CCD Letter on Accessibility in Autonomous Vehicle and Surface Transportation Legislation

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December 23, 2025

The Honorable Brett Guthrie
House Energy & Commerce Committee
2125 Rayburn House Office Building
Washington, DC 20515

The Honorable Ted Cruz
Senate Commerce Committee
254 Russell Senate Building
Washington, DC 20510

The Honorable Frank Pallone
House Energy & Commerce Committee
2125 Rayburn House Office Building
Washington, DC 20515

The Honorable Maria Cantwell
Senate Commerce Committee
254 Russell Senate Building
Washington, DC 20510

RE: Accessibility Considerations to Ensure Access and Safety for Disabled Travelers in Autonomous Vehicle Legislation and Provisions in Surface Transportation Reauthorization

Dear Chairs Guthrie and Cruze and Ranking Members Pallone and Cantwell:

The undersigned members of the Consortium for Constituents with Disabilities (CCD) Transportation Task Force and fellow advocates urge you to consider and prioritize the safety and access needs of disabled passengers and pedestrians in any stand-alone autonomous vehicle (AV) legislation or surface transportation provisions. Recommendations in this letter reference Congressman Latta’s 2023 SELF DRIVE Act discussion draft (SELF DRIVE Act Draft) and Congresswoman Dingell’s AV framework proposal (AV Framework Proposal).[1] We recognize Representative Dingell and Latta’s leadership of the Congressional Autonomous Vehicle Caucus and are grateful for their acknowledgement that disability rights advocates must be at the table as AV frameworks are developed.[2] We are also providing ‘Disability Access in AVs and Motor Vehicles’ draft bill text (Access in AVs Draft) for your consideration.

CCD is the largest coalition of national organizations working together to advocate for Federal public policy that ensures the self-determination, independence, empowerment, integration and inclusion of people with disabilities. The Americans with Disabilities Act (ADA) sought to “provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities.” Through AV policymaking Congress has the opportunity to lead, uphold the ADA’s mandate, enhance safety, and improve lives and mobility for all.

The CCD Transportation Task Force has adopted cross-disability AV Principles and provided feedback on past AV legislative drafts.[3],[4] Signatories to the principles included 20 national organizations. Many of our members also participated in 3 days of AV accessibility workshops in 2019 hosted by the Alliance of Automobile Manufacturers (an organization preceding the Alliance for Automotive Innovation) with government, industry and disability stakeholders, and U.S. Department of Transportation (USDOT) and U.S. Department of Labor (USDOL) listening sessions.[5],[6] AVs can improve mobility and quality of life for the disability community, including for those with physical, sensory, intellectual and developmental disabilities and neurological conditions such as epilepsy. For the full potential of AVs to be realized any AV legislation must:

• explicitly include consideration of accessibility and the needs of disabled travelers of all disability types in each rulemaking, including federal motor vehicle safety standards (FMVSS) updates;
• ensure exemptions granted based on improved access address the biggest challenges to accessibility;
• ensure preemptions do not prohibit state or local requirements or performance metrics that would increase the numbers of fully accessible autonomous vehicles and services accessible to people with disabilities, including wheelchair users;
• ensure AV-related ADA or other civil rights claims can be filed in court;
• ensure AVs complement and improve public transit;
• ensure data collected and safety considerations address the needs for accessible sidewalks, crossings, curb cuts, accessible pedestrian signal and related infrastructure;
• and ensure USDOT and the US Access Board have the resources and staff to adopt and implement necessary research, rulemaking and standard setting.

Nearly 1 in 5 people in the U.S. has a disability (more than 57 million). In addition, the age of people over 65+ is set to double by 2050. Many older adults who acquire short or long-term disabilities or health conditions in both rural and urban settings will need accessible transportation options to access healthcare and remain active in their communities. As a result of the passage of the ADA, 99% of public buses are equipped with ramps, curb ramps benefit the public, and there is improved provision of accessible transit to people with sensory disabilities. Yet, significant barriers to accessible, affordable transportation remain across modes.

