This post features organizations that represent, protect, and promote the rights and lives of people with disabilities. The overall framing of the conversation is where the value of these comments to the Draft Strategic Plan on Accessible Transportation begin, but what I did not expect from these organizations was the variety among the comments sent. There was not a coalition-type decision for every group to send the identical or nearly identical comment. These comments give a feel for the meaning for people with disabilities of the obstacles that continue to obstruct their path in using our transportation network on an equal footing with all others.
What is missing in this record of comments are many organizations that work with and on behalf people with disabilities, those who represent seniors, and those who provide transit and transportation services for them.
The comment of the Consortium for Citizens with Disabilities (CCD) comes from the CCD Transportation Task Force. Please be aware that I have met most of the co-chairs of the task force, some multiple times, and I respect and support their work. One of the co-chairs has been very active on work related to accessibility of autonomous vehicles (AVs) and others have participated to a lesser degree.
The CCD comment puts disability in American life and life in the US with a disability into perspective. One fifth of Americans have a disability; many are either unable to drive or cannot afford a retrofitted vehicle. A significant percentage live on an income of $25,000 or less, problematic for anyone, but more so for people who need extra support. Therefore, CCD points out, affordability is as much as an issue as accessibility. In a nutshell, CCD desires that "[t[he rights of people with disabilities must be prioritized, infrastructure drastically improved and accessibility baked in to any innovation."
CCD is pleased with "DOT’s inclusion of spontaneous and independent
travel as a facet of the principles."
CCD seeks to:
- "[I]ncentivize the expansion of accessibility in all parts of the transportation system"
- Embed accessibility in innovation
- Promote geographic equity, including rural and tribal
- Add racial equity to the framework principles
- Change the language from removal of unnecessary transportation barriers to "reframing and setting as a goal removal of all barriers to people with disabilities"
- "Elevate concerns about affordability and digital inclusion when considering the deployment of new technologies that empower new networks, operational models, and vehicle types" (going beyond the embedding of accessibility into AVs)
- Incorporate safety for people with disabilities as passengers and pedestrians into the Federal Motor Vehicle Safety Standards (FMVSS)
- Fully staff "NHTSA research programs and its Office of Civil Rights ... with a budget for fully qualified expert full time employees for compliance reviews on a continuous basis, and research and regulation reform to ensure inclusivity now and in the future."
- Establish "[v]igorous complaint and remediation processes, and compliance with the ADA," including discrimination in driver licensing and commercial driver licensing,
- Ensure audits of sidewalk and curb ramps
- Fund "repair and expansion" of the sidewalk accessible network
- Redirect funding from police enforcement, which disproportionately affects people with disabilities, towards "infrastructure improvements and ADA compliance"
- "[E]ncourage education of micromobility providers on the dangers of scooters and bikes which block PROW [public right of way], and solutions, including provider in-app penalization options for micromobility abusers"
- Strategize to fully include people with disabilities into transportation surveys
- "Encouraging inclusivity and reminding state and local DOTs of ADA obligations"
- Conduct a "survey of all inaccessible Amtrak and legal rail stations, and a detailed plan with deadlines to ensure full accessibility in the future"
- Ensure accessible on-demand transportation that is part of programs to complement transit services
- Designing federal programs so that on-demand transportation does not supplant transit service*
- Accessible rail cars, including bathrooms, redundant announcement systems, and entry-level boarding.
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| Hand lettering of "spicy." |
* This point is one with which I disagree. I fully support all-accessible on-demand transportation, whether that be taxi, ridehailing, or microtransit service (leaving aside for the moment micromobility options), but there are often occasions where an on-demand option can better serve a route or an area than retaining or supplementing existing transit service, particularly infrequent and often unreliable service. I think that CCD's fear is that the replacement will not serve people with disabilities as well even while it might be an improvement for others.
