Monday, March 29, 2021

#6 Comments on Draft Strategic Plan on Accessible Transportation

This is the last post about comments submitted in response to the Draft Strategic Plan on Accessible Transportation. The comments discussed below were all submitted by individuals speaking on their own behalf, though represented in that group is one well-connected professor and a strident activist among the group. There were a total of 28 comments, pretty meagre considering that approximately 15-20 percent of the US population has a disability.

For me, it's a privilege to read the comments. Picture the black-and-white fact of voting results and imagine every person explaining why they are showing up to vote. That added color, as it were, is what we get to read in these comments.

Comment from Louise Shawkat

This comment states that not all people are able to drive and everyone needs to access medical care, voting, and houses of worship.

This comment expresses full support for frequent and reliable public transportation
[S]o we wheelchair users can get to school, work, groceries, friends and of course doctor appointments. Paratransit is universally terrible and actively dehumanizing - you have to allow a 3 hour window for pickup and then the way back and on the drive, they may go out of the way to drop off someone else.

This is so sad because Ms. Henry compares what anyone would consider mediocre bus service in DC or New York to be heaven because she would be able to reduce her harrowing three-hour wait and trek to an hour and a half.

Comment from Walter Park

This comment implores the USDOT that now is the time to take big steps and those steps, in the opinion of Mr. Park, are to support a robust, multimodal public transportation system. "Accessible transit can also be a huge benefit to the environment and a clean energy job-maker. Accessible high speed rail can transform California's economy and its communities."

This comment is from a civil engineering professor emeritus at the University of London. 
I am also a member of the Disabled Persons Transport Advisory Committee (DPTAC) which is an expert committee established by the Transport Act 1985, providing advice to the UK  government on the transport needs of disabled people. I chair the DPTAC Research and  Evidence subgroup. I am also a member of the US TRB Accessible Transportation and  Mobility Committee. 
I have been actively involved in the development of the Inclusive Transport Strategy (ITS) which is an equivalent document to the US Strategic Plan on Accessible Transportation. The ITS can be downloaded from https://www.gov.uk/government/publications/inclusive-transport-strategy
This person has credentials. Prof. Mackett's first point is that the Draft Strategic Plan on Accessible Transportation is missing both a timeline and a plan for how to monitor progress. The professor offers contrasting policies in the UK as well. For instance, he discusses e-scooters, which are permitted to operate in the US, sometimes even on sidewalks. In the UK, in contrast, due to the risk that these devices pose to blind pedestrians, they can only be used on private land or as part of ongoing research trials. Prof. Mackett also provides a link to information about lawsuits brought by rail passengers who use wheelchairs. He asks that research be done on access to trains, looking at the spacial difference between train platform and rail car.

Prof. Mackett also refers to the seminal work done in the UK to review laws and regulations related to autonomous vehicles (AVs), including, specifically, for people with disabilities and older adults. For anyone seriously interested in legal frameworks for AVs, that multipart series (probably coming to over 700 pages in full) is a tremendous resource. 

Comment from Zach Karnazes

We have here a comment from a knowledgeable disability activist. Here is a link to Zacthivism, which goes into detail about Mr. Karnazes' disability work and info, which is very San Francisco centric, but quite informative and thorough. I will just say that Mr. Karnazes is also quite pro-equity and pro-transit union. Indeed, his first point is exactly what I keep saying, that the Americans with Disabilities Act (ADA) should itself be complemented with or changed to allow for constant monitoring and enforcement rather than relying on passenger complaints. He suggests a federal civil rights enforcement body.

What Mr. Karnazes really wants is a new, better version of the ADA. I agree, but I doubt it will happen even if the filibuster were thrown out the window. Between COVID, vaccinations, saving democracy, and perhaps fixing or replacing crumbling infrastructure, no disability organizations are pushing for a wholesale refurbishing of the ADA. Mr. Karnazes, I salute you for speaking truth to power.

This comment is well worth the read, opinionated and with heart; here is a cursory look at Mr. Karnazes' wish list.
  • New ADA Title II, which removes "vague language around denials of access" based on administrative and financial burdens (which goes beyond transportation).
  • Increased funding for public transportation. Mr. Karnazes here cites the inherent conflict of interest for the bus driver when attempting to remain on schedule while taking the time to secure a person in a wheelchair.
  • Create an ombudsman office to help people with disabilities. "New York State has a program like this (https://aging.ny.gov/long-term-care-ombudsman-program), but California and most all other states do not."
  • Stop relying on disability organizations, "so-called "stakeholders" and corrupt "non-profits" that do not represent our community well and are afraid to make bold claims for fear of losing their federal funding." Instead, Mr. Karnazes suggests policy based on polling or other data collection that reflects the lived experience of people with disabilities. I will not offer my own commentary except to say that this gets complicated.
  • Make public transportation fare free for people with disabilities who are living in poverty. Mr. Karnazes refers the reader to videos in which people with disabilities describe the difficulties of living on Social Security assistance.
  • "Create a non-biased Grievance oversight procedure for ADA access issues with transportation, with the hearing judge that is not employed by or working at the office where the complaint is filed." Having worked at a local transportation administrative agency in a large city, I will remark that this recommendation has merit. However, I do not have knowledge of other agencies in this respect.
  • Support the bus drivers in their work and through their union.
This comment advocates briefly and without specifics for much improved public transportation systems in the US. The goals are accessibility, abundance of transit, and environmental friendliness. "Also, when you make public transit more accessible for one group of people, it ends up helping us all." Amen.

No comments:

Post a Comment