#3 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

Request for Qualifications - RFQ

US Department of Transportation - USDOT

Which comment opportunity are we talking about?

I have to admit that I forgot about this comment opportunity, but being a person who doesn't close the many, many open tabs in my browser, and monitoring the numbers of various comment opportunity responses, the ball has not been dropped. This is the third post about 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, These were slow in coming in, but we have a total of 10.

Today I cover three non-profit comments that could not be more different. These are the last comments.

Comments submitted = who is paying attention

What strikes me is not so much who has submitted comments as the many players - stakeholders - in this  sandbox who have wisdom and experience, but whom we do not see on the comments list. These include major national organizations that might merely offer a paragraph showing support and perhaps a  suggestion. What I wonder is whether these major organizations in the fields of disability, transportation,  universal design, aging, urban planning, rural development, and equity are good at and concentrate on their relationships in Congress and with USDOT staff, but do not consider the time spent on contributing comments to be time well spent. Or perhaps it is just that all it takes is a staff member to take on this task. I suspect that many busy people and organizations do their jobs and are too occupied or not paying attention beyond their four corners to consider the contribution of comments to the administrative record.

A tale of two types of commenters

Comment from SAE International

This comment is more like a response to an RFQ than an RFI. SAE writes a nice comment about how it is already in the business of:

Designing, operating, and maintaining engineering reference hubs for various technologies, capacities, modes, and subject areas is what SAE has been doing for decades. This is a core element of SAE’s product and service portfolio. SAE has the program management and operational experience to support the daily operations and lifecycle requirements for an inclusive design hub as envisioned by USDOT. In addition, SAE has an established technology transfer processes in place and continually develops new products to further serve the community. This is what we do; a vehicle manufacturer cannot build a saleable motorcycle, car, truck, or bus without using SAE standards, best practices, design tools, and other reference materials.

Who or what is SAE? Previously known as the Society of Automotive Engineers, like its peer AARP, this successful society ditched the name and retained the acronym because it expanded into aerospace. Henry Ford was one of the founders, according to Wkipedia. SAE has been active on engineering standards, but also, in the last few years, on issues surrounding shared-use transportation, accessibility, and, of course, with its famous levels of automation, for automated vehicles. (I used the term automated and not autonomous because SAE's involvement is broad and automation includes everything from cruise control and up.)

According to its comment, SAE, again still marching in front of the judges in order to win the crown, reminds the USDOT that it already does this type of work for the agency and it gives lots of examples.  "SAE proposes to set up a webinar or an in person meeting (whatever the criteria is at the selected time   regarding in person gatherings) to respond to many of the questions in the RFI by demonstrating  reference hubs, standards development processes, and examples of the continuous transfer of technology  performed by SAE for stakeholders." More details follow in this two-page comment, but you get the picture. This comment had nothing, nada, zippo, about the idea of establishing an Inclusive Design  Reference Hub and how that would or would not advance accessible design in transportation. 

Comment from Feonix - Mobility Rising

This comment represents the very opposite of the previous comment. Feonix Mobility Rising is a player in the small urban and rural on-demand transportation world. Feonix concentrates on stakeholder coordination for partnerships mixed with Uber-like ride-request technology, accomplished through publicly-funded projects and the leadership of Valerie Lefler, who is based in Nebraska. Valerie is a strong believer in the value of community in rural towns and she is a proponent of increased access for people with disabilities. Lefler's current and previous work has involved every type of project from volunteer-led partners to transit agencies and other entities that serve transportation-challenged populations in sparsely populated areas.

Feonix works to improve that sorry world for rural residents who do not drive, many of them elders who have lived their entire lives in a particular community. Social isolation and a lack of transportation or expensive transportation are all terrible choices; but non-profit transportation services, often operated by volunteers, or meagre transit systems help these residents with their very personal, friendly, and community sustaining service. Making the most of the sum of the local institutional partners available in a given area, Feonix brings technology rather than actual wheels on the ground, which are provided by local players.

The comment offers suggestions of existing research to include, such as that done or funded by "AARP, the Robert Wood Johnson Foundation, the American Center for Mobility, and the US DOT UTC Program/Council of University Transportation Centers" as well as focusing on several audiences, including non-profits, engineers, and graduate students, among others. This comment has a no-wrong-door feel as well, extending to its suggestion that the proposed Inclusive Design Reference Hub reflect the diversity of types of disability and the lived experience of people along that spectrum.

