February 16, 2021

Office of the Secretary of Transportation U.S. Department of Transportation 1200 New Jersey Ave, SE Washington, DC 20590

Re: Docket No. DOT-OST-2021-0004

Dear Office of the Secretary:

United Spinal Association has fully supported the U.S. Department of Transportation’s (DOT) continuing strategic planning efforts to increase access to transportation for our members and all people since its inception. To continue our support, we have joined with numerous other disability organizations to offer comments, including comments submitted by the Consortium for Citizens with Disabilities Transportation Task Force and comments submitted by Paralyzed Veterans of America in response to the Draft Strategic Plan on Accessible Transportation (Draft).

In addition, United Spinal offers the following comments, suggestions and aspirational, but certainly tangible and doable, hopes for the Draft. All we offer below can be realistically accomplished with adequate resources and a will to commit to them. Many of these, at least in part, have crystallized in the midst of a literal transportation crisis, being driven by the current COVID-19 Pandemic. It continues as a tragic, but nonetheless opportune, time from which long lasting and wide-ranging impacts need to be memorialized, further researched and applied to a robust equation to yield far greater accessibility in transportation.

In previous suggestions to DOT, United Spinal advanced the proposition that the more accessible our transportation universal, the better it works for everyone. Thus, we applaud the Draft’s statement that, “Through this strategic plan, DOT sets goals and objectives to facilitate the broad realization of accessibility in a way that improves the travel experience for all Americans, especially people with disabilities.”

Indeed, United Spinal notes that, on occasion, the Draft does take a broader, more encompassing, more inclusive approach when discussing the accessibility in terms of audiences. Draft statements like the example above and such as, “the “complete trip” concept means that all travelers, including people with disabilities, should be able to get not just curb-to-curb and door-to-door, but point-to-point,” we submit reflect the proper context for inclusion, not only for people with disabilities, but for everyone. We suggest that the next iteration consistently reflect this contextual perspective from its introduction to the conclusion.

Moreover, we strongly, respectfully request that the next iteration of the Draft consistently pursue a universal audience approach at every opportunity. For instance, we appreciate the fact that the 30th Anniversary of the Americans with Disabilities Act (ADA) was a catalyst for some sporadic recognition of the grossly inadequate progress our nation has made to achieve the goals of that landmark law. But eventualities, such as the so-called gray tsunami, as baby boomers age, and as they integrate into the disability community, should also be a wake- up call for universal accessibility within the transportation community. It is critical that the federal community

1 approach every aspect of accessibility with a simple but far-reaching premise, a barrier that taxes one of us, ultimately, costs all of us. The collective exponential costs of transportation barriers, as we have shared previously, may well be so immense they are incalculable. Suffice it to say, accessibility not only aids everyone, it has tremendous positive impacts on our environment and our economy as well.

Make no mistake, we certainly appreciate the attentiveness given to people with disabilities (PWD) from the DOT. But by placing PWD in proper context, as a key to a successful policy solution, we hope to appropriately elevate our potential contributions to transportation to maximize the high level of increased efficiency and effectiveness our engagement can help achieve. Without question, as we have offered to DOT numerous times, PWD have the experiential expertise to make a profound and lasting contribution to the transportation accessibility universe. Because of the cost effectiveness of including PWD’s accessibility expertise, DOT must include PWD in every discussion about accessibility and every discussion within DOT must address accessibility. DOT must value accessibility as an intrinsic element in any transportation improvement effort. And DOT must recognize that accessibility is inherit in the development of every evolving safer transportation outcomes.

Clearly, the Draft is still in its embryonic stage, and as such, can easily and fully benefit from a full chorus of additional stakeholder voices, so we reiterate our previous request that DOT, “cast a broad net in seeking comments from every corner of the country and beyond to enrich the Framework’s end product.”

To the above end, United Spinal echoes a request we and other disability organizations, led by the Consortium of Citizens with Disabilities Task Force, have made to Secretary Buttigieg, calling for a meeting with the Secretary and his modal administrators to discuss the shared goals of President Biden’s and his agenda, along with our priorities. We further requested that periodic meetings on some consistency occur to exchange robust ideas and potential solutions to advance our shared agendas, certainly accessibility is on the top of that agenda. Importantly the CCD Task Force letter also requested that Secretary Buttigieg adopt Senator Tammy Duckworth’s recommendation that his senior leadership team include a staff person to focus on accessibility and universal design. The staff person would ideally engage with all modal administrations and have significant experience working with the disability community.

We also repeat that, “a tried and true vehicle to assist with the above essentials, to fully developing the current Framework and to remove barriers in our nation’s transportation network is the Federal Advisory Committee. DOT should establish a general Federal Advisory Committee on Transportation Accessibility.” United Spinal’s bottom line is that a consistent reliable conduit for universal stakeholder engagement with DOT on accessibility must lie at the heart of the ultimate DOT Strategic Plan on Accessible Transportation.

We are encouraged by the examples given in the Draft in which the DOT pledges greater collaboration with the US Access Board, but respectfully, the examples given are too few and far between. DOT must take a comprehensive approach to strengthen coordinating its accessibility efforts with the tremendous knowledge base and institutional resources of the U.S. Access Board. DOT must be ever cognizant though of the Access Board’s severely limited budget and that optimal partnerships will depend upon DOT’s significantly larger and therefore more flexible budgetary resources to be committed to coordinating initiatives.

