Inclusive Design of Autonomous Vehicles: A Public Dialogue Goal 3: Improve access for individuals with disabilities to passenger & commercial vehicles

Volkswagen Group of America supports DOT's focus on accessible transportation, including its announcement to create an online resource or library to house industry-produced accessible design standards and best practices and funding preliminary research work to begin the process of developing voluntary standards for vehicle accessibility developed by a private Standards Development Organization.

Despite fully self-driving... more »

In addition to anti-discriminatory licensing, USDOT should highlight existing ADA requirements that prohibit refusal of service because of insurance company conditions, coverage or rates. Research, discussions and other steps should be undertaken to ensure insurance rates for vehicles with ramps, lifts and additional accessibility features are not prohibitive and do not stall testing and deployment. In addition, if passengers... more »

USDOT should ensure AVs and current vehicles provide lifts or ramps, including kneeling, as well as securements. In addition, securements must include proper seat and shoulder belts in good repair. Today, the absence or incomplete presence of seat and shoulder belts often expose wheelchair riders to danger, even in ordinary traffic conditions, as opposed to a sudden stop or collision.

USDOT should consider adopting recommendations made by the CCD Transportation TF regarding 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. NHTSA should... more »

USDOT should encourage state DOTs and transit agencies partnering with or hosting AV testing or deployment to respond to the community's needs, particularly those in the disability community, low income, and communities of color, in rural and tribal areas that are often underserved. Agencies must engage these communities to identify problems and solutions, acknowledge the wealth of knowledge derived from experience, and... more »

USDOT should develop engagement guidance to state departments of transportation, state policymakers, metropolitan planning organizations and transit agencies, that includes steps on how to include members of the disability community, low-income communities, and communities of color in advisory groups.

USDOT should provide a template for private industry that could be used to undertake an accessibility assessment for all new vehicles. The assessment could be similar to the voluntary safety assessment. The results of the assessment should be included in the AV Transparency and Engagement for Safe Testing (AV TEST) Initiative database and website.

USDOT should consider and adopt July 2019 recommendations made by the Consortium for Citizens with Disabilities Transportation Task Force regarding commercial motor vehicle operation. The Transportation Task Force urged FMCSA to reconsider physical qualification restrictions regarding operation and monitoring of ADS-CMVs, and eliminate the restrictions placed on deaf and hard of hearing applicants for ADS and Non-ADS... more »

A recent NPRM regarding occupant protection for AVs provides 4 guiding principles NHTSA is using to address Federal Motor Vehicle Safety Standards (FMVSS) reform and regulatory barriers. These include: (1) maintaining current performance requirements, (2) reducing unnecessary barriers and uncertainty for manufacturers, (3) maintaining the current regulatory text structure, and (4) remaining tech neutral. In addition to... more »

As they are providing a service to the general public, they should not be allowed to do so unless they are accessible to those with disabilities. This should have to be demonstrated before they are given a license to operate.

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... more »

AFB is particularly concerned about AV accessibility. Without clear federal standards and enforcement, people who are blind or low vision are likely to be left out of the vehicles promise. On this priority, we encourage DOT to make accessibility and non-visual access a key priority in research activities and vehicle approvals. Requiring accessibility from the onset will ultimately enable equal access. In addition, DOT... more »

Vehicles are increasingly using more and more technologies. It should be standardized that Input/Output should be accessible to those with sensory disabilities. Moreover, with the development of self-driving autonomous vehicles, those new vehicles should be accessible for those with mobility disabilities as well. For example, a person who is blind or deaf should be able to enter a, say, autonomous taxi and able able to... more »

As a veteran, injured on active duty, It is still not safe for me to fly. Not covered by the ADA, air travel was supposedly ensured for the disabled by the Air Carrier Access Act signed over thirty years ago. It's not working. I've been dropped by low paid contract airline assistants, my wheelchair damaged to be unusable, and many other disabled Americans have faced similar problems. Some people have been refused flights.... more »

Rural isolation in unincorporated areas of counties makes it financially and geographically difficult for urban and suburban transit to provide needed door to door pick up when it is 7 miles or further to the rural location from the edge of the urban or suburban setting where services are available. Nonprofits can provide the dead end trips that allow rural isolated seniors and adults with disabilities who are unable... more »