APEX’s DOT Filing Aims to Leverage Expertise to Address Disability in Air Travel

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Illustration by Marcelo Cáceres.

APEX Insight: Working with the DOT toward the shared goal of making in-flight entertainment more accessible for passengers with disabilities, APEX’s recent filing recommends that involving industry experts in a traditional rulemaking process will enable stakeholders to agree upon implementable standards.

On Thursday, January 21, APEX filed an official comment, “Nondiscrimination on the Basis of Disability in Air Travel: Consideration of Negotiated Rulemaking Process,” with the US Department of Transportation (DOT). Within the filing, APEX agrees to represent aerospace industry members – including airlines, hardware and content providers – in conducting rulemaking with the DOT on making in-flight entertainment (IFE) systems more accessible to passengers with disabilities.

The implementation of accessible IFE for passengers has been a major focus for the association and its members. “There are many great examples,” says Joe Leader, APEX CEO. “But one that comes to mind is Air Canada’s initiatives to broadly include closed captioning and spoken-narrative technology for hearing- and visually-impaired travelers. The initiative sets a paragon of stepping above and beyond.” In 2014, the airline became the first to provide a fully accessible IFE system with the unveiling of its Boeing 787 fleet, equipped with Panasonic’s eX3 system developed in collaboration with Global Eagle Entertainment. The system allows visually-impaired user navigate the graphical user interface in complete autonomy thanks to text-to-speech technology.

APEX’s Closed Caption Working Group (CCWG) co-chaired by Bryan Rusenko and APEX’s Technology Committee chair, Michael Childers, has been working closely with the DOT toward developing industry standards for hearing-impaired travelers. The CCWG has developed the APEX 0814 standard for closed caption, which utilizes Timed Text Markup Language to support worldwide languages and captioning formats. Since 2006, more than 50 percent of global airlines fly with IFE systems equipped with closed captioning capabilities.

“We are telling the DOT why we believe that the traditional Notice of Proposed Rulemaking process is likely to be more fruitful than the negotiation rulemaking process.” – Michael Childers, Chair, APEX’s Technology Committee.

APEX’s comment comes in response to the DOT’s proposal to employ negotiated rulemaking to determine regulations for the use of closed captions on video content aboard commercial aircraft flying in and out of the US. “In our response, we are telling the DOT why we believe that the traditional Notice of Proposed Rulemaking (NPRM) process is likely to be more fruitful than the negotiation rulemaking process,” explains Childers.

The filing strongly recommends that a NPRM would allow key stakeholders to engage earlier on in the negotiation process, with the aim of establishing feasible timelines and solutions. The association posits that the traditional NPRM rulemaking process would better account for the technical intricacies and economic impact of the DOT’s decisions, preventing members and airlines from facing penalty or being forced to retrofit aircraft flying in and out of the US – a proposition that would cost the industry millions of dollars.

“We want to advance this issue in a way that serves passengers without driving up costs.” – Joe Leader, APEX CEO.

“APEX represents our industry and cares about our passengers,” says Leader. “We want to advance this issue in a way that serves passengers without driving up costs.” Regardless of which process is chosen, APEX will continue to maintain its leadership role in setting technical standards and working with the DOT and industry members to make IFE more accessible for all air passengers.