Accessible Rights of Way play an outsized role in transportation accessibility for people who are blind or low vision. We strongly support the 2011 AccessBoard Public Right of Way guidelines and would encourage DOT to promote further best practices for accessibility in the right of way that promote complete trips. Moreover, standards alone are not sufficient. Investing in pedestrian and transit-oriented infrastructure is key to ensuring that automobile dominance does not exclude people who are blind from participating in society. Even effective, systematic snow clearing promotes better access to integrated multimodal services. As we look to future innovative transportation, infrastructure design that incorporates accessible Pick-Up/Drop-Off Lanes (PUDOLs) promotes access to a variety of modes beyond fixed-route transit, including paratransit and other on-demand transportation services. These PUDOs should account for the safety of crossing bicycle infrastructure and parking.
Offices of Civil Rights are absolutely important for overseeing accessibility compliance. We believe more accessible complaint reporting processes that don't requiring mailing paper forms and maximizing OCR resources should be a part of the activities to improve accessibility.
People with disabilities should be included in the development and improvement of common data specifications to ensure that systems include the full range of accessibility variables necessary to identify barriers or accessible routes. These data specifications should not only be common to multiple modes but also across jurisdictions.