We applaud DOT's commitment to accessible transportation and are excited by the investments they have already made to fund the development of accessible AV standards through a partnership with a Standards Development Organization. We look forward to engaging in this important work and hope that DOT will intentionally engage people with disabilities and disability rights organizations as the agency pursues this necessary work. We urge DOT to work with the DOJ's Civil Rights Division to develop guidance for companies that operate a private primarily transportation service. This should include technical assistance on steps to take to ensure that all people with disabilities can use the service with comparable wait times for users that don't have a disability. Currently, wheelchair users, for example, are unable to rely on existing on-demand transportation services, typically taxi cabs and similarly operating services.
As AV services begin to operate in a few parts of the country, it is important that we avoid waiting for these fleets of autonomous vehicles to be deployed before the companies have access to information that will allow them to stand up a service that complies with the ADA. The same holds true for autonomous shuttle and circluator services, some of which have started running and are inaccessible to many people with disabilities. Today, the wheelchair-using population is unable to access on-demand service primarily due to the "taxi cab" exemption in the ADA. Additionally, many people with disabilities are unable to access transit options due to a lack of equity in the distribution of transit resources and infrastructure. With foresight in the form of thoughtful guidance developed in collaboration with disability stakeholders and industry, we will be able to end the transportation disparities experienced by certain populations of disabled people.