AIR TRAVEL ACCESS UPDATES

April 8, 2016 Comments Off on AIR TRAVEL ACCESS UPDATES

Captioning in Transportation – Air Travel and More

Copying this from updated CCAC webpage – http://ccacaptioning.org/captioning-transportation/ – to include new and older air travel advocacy information. It sure takes time – add your voices where you can. The new DOT Committee will include many “usual players” located in the D.C. area, and your comments will be invited too.

CONTINUING CCAC ADVOCACY FOR AIR TRAVEL ACCESS! LOOKING FORWARD TO GOOD PROGRESS IN 2016 after conferring with consultant to Department of Transportation. Since 2010 CCAC volunteer citizen advocates ask for quality captioning in air transportation and offer information about airlines that have captioning in-flight – see below also.
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April 6 2016 -The Department of Transportation has now posted its Federal Register Notice reporting its decision to establish a negotiated rulemaking committee to seek consensus recommendations on three sets of issues: definition of service animal, accessibility of in-flight entertainment, and accessibility of lavatories on certain single-aisle aircraft.

Docket No. DOT OST 2015-0246 and it looks like our requests for discussion of in-flight Announcements to become accessible with text is under consideration too. Full documents in CCAC Member Forum online.
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Join the CCAC Team to find solutions, access and inclusion! Collaborations with other groups welcome, as always. Email: CCACaptioning@gmail.com
12/23/15: CCAC met with Dr. Richard Parker who is coordinating this activity for the DOT: Nondiscrimination on the Basis of Disability in Air Travel; Consideration of Negotiated Rulemaking Process.
Read more about above on http://www.regulations.gov/#!documentDetail;D=DOT-OST-2015-0246-0001

12/22/15: CCAC submitted a Comment Letter to the DOT as follows:

“For the DOT concerning Air Carrier Access Act Implementation – Docket No. DOT OST 2015-0246

We were pleased to see the announcement https://cms.dot.gov/briefing-room/dot-explores-consensus-based-initiative-make-flying-easier-individuals-disabilities and also the notice of intent http://www.regulations.gov/#!documentDetail;D=DOT-OST-2015-0246-0001 pertaining to Air Travel Access.

For the membership of the CCAC (CCACaptioning.org) and many others, we submit these concerns:

IFE must become accessible with quality captioning that offers reasonable choices to all airline passengers since, as paying passengers, we and the airlines benefit from accessible in-flight entertainments. However, IFE seems a too-narrow focus for this Negotiated Rulemaking Process.

Importantly and in addition to IFE concerns, we strongly suggest two other areas that are vital for access and inclusion of people with hearing loss and deafness who use captioning for understanding speech – (1) airport announcements and also (2) in-flight announcements.

Safety in airports and in-flight also are surely major concerns for everyone. Announcements in the airport, always considered essential for air travel, need to become visible with quality speech-to-text (live captioning). Sudden emergencies of any sort, gate changes after arriving at gates (not to miss the flight), and any other airport announcements can use existing technologies to create access with live captioning, not only for deaf and hard of hearing people, but also for so many with different first languages or other conditions that use captioning for comprehension (e.g. autism, tinnitus, auditory perceptual differences).

Similarly, we argue that in-flight announcements are vital for safety and equal communication access in-flight. Information access of any and all announcements is required. Not only people who are deaf or have a hearing loss need this information, live and real-time; there are many others in-flight (hearing also) who do not understand these announcements, and safety and calm environments in-flight are just as important as always, for everyone.

We hope that the DOT agrees and finds ways to include these concerns along with IFE matters.
Respectfully,
Lauren E. Storck (PhD).
President, Collaborative for Communication Access via Captioning (CCACaptioning.org) – Volunteer Citizen Captioning Advocates, Official 501(c)3 Non-Profit Organization.

CCACAPTIONING@GMAIL.COM
twitter.com/CCACaptioning
http://www.facebook.com/ccac.captioning
http://www.youtube.com/user/CCACORG/videos”

12/14: READ NEW BLOGPOST PLEASE – IMPORTANT UPDATES https://ccacblog.wordpress.com/2015/12/14/air-travel-access-updates/
See the Flyer and Use it: http://ccacaptioning.org/wp-content/uploads/2012/09/AIRTRAVELACCESSFINAL2.pdf
Since 2010 CCAC advocates for Air Travel Access. See Letter below.
November 2015 we welcome advocacy called #deafintheair also. Check it out on Twitter.
For MORE about AIRTRAVELACCESS, with listing of Airlines, see below. Email the CCAC to talk – let’s push this forward.
Newest Spreadsheet from Rachel, CCAC team member too – coming soon here!
(test only, may not open here yet: https://drive.google.com/file/d/0B_vnTaZ_7cjsUzZCM1dYWnhLa25FdmdDOHFoYWdFTDJfOWdR/view?usp=sharing)
Meanwhile, see lots of airline information down the page.
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EARLIER CCAC EFFORT HERE FROM MARCH 23, 2010! CCAC ONE OF SIGNATURES ON THE FOLLOWING DOCUMENT CONTACT AAPR for more information. Many of same points made by Senator Harkin’s Bills in US Congress again 2012 and included in the CCAC FLYER also.
Letter: RE: CAPTIONING / SUBTITLES ON ALL IN-FLIGHT ENTERTAINMENT
Dear Secretary LaHood,