The American Association of People with Disabilities (AAPD) is a member of CCD. AAPD's comment is pretty global in its suggestions, making broad suggestions on (1) stakeholder engagement when issuing regulations, guidance, and funding announcements; (2) the role of regulation, urging appropriate regulation instead of knee-jerk (my word) anti-regulation bias; (3) enlarging the scope of the "complete trip" definition to include digital access for booking rides; and (4) geographic equity, particularly for communities of color and low-income populations.
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AAPD saves its specificity for AVs. It asks that the USDOT expressly include organizations representing people with disabilities in the stakeholder engagement section of the proposed framework. AAPD also suggests that people with multiple disabilities be included in AV design: "Advance solutions that can further enable people with physical, sensory, and cognitive disabilities, [including those that live with multiple disabilities] to use automated vehicles." [Emphasis on AAPD's suggested additional language.]
United Spinal Association organization is a member of CCD. United Spinal applauds the attitude of universal design in the framework and "respectfully request[s] that the next iteration of the Draft Strategic Plan on Accessible Transportation consistently pursue a universal
audience approach at every opportunity." This organization calls the draft plan "embryonic," as though it expects significant changes before the draft plan reaches final form. Clearly, United Spinal is banking on the change in presidential administration because a bold request is made now, not when a final plan is issued, to appoint a specific person at the USDOT to focus on accessibility and universal design, and to meet with the CCD transportation leaders, USDOT modal administrators, and the Secretary of Transportation on a regular basis.
It is not that United Spinal is asking for anything different than what the draft plan envisions, it is that this organization wants a commitment to realizing the goals enunciated in the draft plan.
DOT must take a comprehensive approach to strengthen coordinating its accessibility efforts with the tremendous knowledge base and institutional resources of the U.S. Access Board. DOT must be ever cognizant though of the Access Board’s severely limited budget and that optimal partnerships will depend upon DOT’s significantly larger and therefore more flexible budgetary resources to be committed to coordinating initiatives.
...
United Spinal respectfully requests that DOT convene a series of workshops to further operationalize the complete trip concept in the next iteration of the Draft. While the Draft addresses multiple aspects of complete trips primarily through examples of existing work the DOT is conducting, a more comprehensive analysis of the concept is truly needed.
...
Future iterations of the Draft must include a timeline of realistic goals and achievable benchmarks to increase accessibility for all Americans.
What the USDOT offers in the draft plan, United Spinal says, is a start. In terms of AVs, United Spinal sees the possibilities and the very real risk that an accessible transportation network might not be realized.
United Spinal supports:
• a separate objective be established in the Draft to further AV safety, testing, research and design and above all, accessibility exclusively.
• An AV Federal Advisory Committee.
Until [then,] Spinal wants to reiterate its support for the recommendations made by the Consortium for CitizensTransportation Task Force regarding DOT’s AV 4.0, including formation of an AV Advisory Committee with an accessibility subcommittee, and any grants funding autonomous vehicle projects requiring that people with disabilities are part of the design and testing of new technologies in order to ensure the accessibility and usability of the technology from the start.
United Spinal lends its support to expansion of broadband access.
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In its comment, the Hearing Loss Association of America (HLAA) speaks about the unrealized guarantees of the ADA and need for redundancy in communication throughout the transportation system. HLAA is not a member of CCD. The technologies are already here and HLAA suggests which ones would help people with hearing loss. These would provide redundancy for announcements on buses, planes, and trains, and at stations, sometimes to note last-minute changes or emergencies.
Likewise, HLAA asks that AVs be accessible, which would include technology that provides "hearing loops, visual and text information
... whenever verbal information or audible prompts are used." Again, redundancy is featured in its recommendations.
- Assistive listening systems, including hearing loop systems in stations, rail cars, at information points and any other place that requires understanding speech, whether via broadcast announcements or person-to-person communication.
- Tablets, iPads, computers, and/or smart phones with speech to text software applications and with lapel microphones for person-to-person interactions.
- Captions for videos or on-line communication.
- Public information boards that simultaneously display audible announcements in text.
Similar to other comments from disability organizations, HLAA speaks about more and better integrated stakeholder participation.
