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. 🤨  

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.

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