Accessibility DOT/CTA Updates April 2016

New Air Carrier Access Act Regulations ACI-NA April 2016 New Air Carrier Access Act Regulations New rules were published November 12, 2013 as part of DOT’s continuing implementation of the Air Carrier Access Act.

ACI-NA April 2016 Kiosk Accessibility US and foreign air carriers that own, lease, or control automated airport kiosks at US airports with 10,000 or more annual enplanements are required to ensure that 25% of automated airport kiosks installed 3 or more years after the rule’s effective date (December 12, 2016) meet the required technical accessibility standards. By December 12, 2022 at least 25% of automated kiosks in each location at an airport must be accessible. Carriers and airports are jointly liable for shared use kiosks.

Key dates to note for US airport kiosks: ACI-NA April 2016 Key dates to note for US airport kiosks: - Automated airport kiosks installed on or after December 12, 2016 are impacted by the rule: Of those installed kiosks, 25% are required to meet the technical accessibility standards at each location. - Effective December 12, 2022 at least 25% of automated kiosks in each location at an airport must be accessible. Automated airport kiosk – provides carrier software applications that enable customers to independently access flight related services. Shared-use automated airport kiosk - a self-service transaction machine that is jointly owned, controlled or leased by an airport operator and carriers and/or an independent service provider and that provides carrier software applications which enable customers to independently access flight-related services.

Installed is the key take away ACI-NA April 2016 Between December 2016 and December 2022: Installed is the key take away Nothing changes until kiosks are installed.   The regulation applies only to the cluster of kiosks that are being installed. Example: Carrier/airport is adding a cluster of 100 kiosks to an already existing cluster of 100 kiosks; only 25% must be accessible.   When the existing cluster of 100 kiosks are replaced (installed) 25% must be accessible.   If the carrier wants to voluntarily get ahead of the game, knowing they will have a total of 200 kiosks in the future, the carrier could choose to install 50 accessible kiosks but they are required to install only 25 accessible kiosks at the time 100 additional kiosks are added.

ACI-NA April 2016 Highlights: Accessible automated kiosks in each location at an airport must provide all of the same functions as inaccessible kiosks in that location Must ensure that accessible automated airport kiosks are visually and tactilely identifiable and maintained in working condition The standard applies when kiosks are “installed” not just new kiosks 25% applied on a per location basis, installing 12 kiosks, 3 must be accessible Airports and carriers are jointly and severally liable for ensuring that shared-use automated airport kiosks meet accessibility requirements

ACI-NA April 2016 Industry Compliance Plan is under development to address all requirements, some solutions include: Visual/Tactile identification of kiosks Universal blue wheelchair accessibility symbol is placed on the accessible kiosks ‘first position’ kiosk is accessible, signage advising passengers with a disability have priority access Agents should monitor and manage usage of accessible kiosks Timing (of operable parts). Where a timed response is required, the user must be alerted visually and by touch or by sound and given an opportunity to indicate more time is required. Industry standard includes the ‘alert’ The platform must adjust the total session timeout to 30 minutes as soon as the application performs the notify (ACTIVE_ACCESSIBLE) request Plugging in/out the headset triggers/disconnects accessibility mode

ACI-NA April 2016 Cluster Gray area No formal government definition of a ‘cluster’ – case by case basis Discussions with DOT have clarified criteria that distinguishes clusters are: *proprietary kiosks *common use kiosks *functionality of kiosks *groupings of kiosks Example: Proprietary kiosks with self tagging functions would be one cluster Document your analysis of what constitutes a cluster and retain for DOT audits.

