Monday, February 22, 2021

#9 Comments in Response to NHTSA ANPRM - One Institute, One Engineer

A little bragging - The Washington Post published my letter to the editor on Friday, Feb. 19, 2021. Just including it in case anyone is in need of a transportation rant about safer roads.


Acronyms for today


ADS - Automated Driver System (sometimes referred to as ADAS for Advanced Driver Assistance System), which requires a human driver to monitor and at points take over operation of the vehicle
ANPRM - Advanced Notice of Proposed Rule Making
AV - Autonomous Vehicle
GAO - Government Accountability Office
GAO is a legislative branch government agency that provides auditing, evaluation, and investigative services for the United States Congress. It is the supreme audit institution of the federal government of the United States.
NCAP - New Car Assessment Program
NCSL - National Conference of State Legislatures
NHTSA - National Highway Transportation Safety Administration (an agency within the US Department of Transportation)
NTSB - National Transportation Safety Board
SUV - Sport Utility Vehicle
USDOT - US Department of Transportation

Comments tally

Disclaimer/Explanation: Please note that anonymous comments and ones where the author's background is undeclared or not easily discovered are counted as "regular people" unless it becomes apparent that the commenter has professional expertise, which then shifts the comment into that category. Also note that the comments tally includes those comments summarized below in this blog post. All categorizations are my own and might seem random or wrong to someone else.  I am not an engineer, an automotive geek, or a software expert.

Comments are due by Feb. 1, 2021

Total comments to the Framework for Automated Driving System Safety (Framework) Advance Notice of Proposed Rule Making (ANPRM) issued by NHTSA that I have studied - 18 

Total comments as of Feb. 15, 2021 - 649 - The math comes to a difference of 631 unread comments. ๐Ÿคฏ๐Ÿ˜ฒ ๐Ÿ˜จ๐Ÿ˜ฑ

This is a tally of those comments I have read. Needless to say, I have a year or more of reading ahead or I can forget this. What keeps needling me, though, is the thought that no one but a bored, overworked, government functionary is reading these. I am respecting those who have submitted comments by giving them a thoughtful read and summarizing them.  

Anonymous - 2

Companies or Organizations - 8

Individuals with professional expertise - 6

Cybersecurity -2  

Regular people - 6 

Regular people who want increased safety - 5

Regular people who do not believe AVs will be safer than human drivers - 1

Regular people who do not want regulation to constrain innovation - 1

Spam comments - 1

Instructions for submitting comments can be found in the ANPRM.

Please note that these comments are not necessarily representative of the opinions of the US population; rather they come from corporate or non-profit entities or professionals with an interest in AVs, or people with the time, energy, and space in their lives attend public meetings - in this case to devote attention to Federal Register notices. The regulation-making process is, if not hidden, then placed out of the way in the bowels of federal agencies, and is oft forgotten when we vote or choose where we participate in our democracy.  

David DeVeau - Comments

I will get a guest blogger for this one. This guy is obviously an engineer who only writes in engineer speak. It does seem like he has something valuable to say.  I will ask around.

Humanetics - Comments

Humanetics is the leading crash dummies manufacturer, at least according to itself. I will be frank that the whole point of an AV, in terms of safety, is to avoid a crash, leaving the crash dummies to ride along and check their fake smartphones and drink their pretend lattes. That said, there's no reason to get rid of the crash dummies. 

Humanetics requests that we retain the particular FMVSS regulatory frameworks and certain equirements, such as gender-based crash dummy tests. 

Humanetics encourages the agency to implement a regulatory framework soon. It is not too soon and would not inhibit the advancement of technology. There are clearly certain basic driving scenarios which are anticipated to be very common, and all manufacturers would recognize these as critical and it is not too soon to implement a regulatory framework. As previously mentioned, these regulatory protocols could be supplemented with voluntary measures to control and manage a broader range of driving / test scenarios. Those voluntary scenarios / tests should remain fluid as the technology evolves.

Though Humanetics favors employment of the FMVSS, it does suggest an avenue for using alternative protocols. It envisions "a parallel path with regulatory testing with an option for a manufacturer to provide evidence supporting an alternate test protocol based on their technology is appropriate. Both the regulatory protocol and any alternate path should both utilize physical testing to ensure the performance of the  vehicle."

Now only 629 comments, give or take, to read. Why does that song 100 Bottles of Beer on the Wall, sung on every middle school trip, come to mind?

Write-In Campaign


Love this! We have a write-in campaign from members of the League of American Bicyclists. Identical comments, very brief, from avid bikers. Nice. I am going to collate all of these later in one post. Two of these are already included in the tally. Maybe there are more among the 600-plus comments left for me to read. Why do I complain about insomnia when there is a cure if I keep my laptop beside the bed?


