WWR DOT RFI Response

January 31st, 2020

We Will Ride Coalition
Samuel Drzymala, Advocacy Consultant

[email protected]​, 314-608-9319
P.O. Box 40411

Arlington, VA 22204

Mr. Finch Fulton
Deputy Assistant Secretary for Transportation Policy
Office of the Secretary of Transportation (OST)
Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590

Re: DOT-OST-2019-0187

As members of the We Will Ride Coalition, the undersigned organizations applaud,
support and encourage the U. S. Department of Transportation (DOT) in its efforts to
launch an inclusive design challenge to enable access to automated vehicles (AVs) for
persons with disabilities, and we offer the following comments on ways to refine the
approach.

The We Will Ride Campaign was founded by leaders in the disability rights movement
to ensure that the coming transportation revolution of autonomous vehicles reaches its
potential to serve all Americans. We work to develop a constructive conversation
around the needs of Americans with disabilities and how automobile manufacturers and
agencies of the federal government respond to a changing regulatory environment.

We encourage DOT to refine the “vehicle use” criteria to encourage innovation in
wayfinding more comprehensively, similar to how the draft criteria deal with the issue of
mobility device securement. For example, wayfinding should not be limited to only
locating the vehicle. For some people with disabilities, door to door assistance is
necessary in order for the entire trip to be completed in an independent manner.
“Complete Trip” wayfinding should build on the excellent work being done by DOT’s
Accessible Transportation Technologies Research Initiative​ (ATTRI) and be expanded
to address locations that are not in close proximity to public transit hubs.

We ask the Department to expand the challenge to include interaction with the physical
environment as well as the transportation infrastructure that facilitates vehicle travel and
passenger use. Challenge criteria should include, but should not be limited to, the
accessibility of pick up and drop off areas. Accessibility of sidewalks and streets is
essential to ensure safe use of the infrastructure as individuals with disabilities seek to
complete their trip by entering and exiting the vehicle and efficiently locating their final
destination. We also ask the Department to expand their understanding and definition of
the kinds of equipment that may need to be stored in a vehicle. A variety of people with
disabilities, beyond those with physical disabilities, use a range of equipment that may
need to be stored in a vehicle. For example, someone with chronic obstructive
pulmonary disease may use oxygen therapy and need to transport an oxygen tank on a
regular basis.

Significantly, the RFI encourages design suggestions that extend current reliance on
vehicle aftermarket modification. Reliance on aftermarket modification is in conflict with
both the overall spirit and the specific purpose of the competition: encouraging original
equipment manufacturers to design the next generation of passenger vehicles
accessible to people with disabilities. Should DOT issue a Notice of Funding Availability
(NOFA) on inclusive design, it must be clear that the AV of the future should not be
dependent on aftermarket processes that tremendously increase the cost of vehicle
platform, ongoing maintenance, and make it more difficult for the vehicle to meet
Federal Motor Vehicle Safety Standards (FMVSS). We support including the above or
similar language when a design challenge is released by the department. We strongly
urge the DOT to fully consider it.

We appreciate your efforts to include people with disabilities, and we suggest
strengthening these efforts by requiring that the process for selecting criteria to evaluate
design challenge submissions include people with disabilities, particularly individuals
who currently face the specific barriers to transportation that the design team seeks to
address.

We applaud DOT’s emphasis on engaging members of the disability community
throughout the design and development process. One troubling dynamic within this
design challenge is that there is an inherent assumption that people with disabilities will
only be consumers of these designers and not act as designers, engineers, or project
leads themselves. People with disabilities are found in every profession. We encourage
DOT to address this assumption and recognize the diversity of roles that members of
the disability community may have in the design challenge process.We hope people
with disabilities using their professional training are able to join the competition on

design teams, to compete and be evaluated for the expertise they bring to addressing
this essential challenge. We also strongly encourage DOT to require engagement with
multiple marginalized people in the disability community, whether as designers or as
stakeholders. The disability community is incredibly diverse, and people with disabilities
experience poverty at greater rates than those without disabilities. Solutions that do
recognize these realities will not reach the desired outcome of autonomous vehicles
serving all Americans.

Finally, we encourage the Department or a third party to establish a “clearinghouse” of
information for those interested in participating in the design challenge. The goal of the
clearinghouse would be to identify stakeholders interested in collaborating on similar
issues included in the challenge, and to facilitate the formation of multi-stakeholder
teams to address these accessibility challenges.

Information sharing would assist with capturing the contributions of as broad a range of
perspectives as possible. It would allow communities to be formed that will have value
beyond any immediate innovation that an inclusive design challenge might create, thus
supporting additional innovations in the future. For example, all those who submit
proposals to the design challenges could be compiled in a database, including their
specific areas of interest. The database could be made available to the public through
the Federal Register or another official website. An approach such as this will allow
information sharing while avoiding the perception that DOT is exerting undue influence
in the competition.

We look forward to working with stakeholders and the Department on this design
challenge, and encourage its release as soon as possible.
Sincerely yours,

The American Association of People with Disabilities​ (AAPD)
The National Council for Independent Living​ (NCIL)
Paralyzed Veterans of America​ (PVA)
United Spinal Association