requirements for Web sites and other forms of ICT. The W3C 

published updated consensus standards—the WCAG 2.0 recommendations—in December 2008. 

This appendix provides a brief description of Web site basics, describes the evolution of Web 

accessibility standards, and summarizes the WCAG 2.0 Level A and Level AA requirements.

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 

partly 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 

and functional capabilities has provided benefits for air travelers, especially those who are deaf, 

have limited hearing, or have limited mobility. 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.127 The full versions of other carrier Web sites currently afford different 

degrees of accessibility for consumers with various types of disabilities.

 

127 Moreover, a 2011 review of the Delta text-only version of its primary Web site indicated that it lacked some of 

the functionality of the carrier’s primary Web site and did not meet all of the WCAG 2.0 conformance standards.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page A-2

Econometrica, Inc. October 23, 2013

Web Site Technology and Accessibility Standards

Making Web site content accessible to people 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 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 people with disabilities. However, 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 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, inaccessible content can be creatively reprogrammed or reformatted as 

accessible content without changing how it is displayed in a standard Web browser.

A.2. Evolution of Web Site Accessibility Standards

Current Section 508 Standards Evolved From WCAG 1.0

WCAG 1.0 has three priority levels (1 through 3) that correspond to the A, AA, and AAA levels 

in WCAG 2.0. A substantial portion of the current Section 508 standards for Web sites, and in 

many instances other forms of ICT, was adopted from the WCAG 1.0 recommendations. A 

Section 508 compliant Web site could require additional remediation in a few areas (including 

audio description, dynamic updating of text equivalents, and use of clear language) to meet the 

WCAG 1.0 Priority 1 recommendations. 

Five provisions in Part 22 of the Section 508 standards do not have close analogs to WCAG 1.0 

Priority 1 checkpoints, but they were incorporated in the development of WCAG 2.0. Some 

Section 508 requirements are similar but not identical to the analogous provisions in WCAG 1.0 

(scripting, applets/plug-ins, forms), and others (flicker, navigation bypass) are more specific than 

their WCAG 1.0 counterparts. Only one Section 508 requirement (the need to provide users with 
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page A-3

Econometrica, Inc. October 23, 2013

adequate time to respond when a timed response is required) was not addressed at all in the 

WCAG 1.0 Priority 1 recommendations.128

WCAG 2.0 Standards Evolved From Current Section 508 Requirements

New technologies, techniques, and accessibility issues have emerged since the current Section 

508 standards were published. WCAG 2.0 recommendations were developed to address specific 

gaps in the current Section 508 standards, including a requirement for a logical reading order, the 

ability to resize text, the ability to turn off background audio that might interfere with 

comprehension, and compatibility with screen reading software.

One important aspect of the WCAG 2.0 standards is that they are generally more testable than 

those in Section 508 or WCAG 1.0 because WCAG 2.0 establishes a set of success criteria for 

defining conformance to the WCAG 2.0 standards. WCAG 2.0 success criteria are written as 

testable statements that are not technology-specific. 

A.3. WCAG 2.0 Level A and Level AA Success Criteria

WCAG 2.0 Level A

WCAG 2.0 Level A success criteria provide a minimal level of accessibility without necessarily 

requiring any changes in the underlying design of the ICT. Table A-1 lists the Level A success 

criteria and describes what is required to ensure that each criterion is satisfied in the context of 

an HTML-coded Web site.

Table A-1–Level A Success Criteria in WCAG 2.0

Guideline Heading/Link Description (Application in HTML)

1.1.1 Non-Text Content All images, form image buttons, and image map hot spots 

have appropriate, equivalent alternative text. Embedded 

multimedia is identified via accessible text.

1.2.1 Prerecorded Audio-Only 

and Video-Only

A descriptive text transcript is provided for non-live, Webbased audio. A text or audio description is provided for 

non-live, Web-based video only.

1.2.2 Captions (Prerecorded) Synchronized captions are provided for non-live, Webbased video (YouTube videos, etc.).

1.2.3 Audio Description or 

Media Alternative 

(Prerecorded)

A descriptive text transcript OR audio description audio 

track is provided for non-live, Web-based video.

