NCD letter to DOT OCR on WAV ground transportation

Mr. Sean Clayton
Acting Deputy Director
Departmental Office of Civil Rights
U.S. Department of Transportation, DOCR (S-30)
1200 New Jersey Avenue, SE
Washington, DC 20590

June 10, 2026

Dear Mr. Clayton:

I write on behalf of the National Council on Disability (NCD), an independent federal agency that advises the President, Congress, and other federal agencies on disability policy, to request a meeting with you to share findings from our recent report on the current state of ground transportation for people with mobility disabilities, particularly wheelchair users, and the recommendations specific to the Department of Transportation’s Office of Civil Rights. ¹

In our report, NCD found that wheelchair users and others with mobility disabilities are significantly disadvantaged in accessing the most common ground transportation options used by most Americans because of a widespread lack of wheelchair-accessible vehicles (WAVs) nationwide. This lack of transportation impedes or prevents community participation, can make employment and educational opportunities impossible, prevents access to necessary health care, and contributes to poverty and isolation. In this letter, I bring to your attention our specific concerns about the lack of WAVs in ride-hailing services and in emerging autonomous vehicle fleets.

Ride-Hailing

Despite the exponential growth of ride-hailing apps, wheelchair users have not benefited from this common mode of transportation that has benefited others. In fact, this population continues to be left behind, even as technology advances and the need for accessible vehicles is increasing due to the burgeoning senior population. Companies such as Uber and Lyft now control 80 percent or more of the ground transportation market, but people who need WAVs have starkly unequal access to these popular and convenient services, which provide WAVs in only about ten U.S. cities. This leaves millions of wheelchair users in communities across the nation without access while these services become larger and more available to the general public. As a result, wheelchair users remain largely relegated to options like outdated paratransit models, where 24-hour advance reservations are required and a trip can take hours to complete, or to fixed-route buses, which can make even short trips hours long and do not reach all needed destinations. These options are not suitable for many wheelchair users who, like anyone else, want access to transportation when they need it, from door to door, to suit their personal schedules and unexpected needs.

Autonomous Taxis

NCD’s report also examined the autonomous vehicle (AV) industry, highlighting the potential of AV technology to address transportation challenges for many people with disabilities. To serve as that solution, however, AVs must include accessibility features, including wheelchair access. A recent study cited in our report found that accessible AVs could generate $416 billion in additional income, increase U.S. gross domestic product by $867 billion, boost economic output by $1.6 trillion, and yield $92 billion in additional federal tax revenue. Unfortunately, to date, the needs of wheelchair users are not being addressed as AVs advance. The businesses that currently provide rides in fully autonomous robotaxis use small vehicles and offer no wheelchair accessible autonomous options. None of the AV businesses we interviewed for the report had plans to design or manufacture an autonomous WAV. We are concerned that the imminent rise in autonomous taxis without models physically accessible to wheelchair users will result in the same lack of access as the largely inaccessible ride-hail model.

ADA Regulations

The Office of Civil Rights can play an essential role in improving transportation options for people with disabilities by requiring WAVs in ride-hailing services and in emerging AV fleets.

NCD found that the insufficient availability of WAVs in taxis, ride-hailing services, and emerging AV fleets stems from a lack of regulations that require WAVs. The Americans with Disabilities Act (ADA) regulations do not require taxi services to have WAVs. The Preamble to the ADA transportation regulation puts it simply:

Under the ADA, private entities primarily engaged in transporting people and providing demand-responsive service are not required to buy accessible automobiles. Such entities are required to purchase accessible vans unless they can demonstrate that they provide equivalent service. But nothing in the statute requires an entity to acquire a van; if a taxi company acquires only automobiles, it need never obtain an accessible vehicle. ²

In addition, the ride-hail model was created decades after the ADA’s passage, which is why the ADA regulation currently contains no accessibility requirements pertaining to ride-hail. The lack of regulation requiring taxis and ride-hail services to provide WAVs has created a ground transportation system that literally leaves millions of people out. Their opportunities are significantly limited by the inability to travel. They have been left behind while the general public reaps the benefits of on-demand transportation available in most communities 24 hours a day.

To hear about the real-life experiences and impacts of a lack of WAVs on wheelchair users, NCD hosted a panel in August 2025 in Washington, DC. Attached is a transcript of a portion of that panel featuring compelling testimony from two individuals with extensive experience in wheelchair accessible transportation issues – John Morris, a wheelchair user who travels extensively and is the owner of wheelchairtravel.org, and Heather Ansley, Chief Policy Officer at Paralyzed Veterans of America. I encourage you to read this excerpt to gain a better understanding of what wheelchair users across the nation experience daily and the gravity of this problem. Based on the findings in our report, NCD recommends that the Office of Civil Rights: • Amend its ADA regulation or issue a new regulation requiring taxi services, transportation network companies (ride-hail), and autonomous taxi services to maintain a percentage of WAVs in service and available in each locality where they operate.

• Issue a rule requiring companies that provide autonomous taxis to ensure that a certain percentage of their fleets are both autonomous and wheelchair accessible. This could be accomplished by manufacturing their own purpose-built autonomous WAVs, by leasing or purchasing autonomous WAVs, or by contracting with third-party autonomous WAV companies.