Comment from Mollie D'Agostino on behalf of the UC Davis Policy Institute for Energy, Environment, and the Economy


This comment is submitted by Mollie, D'Agostino, whom I know personally, but not well. She submits this comment on behalf of the UC Davis Policy Institute for Energy, Environment, and the Economy (Policy Institute). DAgostino is the Policy Director of the 3 Revolutions Future Mobility Program at the Institute of Transportation Studies at UC Davis. This is a well-thought out comment that turns the safety framework on its head by essentially asking what is safety and is it more than preventing crashes or reducing their harm.
The narrow scoping of this ANPRM may be counter to a more comprehensive AV framework that might holistically address safety in such a way that it also tackles other DOT priorities, including climate resilience, mobility for underserved individuals and communities, and accessibility for all, including people with physical or cognitive disabilities. A narrow AV or ADS framework may obscure or even impinge on the Department’s broader transportation, mobility and sustainability objectives. 
The Policy Institute points to the state of California as an example of AV leadership from a government that has chosen to prioritize safety, environmental sustainability, equity, and accessibility.  And to make it better, the California goals include data collection to ensure we can judge where the state and the industry are in terms of reaching the goals.

Specific requests in this comment include:

  • Clarify terminology - The Policy Institute asks NHTSA what safety means exactly and does it include security, shared-use vehicles, as noted examples. 
  • Consider the possible safety benefits of fleet-based, shared-use AV transportation service. The comment posits that reliable maintenance might increase reliable performance and safety. 
  • Establish a continuous monitoring system through data collection - The comment states that there are examples at the USDOT, specifically the DOT Secure Data Commons, and in the private sector.
  • Set required performance standards - "Binding (rather than voluntary) performance-based ADS safety standards within the FMVSS will likely result in more consistent and improved safety outcomes. Performance-based standards, rather than design-based standards, such as safety benchmarks, will be more flexible and allow the industry to evolve in a manner that preserves safety and consistency."
  • Research to ensure business models that increase safety - The comment states, "more research is needed to assess safety outcomes for these different business models and to understand the expanded role of AV manufacturers in ensuring reliable ongoing performance of the ADS and vehicles whether they are operated by individuals or fleets."
  • Research to identify or set standards for emergency communications, a "panic button."
  • Collaborate with the Federal Transit Administration (FTA) - The Policy Institute includes passenger interfaces in this request. "NHTSA should work with FTA to consider how public transit applications will impact safety, and whether AVs for transit use will meet requirements under the Americans With Disability Act [(ADA)]. ... Both safety and security performance standards could be considered for shared AVs to encourage consistency among commercial service operators, so passengers can become familiar with security practices."
  • Define safety and test for it to include people with disabilities, whom are, the comment points out, 17 percent of the population. Even now, testing performed reflects average sizes . The comment offers a list of examples of specific metrics that might ensure AV safety for people with disabilities. These include physical access, such as wheelchair ramps and securement, as well as communications access. For a petite woman and an advocate for accessible transportation for people with disabilities, this comment is very significant. In my opinion, this deserves a long quote from the comment: 

The AV Safety Framework should consider the safety considerations for passengers with disabilities, including those who may use wheelchairs for personal mobility, or whom currently require aids or drivers to assist them with many aspects of travel. Care must also be taken to consider the needs of riders with other disabilities who are not in wheelchairs. More information is needed to build a concrete and qualitative understanding of the needs of people with all types of disabilities, and DOT should convene NHTSA, FHWA, FTA, and other relevant agencies to consider how a proposed AV safety framework might improve mobility for disabled passengers. 
In this vein the comment requests that we consider everyone, not merely those affluent or able enough to own a vehicle and maintain it. The comment integrates into its requests for research that we examine ramifications for people of color, people with disabilities, and people who bike and walk (pedestrians, yes). 

Monday, February 15, 2021

#2 Comments on Draft Strategic Accessible Transportation Plan

Comment of Cure SMA looks to overcome barriers for wheelchair users

Because many people with SMA utilize a wheelchair or other device for mobility, it is imperative that all existing and future modes of transportation are accessible and operate to meet the needs of individuals with disabilities. Unfortunately, transportation barriers remain prevalent in transportation modes despite the mandate of and the progress since the Americans with Disabilities Act (ADA).

This is a quote from the three-page comment of Cure SMA. First, about SMA and why people with that medical condition and their families would be very interested in the Draft Strategic Plan on Accessible Transportation.

Spinal muscular atrophy (SMA) is a group of hereditary diseases that progressively destroys motor neurons—nerve cells in the brain stem and spinal cord that control essential skeletal muscle activity such as speaking, walking, breathing, and swallowing, leading to muscle weakness and atrophy.

Hand lettering drawing of Dr. Suess
 quotation: "Unless someone like you cares
a whole lot, nothing is going to get better,
it's not.

Cure SMA is requesting that USDOT identify a point person - a disability czar, perhaps - who would be responsible for tracking performance toward achieving the goals of the draft strategic accessibility plan. The comment expresses concern that the lofty goals of the document actually receive USDOT attention and serious effort. This group is concerned about a beautiful plan sitting on a shelf. Cure SMA's specific issues revolve around: (1) Air travel problems regarding wheelchair storage, (3) driver licensing for people with disabilities, and (3) the high cost of retrofitting vehicles to allow for accessible driving.