I am writing to you on behalf of the Association for Airline Passenger Rights (“AAPR”) and the undersigned organizations to request that the U.S. Department of Transportation (“DOT”) require commercial air carriers to provide accessibility on all in-flight entertainment for their deaf and hard-of-hearing passengers and for passengers with vision loss. While DOT requires that captioning be available on all safety and information related videos, it does not enforce the same accessibility standard for in-flight entertainment, such as movies and television shows. Furthermore, much of this video material already included captioning or subtitles and may also have included video description, used by people with vision loss. We contend that by not ensuring pass through of available captioning and video description, DOT has created two
separate, yet unequal standards, one for passengers with sensory disabilities and another for passengers without sensory Title III of the Americans with Disabilities Act (“ADA”) – including changes made by the ADA Amendments Act of 2008 (P.L. 110-325) – covers public accommodations, including businesses that are public accommodations, privately operated transportation, and commercial facilities. The ADA mandates public accommodations must comply with basic nondiscrimination requirements that prohibit exclusion, segregation, and unequal treatment. They also must comply with specific requirements related to, among other things, reasonable modifications to policies, practices, and procedures; effective communication with people with hearing, vision, or speech disabilities; and other access requirements.

Aside from the ADA, the 1986 Air Carrier Access Act (“ACAA”) – 49 U.S.C. § 41705 – requires certain accommodations for passengers who are deaf and hard-of-hearing. The ACAA states that where safety briefings are presented to passengers on video screens in the aircraft, the carrier shall ensure that the video presentation is accessible to persons with hearing impairments by using open captioning or an inset for a sign language interpreter as part of the video presentation, or by closed captioning.

Passengers with sensory disabilities, such as people who are deaf or hard-of-hearing and passengers who are blind, lose value on their tickets when they cannot enjoy the in-flight entertainment on board because of the failure to ensure pass through of any available captioning or video description. It is not right that they have to pay a full fare and not receive the same service as average passengers. Passengers with sensory disabilities travel a lot so they should be given the same consideration by the airlines as other customers. We question whether it is fair or ethical that they have to sit through long flights, forced to miss whatever is being displayed on the in-flight entertainment while other customers are able to enjoy the services to the fulle…

We know that the technology exists to make in-flight entertainment accessible for passengers who are deaf or hard-of-hearing and for passengers with vision disabilities. At least two equipment vendors of in-flight entertainment systems have demonstrated caption display capability in their products and services and deployment has occurred on at least one airline. As you may know, video description is the narration of key visual elements inserted by content providers into the natural pauses in dialogue to help low-vision viewers to better understand the story. Many movies and TV programs now
include this form of accessibility.

Last year, DOT issued new regulations governing ACAA’s accessibility standards. Under Subpart E of the regulations, which were effective on May 13, 2009, air carriers must ensure that all new videos, DVDs, and other audio-visual displays played on aircraft for safety purposes, and all such new audio-visual displays played on aircraft for informational purposes that were created under their control, are high-contrast captioned. The captioning must be in the predominant language or languages in which they communicate with passengers on the flight. It is our belief that DOT missed an important opportunity to require this same accessibility standard extend to in-flight entertainment, too.

At that time, DOT recognized the value of requiring captioning (or subtitles) because it promised to issue a Supplemental Notice of Proposed Rulemaking to get an update on the further development of technology for captioning in the air. As it stands now, DOT has left it to the discretion of the air carriers to implement captioning or subtitles on all non-emergency in-flight entertainment.

Additionally, it is our belief that DOT failed to consider the needs of passengers with vision loss when it did not also require pass through of any available video description.

We contend that in 2010, nearly twenty years after the signing of the landmark Americans with Disabilities Act, commercial airlines should make a good-faith effort to make these accommodations to their paying customers who are deaf or hard-of-hearing, or with vision disabilities, so that all aspects of flying are accessible to them. In the absence of the airlines voluntarily making their in-flight entertainment more accessible, DOT should uphold the spirit of the law and require all commercial airlines to improve customer service for all passengers.

We the undersigned organizations look forward to working with you to correct this inequity. Thank you.
Brandon M. Macsata
Executive Director, Association for Airline Passenger Rights (AAPR) , Washington, DC 20003, Visit us on the web: http://www.flyfriendlyskies.com

For additional information, go to http://ccacaptioning.org/captioning-transportation/
where there is a long list of airline media captioning reports also.

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