March 5, 2018
U.S. Department of Transportation
Docket Operations
1200 New Jersey Avenue SE
Washington, DC 20590
Re: Comments submitted concerning Research Program: Automated Transit Buses
Docket Number: FTA-2017-0024
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.
Transit bus automation has 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 automated transit buses will only be realized if they are truly accessible, and the regulations, laws and policies take into consideration the needs of disabled travelers. To this end, we ask you to consider the following regarding the research program for automated transit buses.
Wheelchair securement must be available and we were grateful to see it listed as an area of interest in the request for comment. Additional research and development could lead to universal, functional, reliable, and safe automated securement systems. These systems would not require an on-board operator for power and manual wheelchairs both with and without brakes. Developers must address the issues of whether wheelchair users can reach and operate seat and shoulder belts, and any controls needed to deploy automatic securement. Q’straint has developed Quantum, an automatic wheelchair securement station. This system, and all future systems, should be reviewed in consultation with the US Access Board and the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA). Standards should be set and factors such as cost, maintenance requirements, quality, the need for mobility device standards, and whether the systems would provide adequate safety for all wheelchair users should be determined.
In addition, DREDF recommends that the FTA and ITS work in consultation with the US Access Board and representatives from the disability community as new technology is developed to ensure full accessibility for automated transit. DREDF notes the accessibility analysis that is set for year three of the Strategic Transit Automation Roadmap (STAR) Plan. The analysis should include discussions with the US Access Board, and cross-disability representatives.
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 FTA automated transit research program in the future.
Sincerely yours,
Susan Henderson
Executive Director