In regard to AVs, "Cure SMA strongly supports the DOT’s efforts to ensure automated vehicles and other new technologies are designed with the needs of people with disabilities in mind." Accessibility of emerging transportation technologies is included in Cure SMA's 2021 priorities.

Comment of a graduate student addresses transportation for people with dementia


Here we have a brief, but thoughtful comment from a graduate student in community planning. The comment of Jonathon Katz specifically discusses the difficulties of a lack of transportation for people with dementia and those who care for them. The comment requests that the draft strategic accessibility plan provide a goal to expanding transportation access for this group, and, among other language in the comment that shows an educated vantage point about this issue, calls for more door-to-door transportation service for this frail population, while acknowledging the efforts of both the US Department of Transportation (USDOT) and the Department of Health and Human Service's Administration for Community Living's programs.

Hand lettering drawing: African-American
Man - Essential 

This comment also points to specific pedestrian safety programs in New York City and Oregon that, if implemented across the country, would substantially help seniors feel safe to walk in their own communities. Mr. Katz asks for separated bike lanes as a means of increasing the safety and comfort of older pedestrians whose pedestrian networks include mixed bike/ped infrastructure. One other request is  "I think more attention to community planning curricula, through the American Planning Association and the Association of Collegiate Schools of Planning, would be highly beneficial as well. "More information about Mr. Katz is available from his graduate school at the University of Maryland. He writes knowledgeably about transportation, disability, and food.

Thursday, February 4, 2021

Mostly complaints - USDOT Draft Strategic Plan on Accessible Transportation

The Draft Strategic Plan on Accessible Transportation is a can't-miss comment opportunity for disability activists, advocacy groups, and their counterparts in the aging world and in transportation. This is an easy way to begin engaging with the new leaders at the US Department of Transportation (USDOT). Keep your federal representatives informed by sending them a copy of what you submit to the USDOT. Submit comments; the deadline is Feb. 16, 2021.

In my opinion, the 25-page draft strategic plan and the comments that will be submitted are a gift to the incoming team at the USDOT to hear from stakeholders, yes, but also from regular people who grapple every day with transportation barriers. 

I have already covered, in a previous post, all of the comments submitted thus far to the draft strategic plan and I will continue to monitor the response submissions

I again thank former Secretary of Transportation Elaine Chao for using every opportunity to raise the issue of accessibility for people with disabilities and older adults. While I may disagree with her faith in the market to achieve this goal and the extent to which government should assist, encourage, and mandate, I appreciate how Sec. Chao faithfully highlighted this issue. In statement of scope in the draft strategic plan, this document issued under Ms. Chao's name honestly acknowledges the current reality: "lack of ramps, poor customer service, or chronic under-maintenance of equipment such as elevators may affect the ability of people with mobility impairments to use certain stops and stations." That description focuses right in on the daily frustrations and barriers that people with disabilities confront - where there is transit service. 

Remember, however, that in many communities there is little to no public transportation available. No federal law requires any public transportation. 

Apologies in advance: This post is full of complaints. Maybe COVID winter is making me cranky.

Let's get to the root of the problem.

Show me the money

A knowledgable basketball fan will tell you to watch the belly button area of a player to consider where that player is heading on the court, and, for AV development, I am watching where the money is flowing.

I'll be honest that, in terms of putting money where one's mouth is, as a society, we are putting billions into AV systems and prototypes for private vehicles and delivery fleets - all with the intent of enriching corporations. That is fine, but there are only millions being invested in accessible AVs, not to mention AV transit vehicles, and equity when we enter the AV age. In my opinion, we are not yet on the road to improving our transportation system writ large; we are merely on a path to replacing what we have and perpetuating the barriers to travel that we already have.

In the US, we simply have not demonstrated the same commitment to accessibility and equity as we have to serving profit-generating customers. 

Encouragement, research, and experiments more than a plan

Keeping in mind the lopsided amounts of money being invested, here is what the draft strategic plan describes about what the USDOT is already doing and what it suggests and for improving  accessibility in transportation. 

It is critical that new vehicle types and operating models are designed with the diverse needs of people with disabilities in mind. The [USDOT] plans to complement industry efforts by conducting and funding research to enhance the accessibility of personal vehicle travel...

...          ...          ...

Research is also investigating how automated vehicles in rural areas can provide transportation options for people who are not able to drive.

...          ...          ...

The [USDOT] recognizes the importance of providing effective and accessible mechanisms for public participation so that travelers with disabilities can have a hand in shaping transportation systems that work for all.

...          ...          ...

[USDOT] seeks to advance implementation of multimodal innovation, network connectivity, and emerging mobility technologies to accommodate people with disabilities.

