Letter to DOT on transportation recommendations

The Honorable Sean P. Duffy
U.S. Department of Transportation
1200 New Jersey Avenue, SE
Washington, DC 20590

December 8, 2025

Dear Secretary Duffy:

I write as Vice Chairman and Acting Chair of the National Council on Disability (NCD) to urge the U.S. Department of Transportation (DOT) to incentivize: 1) the development of wheelchair-accessible autonomous vehicles (AVs); 2) the development of an autonomous, universal wheelchair securement system for use in these vehicles; and 3) partnerships between AV technology companies and manufacturers for the design and manufacture of fully autonomous wheelchair-accessible vehicles and securement systems.

NCD is an independent federal agency charged with advising the President, Congress, and other federal agencies on disability policy to advance the goals of the Americans with Disabilities Act (ADA): equal opportunity, full participation, independent living, and economic self-sufficiency for people with disabilities. In July, NCD submitted a report to the President and Congress entitled, Ground Transportation for People with Mobility Disabilities 2025: Challenges and Progress.¹ This report is the product of an examination of the current state of ground transportation in the United States for people with mobility disabilities who rely on and require accessible transportation—particularly wheelchair users. The report offers extensive research findings and policy recommendations, while detailing continued barriers, challenges, and some promising innovations.

Overall, NCD found that while some progress has been made, transportation barriers remain a major concern for people with mobility disabilities across the nation. These barriers contribute to a host of negative outcomes like unemployment, poverty, inability to access health care, isolation, and diminished social participation. Wheelchair users remain a population that is often left behind, even as technology advances.

Specifically, among other findings, NCD found that as AV technology has developed, the needs of wheelchair users are not being addressed. The businesses that currently provide transportation to the public in fully autonomous taxis are using small vehicles and offer no autonomous wheelchair-accessible options. No AV business that we interviewed for the report has plans to design or manufacture an autonomous wheelchair-accessible vehicle. The imminent increase in autonomous taxis without models that are physically accessible to wheelchair users will result in the same lack of access as the largely inaccessible transportation network company model (e.g., Uber and Lyft).

Furthermore, if AV companies rely on existing, non-autonomous wheelchair-accessible vehicles provided by third parties to offer accessible transportation options, the rise of AV will result in the limited supply of wheelchair-accessible vehicles becoming even less available to people who need them. NCD’s report documents how the expansion of transportation network companies has contributed to decreased availability of wheelchair-accessible taxis. DOT can play an important role in supporting the development of wheelchair-accessible AVs so that the same pattern of innovation diminishing wheelchair users’ transportation options does not repeat itself as reliance on AVs becomes more common.

DOT can, and should, take steps to ensure that that the future of transportation is designed to include wheelchair users. As our report explains, AVs have immense potential to increase the mobility of people with disabilities. But this promise can only be fulfilled if accessibility is addressed while companies design, test, and deploy AVs instead of attempting retrofits or workarounds after the fact. DOT’s support for wheelchair-accessible AVs and autonomous wheelchair securement systems is essential to prevent wheelchair users from being excluded as AV usage expands.

NCD lauds DOT’s demonstrated commitment to the accessibility of AVs over the past ten years. For example, DOT has issued policy and guidance documents recognizing the potential of AVs to promote the independence, economic opportunity, and social well-being of people with disabilities.² DOT has also provided valuable financial resources to support innovative design solutions that make future AVs more accessible to people with disabilities.³ NCD urges DOT to continue to support the development of wheelchair-accessible AVs.

Specifically, based on the complete set of findings in our report, NCD urges DOT to:

• incentivize the development of wheelchair-accessible AVs and an autonomous, universal wheelchair securement system through competitions or other funding mechanisms.

• incentivize partnerships between AV technology companies and vehicle manufacturers for the design and manufacture of fully autonomous wheelchair-accessible vehicles and an autonomous, universal wheelchair securement system.

On December 4, NCD presented the findings and recommendations from this report at the Autonomous Vehicle Industry Association’s (AVIA) AV Summit and watched an excellent presentation by NHTSA’s Administrator, Jonathan Morrison.

I would welcome a meeting with you soon to discuss this letter and NCD’s report. You can reach me at (202) 272-2004 or via email at skennemer@ncd.gov. On December 19th, Joy Welan, Senior Attorney Advisor, will contact your office to coordinate a potential meeting if we do not hear from your office before then. If you have any questions, Ms. Welan at can be reached at jwelan@ncd.gov.

Respectfully,

David Shawn Kennemer
Vice Chairman and Acting Chair

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