1.3.1 Info and Relationships Semantic markup is used to designate headings, lists, and 

emphasized or special text. Tables are used for tabular 

data. Where necessary, data cells are associated with their 

headers. Table captions and summaries are used where 

appropriate.

1.3.2 Meaningful Sequence The reading and navigation order (determined by code 

order) is logical and intuitive.

 

128 JimThatcher.com provides a provision-by-provision comparison and discussion of the Section 508 and WCAG 

1.0 Priority 1 provisions in “Side by Side WCAG vs. 508.”
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page A-4

Econometrica, Inc. October 23, 2013

Guideline Heading/Link Description (Application in HTML)

1.3.3 Sensory Characteristics Instructions do not rely upon shape, size, or visual location 

(e.g., “Click the square icon to continue” or “Instructions 

are in the right-hand column”).

1.4.1 Use of Color Color is not used as the sole method of conveying content 

or distinguishing visual elements.

1.4.2 Audio Control A mechanism is provided to stop, pause, mute, or adjust 

volume for audio that automatically plays on a page for 

more than 3 seconds.

2.1.1 Keyboard All page functionality is available using the keyboard, 

unless the functionality cannot be accomplished in any 

known way using a keyboard.

2.1.2 No Keyboard Trap Keyboard focus is never locked or trapped at one 

particular page element. The user can navigate to and 

from all navigable page elements using only a keyboard. 

Page-specified shortcut keys do not conflict with existing 

browser and screen reader shortcuts.

2.2.1 Timing Adjustable If a page or application has a time limit, the user is given 

options to turn off, adjust, or extend that time limit. This is 

not a requirement for real-time events (e.g., an auction), 

where the time limit is absolutely required, or if the time 

limit is longer than 20 hours.

2.2.2 Pause, Stop, Hide Automatically moving, blinking, or scrolling content that 

lasts longer than 5 seconds can be paused, stopped, or 

hidden by the user. Automatically updating content can be 

paused, stopped, or hidden by the user, or the user can 

manually control the timing of the updates.

2.3.1 Three Flashes or Below 

Threshold

No page content flashes more than three times per second 

unless that flashing content is sufficiently small and the 

flashes are of low contrast and do not contain too much 

red. (See general flash and red flash thresholds.)

2.4.1 Bypass Blocks A link is provided to skip navigation and other page 

elements that are repeated across Web pages.

2.4.2 Page Titled The Web page has a descriptive and informative page title.

2.4.3 Focus Order The navigation order of links, form elements, etc., is logical 

and intuitive.

2.4.4 Link Purpose (In 

Context)

The purpose of each link (or form image button or image 

map hotspot) can be determined from the link text alone, 

or from the link text and its context (e.g., surrounding 

paragraph, list item, table cell, or table headers).

3.1.1 Language of Page The language of the page is identified using the HTML lang 

attribute.

3.2.1 On Focus When a page element receives focus, it does not result in a 

substantial change to the page, the spawning of a pop-up 

window, an additional change of keyboard focus, or any 

other change that could confuse or disorient the user.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page A-5

Econometrica, Inc. October 23, 2013

Guideline Heading/Link Description (Application in HTML)

3.2.2 On Input When a user inputs information or interacts with a control, 

it does not result in a substantial change to the page, the 

spawning of a pop-up window, an additional change of 

keyboard focus, or any other change that could confuse or 

disorient the user, unless the user is informed of the 

change ahead of time.

3.3.1 Error Identification Required form elements or form elements that require a 

specific format, value, or length provide this information 

within the element's label or within the element's title 

attribute. If utilized, form validation errors are presented 

in an efficient, intuitive, and accessible manner.

3.3.2 Labels or Instructions Sufficient labels, cues, and instructions for required 

interactive elements are provided via instructions, 

examples, properly positioned form labels, and/or 

fieldsets/legends.

4.1.1 Parsing Significant HTML/XHTML validation/parsing errors are

avoided. Check at http://validator.w3.org/

4.1.2 Name, Role, Value Markup is used in a way that facilitates accessibility. This 

includes following the HTML/XHTML specifications and 

using forms, form labels, frame titles, etc., appropriately.