Feonix displays its own expertise by referencing a training it created for the Michigan Department of Transportation about disability awareness, but the comment is not at all about its own possible role. Rather the comment points to the importance of engaging and employing existing institutional players: 

It will also be critical that US DOT engage the National Council on Independent  Living,  National Center for Mobility Management, National Aging and Disability  Transportation Center, and the National Association of Area Agencies on Aging in designing and promoting the Inclusive Design Reference Hub. These organizations represent incredible  programs and supportive services that are provided to tens of millions of Americans with disabilities and older adults. Their insight and perspective are essential in the success and  utilization of the Hub.

[Editor's note: Links added. Also please note that the editor of this blog worked with the above-mentioned organizations and directly for the National Center for Mobility Management. I also know Valerie Lefler.]

Comment from Alliance for Automotive Innovation

Now, here at the end of the 10 comments submitted, we have another association, an automotive industry player. The Alliance for Automotive Innovation (Alliance) is relatively new, but it comes from a combination of an established organization, a powerful industry, and new startups in the fields of electric, connected, and autonomous vehicles.

Formed in 2020, the Alliance for Automotive Innovation (Auto Innovators) is a the singular, authoritative, and respected voice of the automotive industry. Focused on creating a safe and transformative path for sustainable industry growth, Auto Innovators represents the manufacturers producing nearly 99 percent of cars and light trucks sold in the United States. The newly established organization, a combination of the Association of Global Automakers and the Alliance of Automobile Manufacturers, is directly involved in regulatory and policy matters impacting the light-duty vehicle market across the country. Members include motor vehicle manufacturers, original equipment suppliers, as well as technology and value chain partners.

[Link added to the quoted text.]

The comment reads like one would expect right around the corner that the Alliance will declare it is in favor of apple pie; nothing controversial here. But let us remember that its members are responsible for manufacturing ever larger vehicles that are responsible for a large increase in pedestrian and biker deaths and injuries, that they advertise machines that keep many people sedentary, and that they have traditionally lobbied for a transportation system that is based on a combination of a single skill, the ability to drive, and money to purchase their vehicles. 

That rant out of the way, the Alliance states that it is fully in favor of accessibility. The Alliance points out that an important focus population should be older adults. After reviewing the large percentages of Americans who either have a disability or whom are considered to be seniors, the Alliance confirms that there is, therefore, a need for greater accessibility in transportation. 

To advance this important effort, we support the establishment of an Inclusive Design Hub that can serve as a library of resources for accessibility in AVs. Once created, this online database can provide a “onestop-shop” for the standards and best practices that currently exist regarding accessible vehicle design as it pertains to AVs. 

The Alliance suggests that - wait for some good Washington, DC speak - "An Inclusive Design Hub that is hosted and maintained by an entity or entities that appropriately reflect or represent the cross-stakeholder nature of this issue is more likely to survive into the future as a useful and productive accessibility resource." Cross-stakeholder: Now that's a word for a conversation when heading on the Green Line to the USDOT building. Love it.

Warning: One more rant

Now let's look at the past and current actions of the members of the Alliance. None of its members are building, proposing, or advocating for a significant increase in the numbers or percentages of accessible vehicles. None are promising an all-accessible product line. If these member companies are innovators, hello!, there is lots of opportunity. Instead the Alliance is advocating for better job training, expansion of electric charging infrastructure, and creating incentives for research and development. Thank you, all good, positive steps, but the actual layout of the car has not changed in a 100 years, without considering cupholders. It is time to design universally instead of for a market that excludes 20 percent of the population, some of whom are unable to enter or exit those vehicles.

This is where the comment is intriguing. The Alliance seems to be looking for guidance, standards, and, perhaps, should I say looking for an opportunity to be officially encouraged to provide more access. 

Perhaps what the Alliance is really saying, through the murky lens of non-committal language supportive of the good of transportation-and-tech challenged populations, is that it is time to actually require the industry as a whole to provide accessibility - whether through the Inclusive Design Reference Hub standards or elsewhere - but that each player left on its own will not move forward individually.