NCD Response to DOT Request for Information Regarding Automated Vehicles and Disability

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June 1, 2018

Submitted electronically to the Accessible Transportation Technologies Research Initiative at ATTRI@DOT.GOV

Re: Email of Friday, May 25, 2018, from Loren Smith requesting information on automated vehicles and disability

To Whom It May Concern:

The National Council on Disability submits the following in response to your request for input on automated vehicles and disability. Thank you for the opportunity to provide input on this important topic. If we can be of further assistance, please contact Joan Durocher at jdurocher@ncd.gov, or Ana Torres-Davis at atorresdavis@ncd.gov.

1) Identify existing research/studies relevant to this issue.

2) Describe any ongoing studies the group should be aware of and the estimated completion date.

3) Make recommendation for new research or demonstrations that could be conducted under the 2018 Omnibus Appropriations Highly Automated Vehicle (HAV) legislation.

NCD strongly recommends that DOT fund research and demonstrations on:

  • AVs for the rural transportation needs of people with disabilities, such as further developing the AV technology that works on unmarked and unpaved roads.
  • AVs that are fully wheelchair accessible with a cost that is comparable to non-autonomous vehicles, such as vans that are adapted for wheelchair users.
  • Innovative AVs – such as those that are created with 3D printing and are accessible to people with disabilities and created with 3D printing technology. The research/demo would include choosing a state to conduct a demo that would waive any restrictions/definitions of “automobile” or “vehicle” so that the models could be road tested.
  • AVs that are designed for paratransit and road tested in rural, suburban and urban settings.
  • Wheelchair accessible autonomous taxis (including road testing).
  • Examining state motor vehicle statutes nationwide to determine barriers to putting AVS on the road and make recommendations on eliminating the barriers and how to achieve comity between state laws on AV.
  • Examining rental-car company policies to determine barriers to persons who have disabilities and recommendations on adapting those policies as such companies add AVs to their fleets.