ACI-NA April 2016 Status indicators (for operable parts) must be discernable visually, by touch or by sound Navigation pad such as easy access could be installed Traditionally 4 types of status indicators have also been used Dedicated such as easy access Full data keyboard – if used must be ‘Qwerty’ with tactilely discernible ‘F’ and ‘J’ keys (standard on most keyboards today) ATM selection keys 12 or 16-digit number entry pad Traditionally 5 defined action keys are used Up/down Action Help Forward/back Enter

Clarifications pending: ACI-NA April 2016 Clarifications pending: List of everything considered in scope in the kiosk universe APC kiosks (CBP, DOT and A4A are working towards clarification whether they are included) Tickets and Boarding Passes Orientation must be tactilely discernible if orientation is important to further use of the ticket or boarding pass Industry solution is to audibly describe the document Small working group has developed sample language to audibly describe the boarding pass orientation Working with Open Doors to finalize the sample language Goal is to convince DOT that audible description is better than tactile If DOT does not agree, industry will have to file an ‘equivalent alternative’ application with DOT

Confirmation from DOT: ACI-NA April 2016 Confirmation from DOT: Characters displayed on the screen must be sans serif font, 3/16 inch high minimum and background contrast must be a minimum luminosity contrast ratio of 3:1, sans serif is not one font but a style Biometrics – if biometrics is the only means for user identification, 2 biometric options using different biological characteristics must be provided Size – the clear floor or ground space shall be at least 30 inches by 48 inches Use of headset as an industry standard In scope are kiosks with additional functions, including, but not limited to bag drop, flight recovery, bag recovery and customer service

Coordination with External Resources for Expertise ACI-NA April 2016 Coordination with External Resources for Expertise Open Doors Met with the Accessibility Kiosk Working Group in Chicago in May 5-6 Supported the solutions agreed upon by the industry Will assist in development of the audio instructions for orientation of a boarding pass CUSSMG Version 1.4, which addresses kiosk accessibility, was published March 31, 2015

Canadian Transportation Agency (CTA) Accessibility Rule Published December 17, 2014 “Therefore, transportation service providers subject to this Code can install automated self-service kiosks that meet the standards of either section 1.3 of this Code (and the accompanying implementation guide) or 14 CFR Part 382 (Nondiscrimination  on the Basis of Disability in Air Travel), § 382.57 (What accessibility requirements apply to automated airport kiosks?) and 49 CFR Part 27 (Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance), § 27.71 (Airport facilities), as it pertains to automated kiosks at U.S. airports.” Carriers and terminal operators should ensure that at least 25 percent of automated self-service kiosks located in each service area of an airport, rail or ferry terminal meet the standards in section 1.3 and the accompanying implementation guide by December 12, 2022 . Carriers and terminal operators should ensure that all automated self-service kiosks installed on or after December 12, 2016, meet the design and functional specifications set forth in section 1.3 of this Code and the accompanying implementation guide, until at least 25 percent of kiosks provided in each service area of an airport, rail or ferry terminal meet this specification.

Canadian Transportation Agency (CTA) Accessibility Rule Published December 17, 2014 Applies to: Air Terminal Operators: Operators of terminals within the National Airports System. Air Carriers: Canadian (As defined in the Canada Transportation Act, i.e. "Canadian" means a Canadian citizen or permanent resident within the meaning of the Immigration Act, a government in Canada or an agent of such a government or a corporation or other entity that is incorporated or formed under the laws of Canada or a province that is controlled in fact by Canadians and of which at least seventy-five per cent, or such lesser percentage as the Governor-in-Council may by regulation specify, of the voting interests are owned and controlled by Canadians.) air carriers that operate fixed-wing aircraft with 30 or more passenger seats used for providing passenger service.

Non-prescriptive so far Directive of the European Parliament and of the Council Published December 2, 2015 Applies to: Air, bus, rail and waterborne passenger transport services, websites used for provision of passenger transport services; mobile device-based services, smart ticketing and real time information; self-service terminals, ticketing machines and check-in machines used for provisions of passenger transport services Under review Non-prescriptive so far Mostly aligned with the US DOT and Canadian Transportation Authority Enforcement is not explicit in the majority of countries Not a phased approach to compliance as DOT and CTA

The link to the DOT rule is: Legislation Links Published December 17, 2014 The link to the DOT rule is: www.regulations.gov, docket DOT-OST-2011-0177. The link to the CTA rule is: https://www.otc-cta.gc.ca/eng/removing-communication-barriers The link to the EU Directive rule is: ec.europa.eu/social/BlobServlet?docId=14813&langId=en

Questions: Email pedwards@airlines.org Thank you!