Source: Adapted from WebAIM.org WCAG 2.0 checklist for HTML documents.

WCAG 2.0 Level AA

Implementing accessibility at Level AA may require changes in design or programming that will 

afford more complete accessibility to users with various types of disabilities. Table A-2 lists the 

Level AA success criteria and describes what is required to ensure that each criterion is satisfied 

in the context of an HTML-coded Web site.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page A-6

Econometrica, Inc. October 23, 2013

Table A-2–Level AA Success Criteria in WCAG 2.0

Guideline Heading/Link Description

1.2.4 Captions (Live) Synchronized captions are provided for all live multimedia that contain 

audio (audio-only broadcasts, Web casts, video conferences, Flash 

animations, etc.).

1.2.5 Audio Description 

(Prerecorded)

Audio descriptions are provided for all video content. NOTE: These are 

only required if the video conveys content visually that is not available in 

the default audio track.

1.4.3 Contrast (Minimum) Text and images of text have a contrast ratio of at least 4.5:1. Large text 

(over 18 point or 14 point bold) has a contrast ratio of at least 3:1.

1.4.4 Resize Text The page is readable and functional when the text size is doubled.

1.4.5 Images of Text If the same visual presentation can be made using text alone, an image is 

not used to present that text.

2.4.5 Multiple Ways Multiple ways are available to find other Web pages on the site—at least 

two of a list of related pages, table of contents, site map, site search, or list 

of all available Web pages.

2.4.6 Headings and Labels Page headings and labels for form and interactive controls are informative. 

Avoid duplicating headings (e.g., "More Details") or label text (e.g., "First 

Name"), unless the structure provides adequate differentiation between 

them.

2.4.7 Focus Visible It is visually apparent which page element has the current keyboard focus 

(i.e., as you tab through the page, you can see where you are).

3.1.2 Language of Parts The language of page content that is in a different language is identified.

3.2.3 Consistent 

Navigation

Navigation links that are repeated on Web pages do not change order 

when navigating through the site.

3.2.4 Consistent 

Identification

Elements that have the same functionality across multiple Web pages are 

consistently identified. For example, a search box at the top of the site 

should always be labeled the same way.

3.3.3 Error Suggestion If an input error is detected (via client-side or server-side validation), 

provide suggestions for fixing the input in a timely and accessible manner.

3.3.4 Error Prevention 

(Legal, Financial, Data)

If the user can change or delete legal, financial, or test data, the 

changes/deletions can be reversed, verified, or confirmed.

Source: Adapted from WebAIM.org WCAG 2.0 checklist for HTML documents.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page B-1

Econometrica, Inc. October 23, 2013

Appendix B: Carrier Web Site Characteristics and Accessibility

In April and May 2011, Econometrica, Inc., 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 present and discuss the results from this review.

B.1. 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—in terms of both the number of pages and the average page size (i.e., 

amount of content displayed).129 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:130

 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 27 U.S. carriers that market scheduled passenger service exclusively on 

aircraft with fewer 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 

need to be included.

 The number of downloadable documents in PDF.

 The number of links to external URLs or other elements.

The results of these tabulations are presented in Table B-1.

 

129 See, for example, WebSiteOptimization.com, “Average Web Page Size Quintuples Since 2003.”

130 Xenu’s Link Sleuth 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 Sleuth

was designed to find broken links in a Web site, but the process also produces many useful statistics.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page B-2

Econometrica, Inc. October 23, 2013

Table B-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 number of pages for reporting carrier Web sites is three times larger than 

that of other large U.S. carriers.

 The largest foreign carrier sites are bigger than the sites of most U.S. carriers.

 Most sites have links to relatively few downloadable PDFs.

 Large U.S. and foreign carrier sites typically have several hundred links to URLs and 

content hosted on other sites.

B.2. Carrier Web Site Accessibility

Another determinant of the costs that will be incurred in complying with the Rule requirements 

is the extent and diversity of accessibility issues that will need to be addressed. To characterize 

the potential scope of the revisions that will 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 (Table B-2).

131 The following tabulations were compiled from the site-specific reports 

generated by Qompliance:

 The total number of issues identified that represent definite or potential violations of

WCAG 2.0 Level A and Level AA standards.

