May 30, 2018
The Honorable Secretary Elaine L. Chao
U.S. Department of Transportation
1200 New Jersey Ave, SE
Washington, DC 20590
Scott Pruitt, Administrator
Office of the Administrator, 1101A
Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Re: The Corporate Average Fuel Economy (“CAFE”) Standards’ Potential Impacts on Transportation Options for People with Disabilities
Dear Madam Secretary and Administrator Pruitt:
As Chairman of the National Council on Disability (“NCD”) - an independent, nonpartisan federal agency charged with providing advice to the President, Congress and federal agencies on matters affecting the lives of people with disabilities - I write to request that the Department of Transportation (“Department”) fully consider the potential impacts that the Corporate Average Fuel Economy (“CAFE”) standards could have on the availability of vehicles and transportation options for people with disabilities. Two significant concerns are the standards’ possible effects on vehicle affordability and the ability and willingness of vehicle manufacturers to continue to produce vehicles that can be specially equipped for people with disabilities who use heavy wheelchairs.
Transportation has been, and remains, one of the most challenging barriers to full inclusion, self- sufficiency, and independence for people with disabilities. People with disabilities are underrepresented in the workforce at a staggeringly high rate compared to their non-disabled peers and as a result many live in poverty although they may be able and willing to work, and a high percentage of people with disabilities report that the lack of transportation is a significant barrier to obtaining and retaining employment. Ensuring that adequate, accessible transportation options are made available is therefore a critical part of the solution to the unemployment and corresponding poverty that is an every-day reality for millions of persons with disabilities.
While increased transportation options will allow people with disabilities to get to work, church, school and participate fully in society, this cannot happen if vehicles are unaffordable to them, thus, I urge the Department to examine whether the implementation of the CAFE standards will impact the affordability of vehicles. In particular, the Department should examine the impact on the price of vehicles manufactured with accessibility features (at the factory), and vehicles that are manufactured for later adaptation for heavy wheelchair access, such as heavier vans. It would be devastating if the standards resulted in making vehicles out of reach for people with disabilities, especially when the disability community and federal agencies are working feverishly to help people with disability achieve greater employment, which requires more and greater mobility opportunities.
It is also unclear how the CAFE standards will impact the ability and willingness of vehicle manufacturers to continue to produce heavier vehicles that can be specially equipped for access by heavy wheelchairs. The standards call for greater fuel efficiency, but it is well known that vehicles, such as vans that are adapted for the use of heavy wheelchairs are not fuel efficient. Nevertheless, they are a much-needed form of transportation for people with disabilities and their families, and must continue to be manufactured to meet their needs. I know from my own family the importance of these vehicles and the weight that adaptations can add. My brother served in the Vietnam war and became quadriplegic. His power wheelchair and accessibility adaptations added so much weight to his vehicle that the gas mileage was greatly reduced - far below the mileage listed when the vehicle was purchased before being retrofit.
In closing, NCD is concerned about the impact of the CAFE standards on the future availability of affordable vehicles and vehicles that can be adapted for the use of heavy wheelchairs. These concerns are also relevant in regard to the emerging technology of autonomous vehicles that, if done correctly, will greatly expand transportation options for people with disabilities. Because of the importance of ensuring that future vehicles are affordable and accessible to people with disabilities, I urge the Department to take into consideration the balance between more efficient vehicles and the needs of a significant constituency that require affordable and adaptable vehicles that might make implementation of those standards impossible. People with disabilities should not be left behind in the development of new transportation technologies, if so it will cause a serious reduction in the supply of much needed transportation options.