Alert: January 9, 2012 is the deadline to submit comments on the United States Department of Transportation’s pending airline web accessibility and kiosk regulations. In my earlier post about the positive and negative parts of the proposed regulations, I explained how comments could be filed on the “user-friendly” website called the Regulation Room. I recently discovered, however, that comments to the Regulation Room, while shared with the DOT, are not treated the same way by the DOT as comments submitted through the “official” Regulation.gov channel. And, because the official channel is not fully accessible, the federal government has an “optional submission form” that is more accessible. Optional? I thought federal government accessibility was mandatory?
Since the Regulation Room is an open public site, it is important to have strong advocacy voices in that forum, even though it is not the official site for comments. For these reasons, advocates may want to file comments in both places. (And in the future, let’s hope the federal government has one clear, accessible, and direct way for the public to comment on important rules that affect the civil rights of people with disabilities.)
Three Ways to Comment
Below are links to the three channels for submitting comments. As for what to say? Read the earlier post on LFLegal about the DOT web and kiosk regulations.
Official Accessible Comment Form
Recognizing that it’s official comment channel poses accessibility challenges for people with disabilities, The DOT has posted what it calls an Alternate Comment Submission Form for the proposed kiosk and web regulations. The form is available as a download from the Regulations.gov web site and, according to the DOT, may be completed, saved, and sent as an email attachment to email@example.com.
Official Comment Form with Access Problems
It is disappointing that in 2012, the United States government is using a commenting platform that it knows contains accessibility barriers. Let’s hope the new year brings one unified federal website where all citizens can comment on issues that affect their lives. Visit the official Site for Submitting Comments to the U.S. Department of Transportation
Joining the Public Discussion at the Regulation Room
Information and links about filing comments through the Regulation Room is provided in my earlier post about the web and kiosk regulations. The federal government describes the alternative filing venue as follows:
For this [Department of Transportation web and kiosk rulemaking, CeRI (Cornell e-Rulemaking Initiative) will submit to the rulemaking docket a Summary of the discussion that occurs on the Regulation Room site; participants will have the chance to review a draft and suggest changes before the Summary is submitted. Note that Regulation Room is not an official DOT website [emphasis added], and so participating in discussion on that site is not the same as commenting in the rulemaking docket. The Summary of discussion and any joint comments prepared collaboratively on the site will become comments in the docket when they are submitted to DOT by CeRI. At any time during the comment period, anyone using Regulation Room can also submit their individual views to the rulemaking docket through the federal rulemaking portal Regulations.gov, or by any of the other methods identified at the beginning of this document [See section entitled ‘Addresses’].U.S. Department of Transportation
The advocacy community spends significant time commenting on regulations that may or may not eventually be finalized. Asking advocates to comment in two places is burdensome. In the future, the government should work to find one accessible, inclusive, easy-to-use channel for citizen participation.