Many people with disabilities cannot drive because of their specific disability, are currently unable to obtain a driver’s license, are denied service or cannot afford to purchase a wheelchair accessible vehicle (WAV).[7] It’s critical that ride-share and on-demand services provide disability access yet there are not adequate WAVs and trip denials for service animal users and other people with disabilities are rampant. There are no purpose-built wheelchair accessible passenger vehicles on the market today in the United States. Wheelchair users often pay nearly double the price of the vehicle for necessary aftermarket modifications, including to have a ramp installed or other features that require exemptions from the FMVSS.[8]

Without affordable, accessible 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. A report by the National Disability Institute found that a critical barrier to competitive integrated employment and entrepreneurship is a lack of accessible transportation options. Accessible, affordable, and sustainable AVs could lead to an additional 4.4 million jobs for people with disabilities, an additional $867 billion in U.S. GDP and $1.6 trillion in U.S. output.[9]

Manufacturers and transportation providers are developing, testing and deploying autonomous shuttles and passenger vehicles. AVs have the potential to dramatically improve access for people with disabilities. The promise and safety of AVs will only be realized if the vehicles and the surrounding infrastructure are fully accessible, and the safety elements consider the needs of all people with disabilities.

Regarding any AV legislation we urge you to:

Retain the Following Provisions from the SELF DRIVE Act Draft and the AV Framework Proposal

Licensing and Insurance – Legislation should prohibit discrimination on the basis of disability by states and any other governmental authorities in licensing and insurance. We strongly support the provisions that prohibit discriminatory licensing laws nationwide.

Highly Automated Vehicles Advisory Council – An Advisory Council comprised of industry, consumer, safety, labor, civil rights and other stakeholders is necessary to continue discussions and identify barriers, unintended impacts and solutions. Disability representation is critical and should be included within any advisory council and should also be required to consider accessibility needs.

Include Accessibility and Strengthen the Following in the SELF DRIVE Act Draft and the AV Framework Proposal

Safety Framework and Self-Assessment Rulemakings – The SELF DRIVE Act Draft and AV Framework Proposal direct NHTSA to initiate safety rulemakings and safety assessments for entities developing AVs. The timelines in the proposals differ. We support the SELF DRIVE Act draft’s inclusion of accessibility including non-visual accessibility, in the safety assessment. The Access to AVs Draft requires a safety rulemaking for accessible AV HMIs and a rule for automated driving systems (ADS) to assess and validate the performance of sensing, perception and response to disabled people outside the vehicle.

Any safety framework rulemaking must also include a requirement for USDOT to consider the needs of all disabled travelers, including people with physical, sensory (those that are blind or low vision or Deaf or hard of hearing) and intellectual and developmental disabilities. A mandate from Congress for all AV-related rulemakings would ensure inclusion. The vehicle’s ADS HMI and object detection outside the vehicle are critical in any safety framework. HMI must be accessible to people with sensory and cognitive disabilities for AVs to reach their full potential. A Disability Rights Education & Defense Fund brief on ableism in AV AI and algorithms recommends standards be set to ensure AVs can detect all people with disabilities and other members of marginalized communities outside the vehicle.[10] Research and recent anecdotes suggest that not all AVs are being taught to detect people seated in their wheelchairs, service animal users, or people with darker skin tones, among others.

Proposed manufacturer self-assessments require USDOT to identify risks to motor vehicle safety and steps taken to mitigate such risks during the design, development, and introduction into interstate commerce. Accessibility and how the needs of disabled travelers, including non-visual access and access for wheelchair users, are being met must be included in safety self-assessments provided by manufacturers and in any publicly available database.

Updating Existing FMVSS Standards – The SELF DRIVE Act Draft would require a review of FMVSS and initiating or documenting research to evaluate AV safety. The AV Framework Proposal would require updating FMVSS within 3 years.

Existing FMVSS must be updated to ensure the safety of AVs, including level 4 and 5. We strongly encourage Congress to require USDOT to include a review of how updated FMVSS will ensure the safety of fully accessible AVs, including those that are both electric and autonomous, and are built with wheelchair ramps and will require testing and deployment of automatic securement systems.[11] The federal safety framework must assume deployment of, and advance progress toward, fully accessible passenger vehicles (both large and small) as well as accessibility standards. These standards will not only increase public trust of AVs, but also a roadmap for those in the industry seeking to develop and deploy the safest, most accessible vehicle.

Examples of FMVSS related standards that require attention for passenger-related accessible ergonomics are active suspension and kneeling capabilities for level entry, vehicle doorway heigh and width for entry, rear passenger entry for ambulatory self-or assisted passenger transfers, passenger restraint systems, ramps and mobility equipment securement, and grab assistance throughout vehicles that allow for perpendicular movement. Any updates to the FMVSS must maintain the current exemptions to crashworthiness for modified vehicles to install a ramp until vehicles are fully accessible and such modification is no longer required for physical access. The Access to AVs Draft requires a standard for automated restraint systems for wheelchair users and ramps and ramp installations.