Note to self: Calm down. Look at another cat photo. Nothing so mesmerizing as one's own pet.


Nice goal, but where's the beef?

While the goals expressed are very American as apple pie, totally non-controversial, there is sometimes a lack of commitment to those goals and sometimes a lack of employing easy answers, instead choosing more convoluted and less comprehensive strategies. For example, 30 years after the passage of the Americans with Disabilities Act (ADA), is it really acceptable that we still have in our future this goal?

For fixed route services (including actual and virtual flag-stop service), all vehicles will be ADA accessible; demand-responsive service must ensure equivalent service to persons with disabilities, including wheelchair users, according to established criteria.

This kind of language makes me skeptical when it comes to the articulated goals in the draft strategic plan of removing accessibility obstacles to multimodal options, micromobility, rights of way, and transit. The goals are laudable, but without the funding available at the USDOT or at agencies across the country to achieve these goals, the words alone are insufficient.  

One important detail

Details are supplied in the draft strategic plan about specific projects and research that the USDOT is  funding. Again, to be repetitive, we're talking huge disparities between public and private dollars and where their basketball belly buttons - to use a weird metaphor - are pointing. 

One specific goal is to establish a common set of data specifications:

FTA will work to promote data specifications for demand response transit and interactions among software systems owned by different transit providers.

...          ...          ...

DOT will encourage other common data specifications, such as ... GTFS, that can help riders more easily access route, schedule, fare, and arrival time information.

Pay attention to the specific words, such as "promote" and "encourage," which do not exactly ring with leadership. This is an area where stakeholder organizations, coalitions of volunteer and non-profit-provided transportation, as well as transit agencies, should be pushing FTA and alerting their representatives in the House and Senate that data specifications are important to the coordination of transportation services. Click here to learn about the work that AARP has done in this field.

What I don't see

I am not seeing common sense, relatively inexpensive programs or simple suggestions that would make a big difference to achieving particular goals. For example, under the umbrella of the complete trip goal, the draft strategic plan declares that the USDOT will collaborate with the Access Board and the Department of Justice (which has authority to file ADA lawsuits), as well as with the disability community, to consider wayfinding technology standards that can be rapidly and easily incorporated into transit facilities and systems and pedestrian connections. 

A big yes to wayfinding technology, an area of exciting technological developments in the last few years. But, no new technology or collaborative advisory groups are needed to provide bus stop benches, shelters, and complete streets infrastructure, including painted crosswalks, stop signs, and traffic signals, to make walking safe. These would do a lot for accessible transit access. 

One more example from the draft strategic plan: NHTSA's evaluation of "a High Visibility Enforcement program aimed at modifying the behavior of motorists passing bicyclists in two localities with a large number of bicycle crashes." Why not safer road and vehicle designs? Design determines behavior. 

Let's not be so mesmerized by technology that we don't invest in proven strategies. I need another cat photo. Deep breath.

I am inappropriately mixing apples and oranges

True, true, I am willy nilly mixing together areas that are separated by law and regulation into distinct federal, state, and local responsibilities, but imagine yourself unable to safely cross the street to the bus stop because of inadequate snow removal, or unable to stand for 10 minutes if there is no bench, or needing to run across six lanes of 45-mph-traffic to reach the bus stop - oh and the bus comes once every 45 minutes or an hour. That is the reality for millions of Americans. That's the reality of putting cars first.

I would like to see an accessible transportation plan from the USDOT that speaks to the persistent challenges confronting people, the challenges that cause them to just stay home, to not be able to hold a job, and to have to buy a car in the first place. - Oh if they are able to drive. 

That money thing again


"FMCSA has 18 Field staff trained to conduct ADA investigations." That's for whole US intercity bus industry. At least the draft strategic plan is honest. There's at least 10 people working in a road maintenance crew for a year at one 1/4 mile stretch in DC. ๐Ÿคจ  

I guess it's true. Show me the budget and you'll discover the true priorities. USDOT agencies are full of competent staff devoted to safe transportation, but local, state and federal budgets demonstrate a commitment to motor vehicles, not to full access for people with disabilities, let alone seniors and low-income communities. I would bet we spend plenty of public money to build and maintain airports, which middle and upper-class people use, but how much money do we devote to intercity bus transportation and facilities, or to Amtrak, in comparison?

One question


As I finish this curmudgeonly post, I have to raise a point of incomprehension, my own. Maybe it's just that the car companies have a century under their belt of a way to make good money, but, please, why don't OEMs and techies have the imagination to realize that there's plenty of money in accessibility? We already have accessible vehicles, so they don't have to recreate the wheel to invent those vehicles. 

We still would have the problem of equity, true, but accessibility is a pot of gold waiting at the end of the rainbow for companies willing to take a risk to serve a big market.

Tuesday, February 2, 2021

#1 Comments on Draft Strategic Plan on Accessible Transportation

This post reviews the comments submitted thus far in response to the US Department of Transportation Draft Strategic Plan on Accessible Transportation. Only one comment, thus far, from Julie Withers, discusses anything about the accessibility of autonomous vehicles (AVs). All of the comments summarized below are brief, sometimes briefer than my mix of summary and remarks.