 The number of different WCAG 2.0 guidelines violated.

 

131 Qompliance is a Firefox Extension that gives Firefox users direct access to Deque’s Worldspace, a Web-based 

enterprise tool that automates testing for accessibility (Section 508 and WCAG), privacy, quality, and security.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page B-3

Econometrica, Inc. October 23, 2013

 The number of issues identified that represent violations only of Level AA-specific 

standards.

Table B-2–Accessibility Testing of Carrier Web Site Home Pages

Carrier Category

Average Number of Violations

(WCAG 2.0 A/AA Levels)

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 indicate 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 will need to be addressed, but the required revisions will still 

involve a substantial number of different WCAG 2.0 guidelines.

B.3. Screen Reader Parsing of Carrier Web Sites

Finally, we used the aDesigner application to estimate the amount of time that it would take for a 

typical screen reader to read each carrier home page included in this review (Table B-3).

132

 

132 Home pages of carrier Web sites are typically among the most complicated to render in fully accessible form, 

since they include the initial user interface for online booking engines and links to the remaining pages on the site. 

The aDesigner is a tool that Web authors can use to ensure that the Web pages they create are accessible to 

individuals who are blind or visually impaired.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page B-4

Econometrica, Inc. October 23, 2013

Table B-3–Carrier Web Site Screen Reader Times

Carrier Category

Screen Reading Time 

(seconds)

for Home Page

Domestic

Reporting carriers 199

Other large carriers (>60-seat aircraft) 231

Small carriers (30−60-seat aircraft) 116

Very small carriers (only <30-seat aircraft) 185

Foreign Carriers with >1 million U.S. passengers/year 225

Carriers <1 million U.S. passengers/year 144

Source: Econometrica, Inc., site testing using Xenu’s Link Sleuth and aDesigner, April−May 2011.

These results demonstrate that a significant amount of time is required for a screen reader to 

parse current carrier home pages, indicating that improvements in the accessibility of these pages 

would reduce the amount of time and decrease the amount of frustration experienced by site 

visitors using these assistive technologies.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page C-1

Econometrica, Inc. October 23, 2013

Appendix C: Kiosk Accessibility Standards

As noted in the evaluation, the technical standards for kiosk accessibility have been developed 

from the existing requirements for ATMs and fare machines under Section 707 of the 2004 ADA 

Accessibility Guidelines and for self-contained, closed products under part 1194.25 of the 

Section 508 standards. Table C-1 provides a list of the specific technical standards in the Rule 

and indicates their analogues or antecedents in the Section 707 or Section 508 standards.

Table C-1–Kiosk Technical Standards

382.57(c) 

/ 27.71(k) 

Reference Heading

Section

508 or 707 

Reference Requirement Stated in Reference

1

Selfcontained 1194.25(a)

Self-contained products shall be usable by people with 

disabilities without requiring an end-user to attach assistive 

technology to the product. Personal headsets for private 

listening are not assistive technology.

2

Clear floor 

or ground 

space

707.2 A clear floor or ground space complying with 305 shall be 

provided.

3(i) Operable 

parts

707.3

Operable parts shall comply with 309. Unless a clear or 

correct key is provided, each operable part shall be able to 

be differentiated by sound or touch, without activation.

3(ii) Timing 1194.25(b) When a timed response is required, the user shall be alerted 

and given sufficient time to indicate more time is required.

3(Iii) Status 

indicators

1194.23(k)

(4)

The status of all locking or toggle controls or keys shall be 

visually discernible, and discernible either through touch or 

sound.

3(iv) Color 1194.25(g)

Color coding shall not be used as the only means of 

conveying information, indicating an action, prompting a 

response, or distinguishing a visual element.

4 Privacy 707.4

Automatic teller machines shall provide the opportunity for 

the same degree of privacy of input and output available to 

all individuals.

4

Privacy 

(screen 

blanking)

707.4-A

Advisory: Speech output users can benefit from an option to 

render the visible screen blank, thereby affording them 

greater personal security and privacy.

