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. 

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