Reading these comments is a privilege. People write in with private thoughts, ones not captured in a polling booth or in polished statements of advocacy organizations, about how government policy matters very personally to them. Even, and, sometimes especially, the comments that are clearly from individuals unfamiliar with government agencies and how they operate are the most moving. Somehow these people have discovered a relevant agency notice and they are sharing with the seemingly anonymous bureaucratic-sphere their unvarnished thoughts.

Comment from John Brown

Comment does not address the strategic plan; it remarks on a particular transit service in Texas.

Mr. Temple says in his comment that he has been in a wheelchair for 27 years, after being injured in the first Gulf War. He has suggestions for how to better retrofit vehicles so that people with particular physical disabilities can use them. "Basically I’m asking to help. I understand the limitations people in wheelchairs have. I understand what is needed for the very wide rang of injuries. I have understanding of the different lifts and their limitations as well. I have been exposed to all the new and old techniques used in Accessibility. The wildest one was a friend of mine who had barely any use of his arms and drove by joystick. It’s amazing what the US can do when we put our minds to it."

Despite the name given, this is not a completely offensive comment and not violently threatening. What the comment does convey beyond anger is frustration with federal efforts to expand accessibility.
Repeat: I cannot call myself an outdoor cat when I
refuse to go out in the snow.
"'Quarterly webinars" as the "innovative" solution to fix the problem is a joke. We know the answers of how to build safe, accessible roadways for a wide range of users - use your powers to properly define and demand them from DOTs.
While USDOT employees sit at their desks or telework from kitchen tables, it is helpful for them to remember that accessibility is a real-life issue for many people, and that the lack of access is extremely unfair and frustrating, creating a huge barrier to living a normal life. But what the angry commenter does not realize is that the authority of the USDOT to affect change is limited to the powers that Congress has granted. So now I have spent more words than Florida person used.

When someone starts discussing the mechanics and implications of local matching fund requirements, this is someone who might know how the federal administrative sausage is made, but then the commenter proceeds to call for a requirement that states supply matching local funds for "sidewalks, cross walks, safe to school routes etc along State and Federal Roadways." Mr. Hager's state, Indiana, is remiss in this regard, he states. However, this comment does not discuss accessibility or the USDOT draft strategic plan.

Also, it would be up to the state, rather than the federal government, to decide whether the state will contribute those matching funds. My advice is to start talking to your state legislators and get others to do so as well.

This brief comment focuses on the lack of requirements or even discussion in the USDOT draft strategic plan regarding service animals. The comment requests additional regulation to ensure that regulation fully enables this type of accessibility aide to provide assistance to those who need it. The commenter is concerned with those who "fake" their animals as service animals. 

This comment presumes the continued dominance of the privately-owned vehicle well into the AV age, as well as their less well-known and more expensive counterparts for people with disabilities, the retrofitted vehicle. That said, this comment is about lack of choice, and within car culture, people with disabilities have severely limited choices, IF they are able to drive or have someone available to drive. 


Off topic: People with disabilities and older adults are the foundation, sometimes the only ridership, of many, many small transit systems that barely provide what one in a major city would consider transit - sometimes only demand-response and not even a fixed-route service. Those transit or non-profit services often require reservations at least a day in advance. To be a person with a disability in small city, small town, or rural America is to be a second-class citizen.

Back to comment: This comment makes design suggestions for accessible AVs that come out of the lived experience of a customer who happens to have a disability and is longing for an alternative in accessible vehicle design that existed 40 to 50 years ago, she maintains. The lingering sad sentiment of this comment stays with me because it shows how desperate it is to be someone whose preferences are ignored in the marketplace. "The car seat should extend closer to the door for easier transfer for a person who cannot stand. The height of the car seat should be approximately 21" from the ground up. Having to lift body weight either up or down can be difficult. Thank you for paying attention to these issues."

Thursday, January 28, 2021

Panda videos and lots of AV comment opportunities, reports, events

All those months when nothing came from the Federal Register about autonomous vehicles (AVs) are in the rear view mirror and a few weeks ago the outgoing US Department of Transportation (USDOT) leadership released a flurry of documents - and thereby opened comment periods - charting a course for a road to accessible AVs. 

My small brain has been having a hard time keeping this all straight, so I am making the virtual effort of straightening out the piles, the dates, and the entities involved. To keep sane and smiling, enjoy the three panda cub videos sprinkled among the AV info.

Best in-a-nutshell AV resource 

Before we get to all that good stuff that has popped up in the Federal Register, here is a big treat: Eric Dennis of the Center for Automotive Research has just updated his excellent table of AV state laws. Warning - Not all of the laws within each category are the same, so this is not a deep dive, but it is a fabulous snapshot and an excellent resource. Also note that sources of regulations for a given state might be a law or an executive order of a governor. Dennis also maintains maps of state laws. Follow him on Twitter @EricPaulDennis for notices of his updates.

