March 5, 2018
U.S. Department of Transportation
Docket Operations
1200 New Jersey Avenue SE
Washington, DC 20590
Re: Comments Submitted Concerning Automated Driving Systems
Docket Number: FHWA-2017-0049
The Disability Rights Education and Defense Fund (DREDF) is a leading national civil rights law and policy center directed by individuals with disabilities and parents who have children with disabilities. Our mission is to advance the civil and human rights, and community integration of people with disabilities. DREDF demonstrated an early interest in the development of equitable autonomous vehicle policy in its drafting of the 2015 National Council on Disability report, Self-Driving Cars: Mapping Access to a Technology Revolution. The report examines the challenges and advances in autonomous vehicle (AV) technology, and proposes directions for research, development, and necessary infrastructure changes. The report also explores potential policies and legislation needed to ensure full access.
Automated driving systems (ADS) have the potential to dramatically improve the lives of people with disabilities and improve the safety of our streets. More than half a million people with disabilities never leave home and cite transportation difficulties. Children with disabilities are more than 5 times as likely to be hit by a motor vehicle as a bicyclist or pedestrian than children without disabilities. Many people with disabilities cannot drive or lack access to a personal vehicle. Only 45% of rental households with individuals who use wheeled mobility devices have access to a personal vehicle.
The promise and safety of ADS will only be realized if they take into consideration the needs of disabled travelers. Where roads in cities, suburban, and rural areas are considered highways, measures to ensure pedestrian and bicyclist safety should be considered. In areas where sidewalks are not provided, the risk for transit-dependent individuals, or those without access to cars in areas where there is no transit, is even higher. Accessible public rights-of-way and safe road crossings are necessary for the safety, efficiency and performance of ADS.
1. What roadway characteristics are important for influencing the safety, efficiency, and performance of ADS? 3. How does the state of good repair (e.g. pavement and road marking quality) impact ADS, including technology or safety costs, if at all?
DREDF recommends consideration of the following roadway characteristics and state of good repair factors:
- All efforts should be made to provide and maintain accessible sidewalks with curb cuts. US Access Board Proposed Public Rights-of-Way (2011) guidelines should be held as the standard.
- Any areas with traffic lights should also include well-marked, accessible crosswalks with audible pedestrian signals.
- Where the community has identified a need for a safe crossing on a highway, a traffic light or pedestrian hybrid beacon should be installed, along with an audible pedestrian signal. The Federal Highway Administration (FHWA) could take this opportunity to review, with stakeholders, warrant requirements for traffic light and beacon installation. Where a light or beacon has been requested by the community, the number of attempted crossings should not be a factor. The lack of a safe crossing should be considered a barrier to crossing, to community participation, equity and access.
6. How should FHWA engage with its State and local partners as they consider impacts on infrastructure, transportation funding, finance, and revenue?
DREDF recommends the following with regard to State and local engagement:
- The FHWA should convene meetings, webinars and other outreach with state and local representatives, and metropolitan planning organizations to discuss needed infrastructure investments and planning. Once needs are identified technical assistance could be provided. The FHWA could make use of materials and lists developed through the Mayor’s Challenge for Safer People, Safer Streets to identify needed infrastructure improvements and resources.
- The FHWA should consider working with the US Access Board to identify and work through specific needs for the disability community, e.g. if automated transit will require new docking stations, how can the station and any new facilities be most accessible and in compliance with current standards?
10. What are likely the most significant impacts of ADS on other motorized and non-motorized users of public roadways? What are the possible roles for road owners and operators to support the interaction of ADS with those users through infrastructure changes or operational changes?
DREDF recommends the following regarding significant impacts of ADS on non-motorized users:
- The most significant potential impact on non-motorized users is increased safety. Removing human error or distraction could decrease the risk of traffic crashes due to distraction. For people with disabilities and older adults, this not only means less loss of life and serious injury, less time in the hospital or in a Dr’s office, but also less frequent damage to wheelchairs and mobility aids. Damaged wheelchairs or scooters, which many rely on for mobility, can take weeks, months, or even years to fix or replace. In some cases replacement or repair may be cost prohibitive.
- Improving infrastructure, such as sidewalks, signals and crossings, will also increase access, safety, and mobility for all community members – which would improve access to transit, jobs, schools, healthcare and overall community participation.
- To ensure the greatest positive impact of ADS, the FHWA should consider outreach to cross-disability, older adult community, and transportation equity advocate stakeholders, including the US Access Board, and members of the Transportation Equity Caucus. The needs and rights of the disability community, older adults, low income communities, communities of color, and transit dependent communities should be considered.
Thank you for the opportunity to provide comment. Please contact Carol Tyson, Government Affairs Liaison, at (202) 878-9186 or ctyson@dredf.org with any questions. DREDF looks forward to supporting the efforts of the FHWA to ensure the safe testing and introduction of ADS on public roadways.
Sincerely yours,
Susan Henderson
Executive Director