December 29, 2020
National Highway Traffic Safety Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
Dear Deputy Administrator Owens,
I write to express my appreciation, and that of the National Council on Disability, for the work the National Highway Traffic Safety Administration (NHTSA) is doing to improve accessibility. I particularly note NHTSA’s recent publication of the Supplemental Notice of Proposed Rulemaking: “Make Inoperative Exemptions; Vehicle Modifications to Accommodate People with Disabilities” [49 CFR Part 595, Docket No. NHTSA-2016-0031, RIN 2127-AL67, 85 FR 84281, Document Number: 2020-28648]. This rule would be an incremental but important step forward for drivers who use wheelchairs or otherwise rely on hand controls to operate a car or truck. I will go further than endorsing the rule, however. I would like to ask you to please consider an interim final rule or other step to make the language in this SNPRM immediately effective.
With the COVID-19 situation having reduced the availability and desirability of transit services, it is even more important that driving be an alternative option for persons with disabilities. The actions your agency proposes seem like common sense moves to help improve safety and accessibility, but particularly so during these challenging times.
While notice and comment processes are justifiably deliberative in the time they take to complete, in this case, it makes sense to act right away on an interim basis while the rule is finalized. This will serve both the safety of the driving public and improved accessibility to driving options for persons with disabilities.
Thank you for your attention.