A database of state AV legislation and laws is available from the National Conference of State Legislatures. Dennis also maintains his own resource.

You didn't have to - lots of AV comment opportunities

Really, Elaine (Chao), you did not have to feel the need to leave so many parting gifts and all with open comment periods. I am sure this work will be helpful to USDOT staff, and I mean that sincerely, but it is also a gift to all of us who care about expanding transportation access and equity because the Chao USDOT made clear where exactly we are and how much we can expect if we do not alter the current public-private transportation divide. Of course, the staff who will be tasked with reading, interpreting, classifying, and preparing a document in response to each document might not be so happy.

  • Framework for Automated Driving System Safety - The National Highway Transportation Safety Administration (NHTSA) seeks comments about various aspects of AV safety, testing, and standards development in terms of NHTSA's role. There are over 20 specific questions posed. The comment deadline has been extended to Apr. 1, 2021. This is an Advance Notice of Proposed Rule Making (ANPRM). I have several posts about comments submitted, though, as of today the number is well north of 613 and I am just at the beginning of reading all of those. ๐Ÿ˜Ÿ  Now well over 500 behind. ๐Ÿค” Maybe time to clone myself.
  • Request for Information: Inclusive Design Reference Hub - The Office of the Secretary (OST) at the USDOT issued this request for information (RFI), which seeks ideas for collating inclusive design research with the goal to "establish a library of resources for accessibility in automation, and work with outside experts to study voluntary best practices for ensuring accessibility in automated vehicles." An RFI is not a commitment; it's a much less formal counterpart to a request for proposals. The comment period ends Feb. 19, 2021. The original comment period, which ended on Jan. 20, 2021, was officially extended. Thus far, there are seven comments and these are summarized in previous posts.*
  • Draft Strategic Plan on Accessible Transportation - The USDOT is seeking comments on its draft plan, which aims toward "mak[ing] America's transportation system accessible to all travelers." That is a tall order and I am just beginning to read this document. (Nothing thus far about requirements or legislation that mandate production of accessible vehicles.) Comments are due on or before Feb. 16, 2021. Six comments submitted so far.
  • See safety and cybersecurity section below for one more open comment period.

* Please note that as of the publication date that the USDOT website is not making available an OST page.

Events

Inclusive Design of Autonomous Vehicles - Mar. 10 - Apr. 21, 2021, every two weeks. Hosted by the US Access Board.

A four-part series of public forums to discuss different aspects of accessibility and the transportation needs posed by particular groups of disabilities. Links to the forum are not posted yet.

African American Conference on Disabilities - Sessions throughout February 2021. Hosted by the  Arizona Center for Disability Law and the Arizona Center for African American Resources.

This is an event with speakers from across the US. There are no transportation panels; the conference focuses on housing, accommodations, education and the effects of the pandemic. 

Plea to AV report writers: Take a vacation

To make it worse, on top of trying to keep abreast of AV work at the USDOT, I am also trying to keep track of and read all of the excellent AV reports that have been issued recently. There's a list below. I have to admit a certain personal conundrum of figuring out what exactly I want to read and focus on these days. I am supposed to be starting a podcast and a book, but, instead, I am treading through virtual piles of AV reading just to remain up to date. ๐ŸŠ  (That's a swimmer emoji, in case it's not obvious. No frantic, treading water emojis were available.)

  • Inspiring Autonomy: How Auto Insurers Will Lead Through Changing Risks - This is an updated 2018 report from Travelers Insurance about AV developments, how the auto insurance industry should continue as AVs roll out, and the best strategy for quickly compensating crash victims. 
  • Autonomous Vehicles and the Future of Auto Insurance - This is a report from RAND Corporation, which has done excellent research and reports on AVs. It explores different AV ownership and insurance regulation possibilities, with recommendations to investigate international models and public-private collaboration.
  • Low-Speed Automated Vehicles (LSAVs) in Public Transportation - This report is from the Transit Cooperative Research Program (TCRP) (within the Transportation Research Board (TRB)). It provides an overview of slow-speed AV shuttles, where they have been used, and factors that contribute to success. This is a practical report, with checklists for procurement, evaluation, and monitoring, among others. There are also a few detailed case studies provided.
  • Automated Vehicle and Shared Mobility Forum (AVSM Forum) - This TRB website hosts a library of brief reports of research summaries and discussion workshops with invited speakers and forum members, an A-list of AV and shared-use mobility thinkers (with professionals from state, local, and federal agencies, the private and non-profit sectors, and academia). The issues covered are wide ranging, but often in the form of articulating research needs and concerns around data, equity, and accessibility, among others. 

