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Usability Professionals’ Association Issues Comment on Proposed Department of Transportation Rule on Non-Discrimination in Air Travel
Date: March 4, 2005
To: The Department of Transportation
From: Whitney Quesenbery, President, Usability Professionals’ Association (UPA), the UPA Board of Directors
Comment on: Notice of Proposed
Rulemaking: 14 CFR Part 382: Nondiscrimination on the Basis of Disability
in Air Travel; Proposed Rule
The Usability Professionals’ Association (UPA) is an international
organization of practitioners in the field of usability and accessibility.
Members work in industry, academic institutions and government on web
sites, software applications, and other products.
We write to support the provisions in Subpart C, Paragraph 382.43(b) of
this proposed rule, which require that web sites used by the public to
make reservations and obtain other information from air carriers be made
accessible to and usable by individuals with disabilities, following the
provisions of 26 CFR Part 1194 (known as “Section 508”). The
federal government already requires itself and all its contractors to
make web sites accessible to blind and low-vision users through “Section
508.” This rule extends these requirements to a group of web sites
important to large numbers of people who are currently disadvantaged by
inaccessible and unusable design. Many travel web sites offer their “best
prices” only on the web and create other incentives to use this
channel to check in for flights, reserve seat assignments, receive notifications
of flight delays, request special services, and communicate with the air
carrier in other ways.
This rule will benefit some 56 million Americans over the age of 18 with
a disability. It will also benefit another large (and growing) segment
of the population: the older adult. Many older adults find travel sites
difficult to use because of age-related vision impairments and motor limitations.
The type size is often too small and not adjustable; buttons aren't always
obviously clickable; links and buttons are often too small to notice let
alone click on. Some of these problems could cause people to make costly
mistakes. It is simply good business for companies to make web sites accessible
to a larger fraction of their customer base.
No doubt companies will resist changing their sites, citing a heavy economic
burden. While we can expect it will take some time to make changes, we
believe that given the rapid cycles of change in web sites and applications,
two years is an appropriate period of time to allow for upgrading existing
sites to meet these accessibility requirements.
We have one specific comment on the language of the proposed rule. The
current wording of Subpart C, Paragraph 382.43(b) says that it applies
to “individuals with vision impairments and other disabilities.”
This language could be made more accurate by changing the wording to “individuals
with vision impairments or other disabilities.”
The Department of Transportation also seeks comments on whether there
are any other standards - domestic or foreign - that would also be appropriate
for this context. We note that other countries, including the UK and Australia
have recently adopted rules requiring that public web sites be accessible
and usable for people with disabilities. Although there are inevitable
differences between these rules and “Section 508,” their provisions
are similar. This shows the wide-spread acceptance of the need for such
rules and will minimize the differences in requirements that global web
sites must meet.
One of the difficulties in enforcing accessibility regulations, including
“Section 508,” has been the lack of clear criteria for assessing
conformance to these standards. One solution is to make the results of
usability and accessibility testing available for review. ANSI NCITS 354-2001Common
Industry Format for Usability Test Reports is a standard for reporting
summative usability test results. While a report of a usability test cannot
ensure that the site is usable, it does provide a way for interested parties
to review these tests in a common format, with the same information reported
for each site.
We also believe that the best way to create a highly accessible and usable
site is through a user-centered (also called human-centered) design process.
This process is described in an international standard, ISO 13407:1999
Human-Centered Design Process for Interactive Systems (ISO 13407:1999).
In summary, we support this rule as it appropriately extends requirements
for accessibility and usability to travel sites operated by, or on behalf
of, air carriers. This is an important step in ensuring that everyone
can participate in the growing use of the World Wide Web for normal business.
Access to the online world is as important as access in the physical world.
We believe that in the future, this rule could be extended to include
other travel sites: railways, car rentals, hotels and other holiday bookings.
Thank you for the opportunity to comment on this proposed rule.
Whitney Quesenbery
UPA President
Contributors to this comment include: Dana Chisnell, Gail Lippincott,
Alice Preston, Janice (Ginny) Redish, Paul Sherman, and Josephine Scott.
The Usability Professionals' Association is an international, non-profit, professional association with more than 2000 members in the US and 35 other countries. Members are specialists in evaluating and designing products that are easy to learn and use. The organization provides its members with a wide variety of professional services. Through outreach the UPA:
- Shares information about the skills and approach of usability professionals in meeting needs for usable products.
- Acts as an advocate for usability in consumer, corporate and governmental software, products and web sites.
- Educates the general public about the usability.
For more information, contact:
The Usability Professionals'
Association
140 N. Bloomingdale Rd.
Bloomingdale, IL 60108-1017
email: office@upassoc.org
web: http://www.usabilityprofessionals.org