Exemptions for Vehicles that Benefit People with Disabilities – The SELF DRIVE Act Draft and AV Framework Proposal would allow NHTSA to exempt up to 100,000 and 80,000 AVs per manufacturer each year respectively. Both proposals would allow exemptions to be granted ‘if the vehicle would provide transportation access for individuals with disabilities, including non-visual access for individuals who are blind or visually impaired.’

We support this provision if the existing language is strengthened to incentivize manufacturers to address the more difficult accessibility challenges such as vehicles that can effectively communicate with people who are blind or Deaf, are accessible for wheelchair users who remain in their wheelchair, and provide automatic wheelchair securement. Vehicles eligible for this exemption must be accessible for all people with disabilities and the exemption should clearly define the requirements.[12]

Exemption Database – The SELF DRIVE Act Draft and AV Framework Proposal require publishing data of exempted vehicles. We urge you to require publishing whether the vehicle was granted an exemption because it would promote access for individuals with disabilities and how it promotes such access.

Public Transportation – The SELF DRIVE Act Draft includes in the definition of AV vehicles that provide public transportation while the AV Framework Proposal does not and requirements in the proposal would not apply to transit vehicles. We encourage any bill to allow use of and permit exemptions for vehicles used in public transportation. We note the ADA requires transportation provider’s personnel to assist with the use of securement systems, lifts, and ramps.[13] We recommend legislation require research into the value of transit employees on transit vehicles who can serve as ambassadors and focus on customer service including wayfinding and emergency assistance. AV use in public transportation ensures AV rideshare providers are under clear civil rights law obligations, including the ADA. Without transit and paratransit providers adopting accessible AVs, a significant market for AVs is lost. It is worth noting that assisting people with disabilities is a universal value consistently expressed by the AV industry.

In addition, permitting AVs to be used in public transit could create opportunities for AV rideshare and transit to work together to ensure on-demand service is complementing rather than replacing transit. Studies have shown that when a rideshare service enters a market and provides what some view as a more convenient alternative to public transit, transit ridership can decrease.[14] Decreased ridership can lead to cuts in fixed bus routes and service hours which also leads to potential cuts in required paratransit service provided for people with disabilities.  Finally, many AVs are likely to be electric vehicles. Prohibitions on the use of certain electric vehicle types by transit agencies may create an additional barrier to electrification of paratransit and transit fleets, leaving people with disabilities behind.

Preemption – There is a provision in the SELF DRIVE Act Draft that preempts state or political subdivisions of a state to maintain, enforce, prescribe, or continue in any effect any law or regulation regarding the design, construction, or performance of AVs. The AV Framework Proposal provision creates an interim period of preemption for 10 years unless an AV framework is established. We are concerned these provisions may unintentionally preempt AV accessibility or equity performance measures or requirements at the state or local level, including state laws that would mandate vehicle environmental standards to mitigate harm. While we understand the need for federal standards of vehicle design and construction, we also encourage allowing states and local jurisdictions to seek higher performance requirements that also ensure the greatest access and benefits for disabled and other historically underserved travelers. Many cities like New York City, Chicago, and San Francisco have taken the lead in defining accessible parity for mobility solutions that use public roads and streets to operate. Their leadership and innovation for service needs to continue to be allowed and local and state levels. The Access to AVs Draft bill prohibits discrimination on the basis of disability by AV operators that would protect the rights of disabled passengers and pedestrians should preemption be included.

Forced Arbitration – The SELF DRIVE Act Draft does not reference or prohibit forced arbitration clauses from AV service providers or sellers. The AV Framework Proposal prohibits pre-dispute arbitration agreements related to the use of AVs but does not include remedies available under civil rights laws.

We strongly encourage inclusion of a prohibition on forced arbitration clauses in any AV framework. AV providers must be held accountable for injuries and property damage, and remedies available under applicable civil rights must be made available.[15] Disabled passengers repeatedly face discrimination from rideshare and micromobility services and disabled pedestrians and cyclists routinely have dangerous interactions with vehicles in public streets and rights of way. The rights of disabled travelers should be protected to ensure a safe and quality experience. In order to fully protect their rights, all disabled people must have the option to take their claims, including those under civil rights laws and the ADA, to court. Should forced arbitration be allowed, we urge upholding disabled travelers’ rights. The Access to AVs Draft bill includes a provision and language limiting forced arbitration when involving death or injury of disabled person, unfair practices affecting a disabled person, harm to wheelchairs or service animals.