Goodies for safety and cybersecurity experts

  • Cybersecurity Best Practices for the Safety of Modern Vehicles - This is NHTSA's draft update of its 2016 (Obama administration) cybersecurity document. Comments are due on or before Mar. 15, 2021.
  • Notice Regarding the Applicability of NHTSA FMVSS Test Procedures to Certifying Manufacturers - The comment period is closed. This document essentially reverses (using judicial terminology) the 2016 statement of the Obama-era USDOT that required AV compliance with the NHTSA-issued federal motor vehicle safety standards (FMVSS). This document basically declares that FMVSS are not themselves performance standards. I am not a safety engineer, so I will offer a quote here. "While the manufacturer of a motor vehicle must produce vehicles that comply with all applicable FMVSS and must exercise reasonable care in certifying compliance, the Safety Act does not require that a manufacturer ensure that NHTSA can validate the manufacturer's certification through the FMVSS test conditions and procedures when it certifies the vehicle." This document has nothing directly to do with accessibility. There were 12 comments submitted and it will be interesting to read these as major organizations and businesses are among those who responded to the notice.
  • Safe Enough: Approaches to Assessing Acceptable Safety for Automated Vehicles - This RAND report is a dive into different ways to measure safety. 
For more panda time, visit the Giant Panda Cam

Request to Congress: Please concentrate on other topics until I am up to date, maybe in four months, before you all circle back to AVs. Thank you. 

Since I am not on the top of anyone's list for that magical vaccine, I can stay home and read official documents and comments.

Tuesday, January 26, 2021

#2 Comments in Response to USDOT OST RFI

Acronyms for today

Americans with Disabilities Act - ADA

Office of the Secretary - OST, located at the USDOT (see acronym in this list)

Request for Information - RFI

US Department of Transportation - USDOT


Which comment opportunity are we talking about?

This comment opportunity should not be confused with the embarrassment of riches of other open comment periods concerning documents related to AVs and/or accessibility. I am covering those as well. I keep getting the image in my head of very busy, almost frenzied workdays at USDOT in the weeks preceding the change in presidential administrations. 

In the next few days I will post a current list of the AV-related requests for comments and recent AV resources. Right now, I need to look at the sweet, formerly-outdoor cat sleeping next to me. He is one cute officemate.

Information hub that addresses broad range of different disabilities.  

In this next set of comments submitted in response to the late release (in the tenure of Secretary of Transportation Elaine Chao) from the USDOT OST, of an RFI for an Inclusive Design Reference Hub, we continue to see comments that emphasize the diversity of disability challenges by type of disability and accessibility accommodation.

The comment period open for another 24 days, or until about Feb. 18, 2021. Please do your own counting because my calculation could be slightly off.

1. Comment of Jenny Anonymous: This commenter self identifies as an ADA coordinator and the comment speaks briefly, but wisely, about ensuring that accessibility for all types of disabilities, be they physical, sensory, or cognitive, are included under the accessibility umbrella. This person points out the lack of accessible infrastructure (such as curb cuts and sidewalks) that impede travel for many persons with disabilities. The comment also calls for more accessible shared-use vehicles, which is especially limited for those who are unable to transfer out of their wheelchairs into a seat.

[I]t makes sense that auto manufacturers would have to have a certain percentage of their line designed with ramps, which can be deployed when the vehicle arrives at the destination. That way, individuals with mobility disabilities wouldn't need to worry about whether there is an access ramp where they are going.

2. Comment of Brad Dicianno - This commenter is, if a Google search has landed on the correct person, a doctor of rehabilitative medicine at the University of Pittsburgh School of Medicine. He requests that the information hub be established and maintained with an inclusive notion of what the person with a disability deals with when traveling. He envisions an information hub with materials about the "entire trip experience to include planning, communication, vehicle design, system design, standards, and ideally data. The Hub should include peer-reviewed publications, industry reports, government reports, technical standards, conceptual models/designs, and forums for stakeholders." This comment also advocates for high standards in terms of hosting, managing, and disseminating the information, "a place for stakeholders to provide feedback.," "[s]patial and geographic mapping, and "using natural language processing" as a possible "component to analyze consumer feedback."

3. Comment of Anonymous (submitted Jan. 13, 2021) - This commenter is pleased that information will be collected about the many variables involved with providing accessible AV transportation and the comment argues in favor of frequent updating once the hub has been created. Like a few other comments, this one calls for a classification system to organize the information. The comment also suggests that further research be conducted related to different disabilities.

4. Comment of John Kazanchy - This commenter, if that Google machine is correct, is a consultant who provides services related to wheelchair accessible vehicles. The comment argues that individuals with real-world experience providing transportation to people with disabilities should be included somehow in the research and that not all research be university based. 

Some simple examples are as follows:
1. Is there anybody on the chosen teams that has had to go and rescue a stranded physically disabled person in the snow at 1 am when their equipment failed?
2. Is there anyone who has installed and modified vehicle for the disabled that is aware of the complexities that are involved.
3. Has anyone had to investigate the charred remains of a disabled consumer that died while their vehicle burned?
4. Has anyone had hands on interaction with training disabled users on the proper usage of adaptive equipment in vehicles and understands the challenges?

