#1 Comments in Response to OST RFI

Today's acronyms

ANPRM = Advance Notice of Proposed Rule Making

NHTSA = National Highway Transportation Safety Administration

OST =  Office of the Secretary at the US Department of Transportation

RFI = Request for Information

USDOT =  US Department of Transportation

Update: Still at 14 comments submitted in response to the NHTSA ANPRM. No additional comments have been added since New Year's. I will keep checking and reviewing those. 

RFI Comment Tally

Comments - 3

• Positive response to RFI - 3
• Responses from regular people - 1
• Responses from professionals - 2
• Suggested substantive changes to the RFI - 1
• Suggested organizational elements of Inclusive Design Hub - 1

Comments are due on or before Jan. 20, 2021. Comments to this RFI can be submitted and found at Regulations.gov.  Just as a reminder, the RFI comes from the OST at USDOT.

Now to the RFI Comments

Inclusive Design Reference Hub RFI

Comment #1 was submitted anonymously and, possibly, with the assistance of some type of software program or special equipment because almost every word is capitalized and most are followed by periods. The gist of this one comment, which barely eeks out to be four lines of text, is that we need updated standards or regulations for accessibility and inclusion that will result in a better transportation system. To read something that likely was written from the heart is a privilege and demonstrates why nothing-about-us-without-us is indeed a wise course. Perhaps this is one occasion where grammar rule adherence would get in the way of the message. "To. Better. Services. A. Disability Community. So. People. With. Disabilities. Can be. Involved. In. This. Layout. For. A. Better. Transportation. System." 

Comment #2 was submitted by Steve Yaffe, whom I know through professional transportation circles and whom I respect. Mr. Yaffe has decades of experience providing paratransit, he has participated in related TRB work, and he is currently a consultant. He also has an educated and inclusive perspective when it comes to issues of transit, mobility as a service (MaaS), and shared-use transportation. 

Mr. Yaffe makes four suggestions to improve the RFI:

1. Explicitly discuss the curb cut effect, a term used to mean the benefit of accessibility features for people without disabilities. Think of the thousands of people pulling luggage up a curb cut or ramp where that feature was put in place for the purpose of helping someone in a wheelchair. There are lots of examples, but, Mr. Yaffe states - and I would agree - that infrastructure or other features available to provide accessibility for people with usually also benefit people without disabilities. He points out that the private sector should discover and reap the benefits of the profitability from providing accessibility.
2. Include a question about whether small, shared AVs should have pull-down infant or child seats. Mr. Yaffe specifically mentions very small AVs with only a couple of seats.
3. Include a question about securing one's wheelchair (if one prefers and is able to switch into a provided seat) or luggage if one is unable to do so on one's own.
4. Include an inquiry into "the minimum length and width of a wheelchair-accessible flat-floor passenger compartment that allows the rider to be secured facing-forward." 

I like how Mr. Yaffe goes to those devils in the details because accessibility is not magic; it depends upon whether and what standards are established and then enforced. He does not comment on the library aspect of the RFI.

Comment #3 was submitted by Greg Vanderheiden. He is an engineer, university professor (now at University of Maryland, College Park), and a specialist in assistive technologies for communications and software accessibility. Please note that I am guessing that this is indeed the Greg Vanderheiden who submitted this comment because biographical and professional details have not been submitted in the comment. I also apologize to the professor if I have mischaracterized anything.

Prof. Vanderheiden makes some valuable, practical suggestions for the planned Inclusive Design Reference Hub in terms of how it should be organized and he welcomes the prospect of an AV accessibility knowledge library. The basic theme of this comment is advice for ensuring a good classification system. He also suggests tagging, and, specifically, tagging by date.

Prof. Vanderheiden "suggest[s] that the groups consider organizing the results into:"

>Highlighted Items (documents, standards, videos); 

>Summary Items (things the review or summarize many other documents or sources); 

>Full collection of items (a searchable general collection of everything that might be useful)

Editorial note: I really have to take more photos of our outdoor-turned-halfway-indoor cat. During COVID, he is a welcome distraction. But a panda playing in the snow is a good substitute.