The American Foundation for the Blind (AFB) appreciates the multimodal approach that the USDOT takes in the Draft Strategic Plan on Accessible Transportation. The AFB comment begins by pointing out the large size of the population it represents and its sheds a spotlight on the importance of access to transportation in terms of getting to vaccination sites. The organization is also a member of CCD.
AFB raises the issue, not discussed previously in the comments, of people who are deafblind. AFB suggests expanded use of tactile wayfinding for this population, as well as education (I think they mean travel training) for people who are blind or have low vision navigating at transportation hubs and in the pedestrian environment.
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| Hand lettering of "mobility smorgasbord." Day 28 of 100 days of hand lettering. |
AFB takes a holistic, multimodal approach and thanks the USDOT for considering all of the modes beyond automotive travel. It mentions wayfinding in some detail as this is an important aspect of trip navigation. In this vein, AFB asks for improvements in shared-use modes.
AFB strongly applauds a commitment to expanding and maintaining accessible public transit infrastructure. We encourage the department to consider ways to incentivize more convenient paratransit service, including by implementing modern scheduling systems, reducing how far ahead individuals must schedule trips, and reducing barriers to traveling across jurisdictional boundaries. We encourage improved collaboration between Federal aid recipients and secondary providers. New mobility, including ridesharing, offers ample opportunity for improving services for people who are blind and has proven successful in several pilots, but such collaborations must provide accessibility to all people with disabilities, including wheelchair users.
For long-distance travel, AFB refers to the CCD comment.
As this comment focuses on and goes into detail only about accessible air travel, I will not be writing about the details. If one is interested in the weaker accessibility requirements for airplanes than for public transit, this is a good comment to read.
New York Lawyers for the Public Interest (NYLPI) lauds the USDOT for developing the Draft Strategic Plan on Accessible Transportation and it offers practical suggestions that would add to accessible transportation in urban settings. This New York refers to the city and not the state, though the website never actually states that.
NYLPI wants to see vastly expanded accessible ridehailing (I take issue with the term "ridesharing," as used in the comment), specifically mentioning Uber and Lyft. "Ride-sharing companies collect record profits, and yet are woefully coming up short in promoting social equity through the provision of accessible vehicles." The former is not actually true; as it stands, Uber and Lyft lose money on every ride. This is the reason why each company invested early in AVs.
NYLPI asks that micromobility companies - bikeshare, scooter share, etc. - be required to develop and make available accessible options. And NYLPI's comment reads like a pedestrian rights manifesto.
[T]he importance of accessible sidewalks and streets must be emphasized in the Strategic Plan. In accordance with the goal of providing for the “complete trip” of people with disabilities, sidewalks must be fully accessible. Full accessibility includes proper curb cuts and Accessible Pedestrians Signals. Moreover, with the rise of outdoor dining, clear protocols and enforcement guidelines must be promulgated to ensure that sidewalks are not obstructed by private businesses. Lastly, protocols and guidelines should be provided for clearing debris and snow from sidewalks, as impassable sidewalks violate disability laws.
Regarding public transit, the accessibility of which is a huge issue for New York City's subways, NYPLI makes clear something that should be shouted from the rooftop of every discussion on this issue: "[F]ull accessibility of rail and bus stations entails more than working elevators." And let me just say that the word "working" here should not be assumed or considered redundant. ADA lawsuits in major cities have revolved around the issue of poor elevator maintenance and repair. Full accessibility also includes safety features that are both tactile and visually noticeable.
And I have to love my fellow New Yorkers for this, even though I am in exile, that NYPLI proudly touts the importance of the city's economy to the nation and its public transportation to the city and the region's commuters.
[Video is Liza Minelli singing New York, New York in the movie of the same name.
And this next video was why youtube was created. Here is Judy Garland and Liza Minnelli onstage together in London.
Sustain Charlotte (which only has a Facebook page) offers a brief comment to support robust, accessible, well-funded public transportation.
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