United Spinal again points out that the original purpose of the Coordinating Council on Access and Mobility (CCAM) is still a pressing need, making our national government more responsive in providing cohesive, seamless access to our transportation network. United supports including an effort to reenergize the CCAM within the Draft. As we have said previously, United Spinal firmly believes in the fundamental principle underlying the catch phrase that even DOT principals have echoed in the past, “nothing about us with without us.” We commend the DOT for including a sub section, Objective 2.5. Transportation Workforce Development. And we applaud the pledges made there; they are a good start. But, they are only a start. DOT must accelerate its own hiring of PWD and other underrepresented stakeholders in its own workforce. Transportation workforce development must be elevated in DOT’s main priorities and certainly within the four corners of the Draft. It is so central to the task before us, we recommend it constitute a guiding principle, itself.

To achieve a multifaceted transportation workforce, United Spinal continues to recommend DOT must:

• conduct a campaign to hire more PWD. • establish more university undergraduate internships, graduate and post graduate fellowships for PWD. • provide numerous opportunities for federal employees with disabilities to be detailed to specific DOT projects such as developing the current Framework. • engage the youngest PWD in virtual workshops, summer camps and development challenges to inspire their imaginations, ignite innovative thinking and lead them to careers in engineering and designing a transportation world devoid of barriers.

As we mentioned above, COVID-19 has brought to light many transportation challenges and opportunities. United Spinal appreciates the support the Draft identifies with drone delivery of goods, but surface transportation delivery must also be included in every possible aspect of accessible transportation services. Since a disproportionate share of PWD and other vulnerable populations must quarantine for health safety, DOT must support accessible transportation technologies and infrastructure associated with such delivery services to serve many of our nation’s communities in emergencies.

Industry advances with testing automated vehicle technologies continue to proliferate. United Spinal fully supports DOT’s work on automated vehicle (AV) research and the current inclusion of it in the Draft but providing a national ecosystem in which accessible AV testing can take place is paramount. The scope and potential impact of a fully developed and deployed AV industry is so great, United Spinal supports:

• a separate objective be established in the Draft to further AV safety, testing, research and design and above all, accessibility exclusively. • An AV Federal Advisory Committee.

Until Spinal wants to reiterate its support for the recommendations made by the Consortium for Citizens Transportation Task Force regarding DOT’s AV 4.0, including formation of an AV Advisory Committee with an accessibility subcommittee, and any grants funding autonomous vehicle projects requiring that people with disabilities are part of the design and testing of new technologies in order to ensure the accessibility and usability of the technology from the start.

As long as the digital divide continues to deepen and grow wider with each new generation of technology, more and more Americans will become isolated and denied access to healthcare, employment and fully contributing to our nation economy. DOT must join the fight for an America with accessible broadband with research and public information campaigns pointing to the critical need for this fundamental service that will enhance mobility. Building broadband in tandem with traditional infrastructure projects is an absolute necessity. Broadband must play a foundational role in the transportation network of this nation and most certainly within the Draft. United Spinal salutes DOT’s concept of the “complete trip.” A nation in which all travelers, including people with disabilities, are able “to get not just curb-to-curb and door-to-door, but point-to-point… spontaneously and independently, being able to navigate sidewalks, intersections, transit facilities, rail stations, vehicles, and all other parts of the transportation network with ease and confidence” is a core goal everyone should share. As such, United Spinal respectfully requests that DOT convene a series of workshops to further operationalize the complete trip concept in the next iteration of the Draft. While the Draft addresses multiple aspects of complete trips primarily through examples of existing work the DOT is conducting, a more comprehensive analysis of the concept is truly needed.

In United Spinal’s continual engagement with both the public and private sectors, we urge the development of model solutions than can then be replicated, as the Draft suggests, to be applied more broadly to the nation’s needs. Chief among the entities to focus upon are transit and pedestrian facilities as defined in the Draft and we humbly submit they are additional candidates, especially for wheelchair users, such as drop off and pickup defined areas.

This important foundation of our national infrastructure should not be viewed as static, it should evolve and grow in efficacy hand in hand with emerging technologies, building materials and energy saving technologies. Its development should prosper side by side the development of the Administration’s goal of 500,000 electric vehicle charging stations. A university transportation center committed to this topic alone could anchor a consortium of academic institutions and other stakeholders to make complete trips a reality for the American people.

Successful economic growth, creating sustainable jobs, demands smart planning, smart research and design and smart construction. Incorporating every contingency possible through designing a comprehensive infrastructure solution to tandem needs as we build back, ultimately betters the end product. DOT is at the epicenter of commanding grants to enable this tested and successful approach to public policy and infrastructure.

Future iterations of the Draft must include a timeline of realistic goals and achievable benchmarks to increase accessibility for all Americans.

For 75 years, United Spinal has sought positive change to make our national transportation system more accessible. The Office of the Secretary as well as the entire DOT should consider our members as a reliable partner in the great work before us.

Thank you for considering these comments. Please do not hesitate to contact Kent Keyser, Public Policy Fellow, with any questions at (718) 803-3782 or [email protected].

Sincerely, Alexandra Bennewith

Alexandra Bennewith, MPA Vice President, Government Relations