The comment proceeds to discuss briefly the complexities, dangers, and profit motives involved in retrofitting vehicles so that they become accessible.

I am up to date on these comments, for the moment, but far behind on others. 

Jan. 26 List of Comments in Response to NHTSA ANPRM I Have Yet to Read

This post is only a list of names of people who have submitted comments to the Advance Notice of Proposed Rule Making (ANPRM) from the National Highway Transportation Safety Administration (NHTSA) to the Framework for Automated Driving System Safety whose comments I have not covered yet. It is a long list and not the only autonomous vehicle (AV) comments I am covering. Rome wasn't built in a day and it will take a good while before I read and digest all of these. 

The end of the USDOT Secretary Elaine Chao's tenure was marked by the release of lots of AV-related documents and then there's other AV legal discussions ongoing as well. Lots of activity on the issue of AV accessibility that I want to delve into.

Please be aware that although mostly individual names are listed, some of these people might have submitted comments on behalf of a company or an organization. This list is through mid-day of Jan. 26, 2021. Only well over 100 comments to read and that doesn't count the rush of comments yet to be submitted in this last week of the comment period.

The comment period ends in six days. 

  1. Aerospace Engineer anonymous
  2. Humanetics
  3. David DeVeau
  4. Car ReFormat comment from Ralph Panhuyzen - listed as a document rather than a comment
  5. Gary Schifmiller
  6. Alan Kailer
  7. Anna Walters
  8. James Hooper
  9. Dave Simmons
  10. Richard Millsap
  11. Allison Burson
  12. Lance Jacobs
  13. Michael Kelley
  14. Champe Burnley (Two comments, both posted Jan. 21, 2021)
  15. Rob Eckmann
  16. Mark Dehanke
  17. Jay Ellis
  18. Robert Nelson
  19. Steve Betts
  20. Ira Josephs
  21. Sean Hunt
  22. Stephen Minster
  23. Gina Simpson
  24. Kristin Firth
  25. Erica Stanojevic
  26. Kira Gillette
  27. David Kaufmann
  28. Fred Story
  29. Michael Colucci
  30. A-D Riley
  31. Alexander Van Duyne
  32. Shawn Aldridge
  33. Larry Riley
  34. Jack Rinaldo
  35. Daniel Frey
  36. Heidi Perry
  37. Frank Blake
  38. Ian Frederick-Rothwell
  39. Lawrence Anson
  40. Steven Gliva
  41. Mary Karimi
  42. Anna Karimi
  43. James Dickson
  44. Wendy Foley
  45. Aaron Buckley
  46. Zeke Smith
  47. Wendy Byrne
  48. Vince Mendieta
  49. Sharon Piekarski
  50. Roger McVeigh
  51. Thomas Polk
  52. Carol Ireland
  53. David Gurney
  54. James Linderholm
  55. Sylvia Star-Lack
  56. Wallace West
  57. Lisa Hart
  58. Robert McBride
  59. Tobias Boyd
  60. Sara Schroedl
  61. Katherine Curtis
  62. Tracy McIntosh
  63. Thomas Sinacore
  64. Kristopher Griffen
  65. Sean Long
  66. Sarah Clark
  67. Jed Lane
  68. Lynette O
  69. Don Burrier
  70. Paul Tucci
  71. Michael Duclos 
  72. Tim Blagden
  73. Joshua Griset
  74. Charlotte Black
  75. Harold Mann
  76. Steven Goodridge
  77. Hector Chang
  78. Dusty Szarell
  79. Robert Havrilla
  80. Jacki Bick
  81. Steven Shladover
  82. Walt Brown
  83. David Phillips
  84. Eric Schonenberg
  85. RC Grimsley
  86. Nicholas Paladino
  87. David Cardarella
  88. Claudia Nix
  89. Diane Schultz
  90. George Hamilton (probably not the actor)
  91. Christopher Quint
  92. Kristina Keogh
  93. Thomas Spellman
  94. John Neller
  95. Catina Passmore
  96. Stephan Vance
  97. Tina Brenza
  98. James Castellan
  99. Doogie Roux
  100. Matt Braun
  101. Robert Burkhardt
  102. John Hall
  103. Richard Holbrook
  104. Deborah Rhodes
  105. Thomas Wald
  106. Steven Ruder
  107. Anonymous Anonymous (Yes, that's how it's listed and I don't know whether that is for emphasis)
  108. Mark Magree
  109. Ben Ferris
  110. T. Roman
  111. Ty Weatherby
  112. Nancy Cousins
  113. Chris Crecelius
  114. Ben Payment
  115. Ben Oberjohn
  116. Glen Worrell
  117. George Mason
  118. Tom Alexander
  119. Ron Hirsch
  120. Maria Rosales
  121. Jay Whipple
  122. Stefan Cameron
  123. Lizabeth Bourret