5(i) Speech 

output

707.5

Machines shall be speech enabled. Operating instructions 

and orientation, visible transaction prompts, user input 

verification, error messages, and all displayed information 

for full use shall be accessible to and independently usable 

by individuals with vision impairments. Speech shall be 

delivered through a mechanism that is readily available to 

all users, including, but not limited to, an industry standard 

connector or a telephone handset. Speech shall be recorded 

or digitized human, or synthesized.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page C-2

Econometrica, Inc. October 23, 2013

382.57(c) 

/ 27.71(k) 

Reference Heading

Section

508 or 707 

Reference Requirement Stated in Reference

5(i)(C)/(ii)

Speech 

output (user 

control)

707.5.1 Speech shall be capable of being repeated or interrupted. 

Volume control shall be provided for the speech function.

5(i)(D)

Speech 

output 

(receipts)

707.5.2

Where receipts are provided, speech output devices shall 

provide audible balance inquiry information, error 

messages, and all other information on the printed receipt 

necessary to complete or verify the transaction.

5(ii)(A) Private 

listening 1194.25(e)

When products provide auditory output, the audio signal 

shall be provided at a standard signal level through an 

industry standard connector that will allow for private 

listening. The product must provide the ability to interrupt, 

pause, and restart the audio at any time.

5(ii)B Speaker 

volume 1194.25(f)

When products deliver voice output in a public area, 

incremental volume control shall 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. A function shall be provided to 

automatically reset the volume to the default level after 

every use.

5(iii) Captioning

1194.22(b) 

(updated 

to conform 

with WCAG 

2.0)

Multimedia content that contains speech or other audio 

information necessary for the comprehension of the content 

shall be open or closed captioned.

5(iv)

Tickets and 

boarding 

passes

707.1-A

Advisory: If farecards have one tactually distinctive corner 

they can be inserted with greater accuracy. Token collection 

devices that are designed to accommodate tokens which are 

perforated can allow a person to distinguish more readily 

between tokens and common coins. Place accessible gates 

and fare vending machines in close proximity to other 

accessible elements when feasible so the facility is easier to 

use.

6(i) Input 

controls 707.6.1

At least one tactilely discernible input control shall be 

provided for each function. Where provided, key surfaces 

not on active areas of display screens shall be raised above 

surrounding surfaces. Where membrane keys are the only 

method of input, each shall be tactilely discernible from 

surrounding surfaces and adjacent keys.

6(ii) Alphabetic 

keys

Industry 

standard

Alphabetic keys shall be arranged in a QWERTY keyboard 

layout. The “F” and “J” keys shall be tactilely distinct from 

the other keys.
Economic Analysis of Final Rule on Accessible Kiosks and Web Sites 1030-000/DTOS59-09-F-10094

Page C-3

Econometrica, Inc. October 23, 2013

382.57(c) 

/ 27.71(k) 

Reference Heading

Section

508 or 707 

Reference Requirement Stated in Reference

6(iii) Numeric 

keys 707.6.2

Numeric keys shall be arranged in a 12-key ascending or 

descending telephone keypad layout. The number five key 

shall be tactilely distinct from the other keys.

6(iv)(A)

Function 

keys 

(contrast)

707.6.3.1

Function keys shall contrast visually from background 

surfaces. Characters and symbols on key surfaces shall 

contrast visually from key surfaces. Visual contrast shall be 

either light-on-dark or dark-on-light.

6(iv)(B)

Function 

keys (tactile 

symbols)

707.6.3.2 Function key surfaces shall have specified tactile symbols.

7(i)

Display 

screen 

(visibility)

707.7.1

The display screen shall be visible from a point located 40 

inches (1015 mm) above the center of the clear floor space 

in front of the machine.

7(ii)

Display 

screen 

(characters)

707.7.2

Characters displayed on the screen shall be in a sans serif 

font. Characters shall be 3/16 inch (4.8 mm) high minimum 

based on the uppercase letter “I.” Characters shall contrast 

with their background with either light characters on a dark 

background or dark characters on a light background.

8

Braille 

instructions 707.8 Braille instructions for initiating the speech mode shall be provided. 

9 Biometrics 1194.25(d) When biometric forms of user identification or control are 

used, an alternative form of identification or activation, 

which does not require the user to possess particular 

biological characteristics, shall also be provided.