USDOT Personnel and Staffing, Resources for Development – The SELF DRIVE Act Draft does not provide funding or staff to USDOT to implement requirements. The AV Framework Proposal authorizes funds to NHTSA and requires a report on the staffing and resource needs for USDOT, including additional personnel or resources needed in the 10-year period following the bill’s passage. The Secretary is to consider the staffing of the Highly Automated Systems Safety Center of Excellence. We strongly encourage including in the report the staffing and resource needs required to ensure accessibility and safety are prioritized in the development of AVs, as well as creating a department within the Center for Excellence, or a separate center focused on accessibility of AVs. We also encourage the hiring of experts with disabilities who bring their own lived experience and informed perspective.

Consider Adding Provisions not included in the SELF DRIVE Act draft or AV Framework Proposal

Infrastructure Data and Considerations – For travelers with disabilities to safely utilize, enter and exit an AV the surrounding infrastructure must be accessible. When data is collected through mapping or other means, AV service providers and government entities should collect and share infrastructure accessibility information, including areas where pick-ups and drop-offs may be unsafe. This data could then be used to identify necessary improvements.

Privacy: Passengers’ health, disability status, and locations visited must not be shared or used for commercial or tracking purposes without permission of the individual.

U.S. Access Board AV Standards Mandate – The US Access Board currently provides accessibility guidelines and standards for policymakers and industry for transportation vehicles including buses and vans, rail cars and automated guideway vehicles and public rights of way.[16] There are currently no federal accessibility standards for fully accessible AV passenger vehicles. USDOT has on their Inclusive Design Challenge webpage a list of existing standards, e.g., wheelchair securement, that may be used as a guide for the time being.[17] There is also a summary report from the Alliance of Automobile Manufacturers-hosted AVs and Increased Accessibility workshops that identifies accessibility needs in detail.[18] However, these do not hold the same weight nor are they enforceable.

A mandate for the U.S. Access Board to draft AV standards is critical in any legislative framework. In addition, including a deadline within which the Department of Justice and USDOT must adopt the standards and providing sufficient funding for the Access Board to develop the standards is necessary.

Thank you for your consideration. Please contact CT Tyson at ctyson@dredf.org and Sarah Malaier, smalaier@afb.org, with any questions. We are eager to support your efforts to enhance safety and mobility for all.

Sincerely,

CCD Transportation Task Force Co-Chairs

Danica Gonzalves, Paralyzed Veterans of America, danicag@pva.org
Sarah Malaier, American Foundation for the Blind, smalaier@afb.org
Tyler Beck, Epilepsy Foundation of America, tbeck@efga.org
Sarah Bellish, Cure SMA, sarah.bellish@curesma.org
Olivia Keller, Amputee Coalition, okeller@amputee-coalition.org

Signatory Organizations

Access Ready

American Association of People with Disabilities

American Council of the Blind

American Foundation for the Blind

American Printing House for the Blind

Autistic Women & Nonbinary Network

Christopher & Dana Reeves Foundation

Cure SMA

Deaf Equality

Disability Belongs

Disability Rights California

Disability Rights Education & Defense Fund

Easterseals

Epilepsy Foundation of America

Muscular Dystrophy Association

National Council on Independent Living

Paralyzed Veterans of America

Spark Access

TDIforAccess

United Spinal Association

[1] Congressman Latta’s 2023 SELF DRIVE Act discussion draft and Congresswoman Dingell’s 2023 AV framework proposal were summarized in a July 24, 2023 Energy & Commerce hearing memo: https://d1dth6e84htgma.cloudfront.net/IDC_Memo_Self_Driving_Vehicles_AV_Hearing_2023_07_26_be020b0868.pdf. The full text of Congresswoman Dingell’s 2023 AV framework proposal is available at: https://debbiedingell.house.gov/uploadedfiles/dingell_automated_vehicle_discussion_draft.pdf

[2] Dingell, Latta Statement on DOT AV Framework (April 2025). https://debbiedingell.house.gov/news/documentsingle.aspx?DocumentID=5644

[3] Consortium for Constituents with Disabilities Transportation Task Force Autonomous Vehicle Principles, updated May 2022. Available at https://www.c-c-d.org/fichiers/CCD-Disability-AV-Framework-Hearing-Letter-072523-FINAL.pdf.

