February 11, 2020
Letter for the Record
Disability Rights Education and Defense Fund
Before the Consumer Protection and Commerce Subcommittee
Committee on Energy and Commerce
U.S. House of Representatives
Hearing: Autonomous Vehicles: Promises and Challenges of Evolving Automotive Technologies
Dear Chairman Pallone, Ranking Member Walden and members of the Subcommittee,
The Disability Rights Education and Defense Fund (DREDF) appreciates the opportunity to supplement the record for your hearing on Autonomous Vehicles’ promises and challenges. DREDF is a leading national civil rights law and policy center directed by individuals with disabilities and parents who have children with disabilities.
Nearly 1 in 5 people in the U.S. has a disability (more than 57 million). In 1990, Congress passed the bipartisan Americans with Disabilities Act (ADA). In enacting the ADA, Congress sought to “provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities.” While 99% of public buses are equipped with ramps, and curb cuts benefit the public, significant barriers to accessible, affordable transportation remain across modes. Without access to affordable transportation people with disabilities are unable to travel to work, to school, to contribute to and participate in their communities, to support and spend time with family and friends, and live their lives to the fullest.
AVs have the potential to drastically improve mobility for people with disabilities. However, the promise and safety of AVs will only be realized if the vehicles and the surrounding infrastructure are fully accessible, ie, accessible to people with sensory, cognitive, and physical disabilities, including wheelchair users, and people with neurological conditions, including seizure disorders. The safety elements such as the human machine interfaces and securement must also consider the needs of all people with disabilities. In addition, accessible vehicles will be needed if they are used by transit providers or in public-use fleets, and retrofitting will be more expensive for providers in the long run.[i] Unfortunately, news accounts of AV testing and deployment timelines, permits, exemptions and legislation often fail to mention accessibility.[ii],[iii],[iv]
DREDF encourages the subcommittee to consider the needs of future passengers with disabilities. Legislation should: prohibit discrimination on the basis of disability in licensing and insurance; require full accessibility for all types of common and public use AVs; and require accessibility features in mandated safety evaluation reports for consumers. Exemptions for development and testing of AVs meant for public use, including transit, paratransit, microtransit, first mile/last mile or circulator service should only be granted if they are fully accessible and safe for passengers, pedestrians and bicyclists. Should infrastructure be addressed, accessibility of public rights of way must be a priority.
Finally, we encourage policy that ensures access for those without smartphones and the unbanked, and inclusion of studies examining AV’s potential impacts on transportation and land-use patterns, congestion, pollution, road safety and public transit, members of low-income, indigenous, and disability communities, and communities of color.
DREDF thanks you for taking the promises and challenges of AVs seriously. We look forward to continuing to work with the Committee as legislation is developed.
Sincerely yours,
Susan Henderson
Executive Director
[i] Johnson, Mary and Barrett Shaw [Eds] (2001). To Ride the Public’s Buses: The Fight that Built a Movement. The Advocado Press.
[ii] Hawkins, Andrew (September 2018). Self-driving pods are slow, boring, and weird looking – and that’s a good thing, The Verge. Available at
https://www.theverge.com/2018/9/17/17859112/self-driving-cars-shuttle-pods-delivery-services
[iii] Laris, Michael (October 2018). From Model T to driverless: Ford to launch fleet of robot cars in Washington, DC, Washington Post. Retrieved from
https://www.washingtonpost.com/local/trafficandcommuting/from-model-t-to-driverless-ford-to-launch-fleet-of-robot-cars-in-washington/2018/10/21/6d98119e-d2f6-11e8-b2d2-f397227b43f0_story.html
[iv] Sage, Alexandria and Paul Lienert (November 2017). GM plans large-scale launch of self-driving cars in US Cities in 2019. Retrieved from
https://www.washingtonpost.com/local/trafficandcommuting/from-model-t-to-driverless-ford-to-launch-fleet-of-robot-cars-in-washington/2018/10/21/6d98119e-d2f6-11e8-b2d2-f397227b43f0_story.html