[4] CCD Transportation Task Force August 23, 2019 feedback on AV Bill Issues, including disability access, advisory committees, rulemakings, exemptions, privacy, safety evaluation reports and accessibility features, crash data, resources for NHTSA, consumer education, studies examining potential impacts, and infrastructure available at https://www.c-c-d.org/fichiers/CCD-Transpo-TF-Feedback-on-AV-Bill-Issues-082319.pdf. November 4, 2019 Feedback on AV Legislation Sections, including on a HAV advisory council, and disability exemptions available at: https://www.c-c-d.org/fichiers/CCD-Transp-TF-Feedback-on-AV-Sections-110419.pdf. December 9, 2019 Feedback on AV Legislation Sections, including on new FMVSS and licensing and insurance available at https://www.c-c-d.org/fichiers/CCD-Transp-TF-Feedback-on-AV-Sections-120919.pdf. February 21, 2020 Feedback on AV Legislation Sections, including on consumer education, cybersecurity, personnel and staffing, and additional considerations available at: https://www.c-c-d.org/fichiers/CCD-AV-Sections-Response-02-21-20.pdf.

[5] Autonomous Vehicles and Increased Accessibility Workshops (May 3, July 19, September 10, 2019). Hosted by the Alliance of Automobile Manufacturers (an organization preceding the Alliance for Automotive Innovation). Washington, D.C. Summary Report, agendas and presentations available at https://www.autosinnovate.org/avaccessibility.

[6] U.S. Department of Labor (October 2019). Autonomous Vehicles: Driving Employment for People with Disabilities. Available at https://www.dol.gov/odep/topics/AV-Info-Guide-Revised.doc.

[7] A Bureau of Transportation Statistics (BTS) study of adults with disabilities found that roughly half of respondents 18 to 64 reported living in a household with income under $25,000. Bureau of Transportation Statistics (2018). Travel Patterns of American Adults with Disabilities. Available at https://www.bts.gov/travel-patterns-with-disabilities.

[8] The aftermarket modifications for wheelchair accessibility are vitally important for the ability of wheelchair users to travel outside their homes. However, wheelchair users face an uncomfortable tradeoff between that access and their safety since the modifications may decrease the overall crashworthiness of the vehicle. People with disabilities regularly choose access over safety. This tradeoff exists because neither manufacturers nor NHTSA have obligations to make today’s passenger vehicles both safe and accessible to all people with disabilities and fail to do so voluntarily. As long as this tension exists, nothing in the proposed legislation should diminish access to after- market modifications of vehicles to provide vehicle access to people with disabilities.

[9] National Disability Institute (December 30, 2022). Economic Impacts of Removing Transportation Barriers to Employment for Individuals with Disabilities Through Autonomous Vehicle Adoption. Available at https://www.nationaldisabilityinstitute.org/reports/autonomous-vehicle-adoption/.

[10] Ian Moura for the Disability Rights Education and Defense Fund (November 2022). Addressing Disability & Ableist Bias in Autonomous Vehicles: Ensuring Safety, Equity & Accessibility in Detection, Collision Algorithms & Data Collection. Available at https://dredf.org/addressing-disability-and-ableist-bias-in-avs/.

[11] The industry’s safety standards for independent wheelchair securement and passenger restraint should be adopted by NHTSA and integrated into the FMVSS.

[12] The SELF DRIVE Act introduced in 2021 included an exemption for vehicles that would improve access for individuals with disabilities. The draft does not reflect how many vehicles could be exempted under this subsection.

[13] 49 CFR 37.165(f)

[14] UrbanismNext, University of Oregon (2021). Do Transportation Network Companies Increase or Decrease Transit Ridership – Empirical Evidence from San Francisco. Available at https://www.urbanismnext.org/resources/do-transportation-network-companies-increase-or-decrease-transit-ridership-empirical-evidence-from-san-francisco-2.

[15] We support provisions prohibiting some predispute arbitration claims. We also encourage remedies available under applicable civil rights laws be included.

[16] The US Access Board is an independent federal agency that promotes equality for people with disabilities through leadership in accessible design and the development of accessibility guidelines and standards. Learn more and review the guidelines and standards they have developed at https://www.access-board.gov/.

[17] US Department of Transportation Inclusive Design Challenge Resources. Available at https://www.transportation.gov/inclusive-design-challenge/resources.

[18] Autonomous Vehicles and Increased Accessibility Workshops (2019). Available at https://www.autosinnovate.org/avaccessibility.