I would appreciate the opportunity to meet with you to discuss NCD’s report and our recommendations, and to ultimately arrange a briefing for your team to dive further into our research and policy advice. Your staff can reach NCD’s General Counsel and Director of Policy, Joan Durocher, at (202) 272-2004 or at jdurocher@ncd.gov to arrange a time that is convenient. Respectfully,

Neil Romano
Acting Chairman

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UNEDITED REALTIME FILE EXCERPT

National Council on Disability

Quarterly Meeting

August 28, 2025

9:30 a.m. – 4:00 p.m. ET

This is in a rough-draft format. Communication Access Realtime Translation (CART) is provided in order to facilitate communication accessibility and may not be a totally verbatim record of the proceedings * * * * *

ANA TORRES-DAVIS: So to begin today, it’s really important for us to set the stage so that we can understand what it looks like to try to travel in a wheelchair in 2025. 35 years after the passage of the Americans with Disabilities Act, our first two speakers have much to offer on this topic. Let’s begin.

John. John Morris is an accessibility consultant and founder of wheelchairtravel.org. John travels and he travels a lot. He blogs about his experiences traveling in a wheelchair, from taxis to hotel shuttles, and more. John, welcome and thank you for traveling to be with us at NCD today. And the floor is yours.

JOHN MORRIS: Well, thank you very much, Ana, and to the entire board for your invitation to be here today. Congratulations on the publication of your report. I think it is going to bring about hopefully tremendous results in the space of promoting accessible transportation across the country.

As Ana said, I’m John Morris. I’m the founder of wheelchairtravel.org, which is a website dedicated to sharing information and resources for disabled travelers to be able to make the most of their travel experiences both here in the United States and abroad.

I do travel frequently. I am often on multiple flights a week, traveling to cities all across the country and around the world. And so through those travels, I have gained a broad perspective on the accessibility of ground transportation in communities from sea to shining sea.

I have not always been disabled. I had a car accident in 2012 that led me to become a wheelchair user. And I was told by many that I would not be able to travel because of the inaccessibility of the world and the condition associated with my own disability. I’m a triple amputee and power wheelchair user.

But my belief at that time was that my experience should be no different from the experience that I had had as a nondisabled person. I adopted sort of a slogan that maybe is a demand for the world, that we should have equal access everywhere, and that everyone should be able to maximize their independence to the highest level of their ability and participate in everything that society offers.

I would first like to talk today about my view of what the current state of ground transportation is for wheelchair users. Some things that really stand out to me particularly in relation to this report are the fact that there are major U.S. cities and airports in this country – major cities – without accessible ground transportation provided by private companies. Some examples, a city that I just came from, Atlanta, Georgia. There are no wheelchair taxis. There had been a couple vehicles prior to the pandemic in the city, but that is no longer the case. Dallas/Fort Worth. That’s a major airport and a city where I cannot access accessible ground transportation. My own hometown of St. Louis, Missouri, and Tampa, Florida, is one where the number of wheelchair taxis has dwindled significantly.

There are even more secondary airports without accessible ground transportation, including state capitals: Tallahassee, Florida, being one example, where my alma mater is located and where I am going this weekend to hopefully see a Florida State victory over Alabama. Am I allowed to say that?

But I think that that last point, the purpose of my travel, is varied. I travel for business. I travel for personal reasons. And I believe that I should have an opportunity to do all of those things and to have an accessible way to get around regardless of the city where I am in.

I think some of the challenges were very well outlined in the report. Some of the things that I notice is that where accessible taxis do exist, their schedules are often pegged to the hours at a doctor’s office and not the hours of life. And as we know in the society in which we live, life is a 24/7 thing.

I have noticed in my research and through the data that I have collected from my own travels that there are the majority of cities where accessible transportation is just not possible. If my flight is delayed and I arrive after public transportation has concluded, for instance, in my own home city of St. Louis, I will have to spend the night at the airport. And not only will I have to spend the night at the airport, even if I wanted to stay at an airport hotel, there are no accessible shuttles available to take me to those hotels.

I have noticed greater than 90% noncompliance among hotels with regards to the equivalent service standards which the ADA holds them to for hotel shuttles.

The consequences of this inaccessibility are significant. Travelers are often unable to get transportation, accessible transportation, to events, flights, and so forth. I even missed my – one of my very best friend’s wedding reception because the accessible taxi that I had booked was not available, did not turn up, and there were no other alternatives.

I have had a couple of experiences where my flight has been canceled and I’ve had to spend the night at the airport because not even the airline was able to muster the resources to get me to the hotel for which they had given me a voucher.

Some other personal examples from these consequences. I once had an early flight out of Cleveland. I took a city bus to the airport and had booked an airport hotel. The airport hotel had no accessible transportation. The city had no wheelchair taxis available. And so I slept on a bench in the terminal and garage, parking garage connector, overnight. I was awoken at about 3:00 a.m. by a police officer to verify that I had a ticket to travel that day.

In Jacksonville, Florida, I did make it to a wedding reception. While public transportation was running and had reserved a taxi to pick me up, that taxi never showed up and I was very far away from my hotel. So I rolled to the nearest place from the venue where I could go and as far as my wheelchair’s battery power would allow, that was a gas station, where I spent the night.

In Fort Lauderdale I was staying in a hotel with a shuttle, a shuttle that provided service in an area around the hotel and to things like the hotel’s private beach. I had planned and spoke to the hotel in advance about my intention to take the hotel shuttle to the Amtrak station at the conclusion of my stay. They agreed to set up an alternate transportation mode because their shuttle was not accessible. It did not arrive. I missed the train. And so my only alternative was to book a flight for hundreds of dollars for the same day, and the hotel refused to reimburse my expenses and claimed no violation of the ADA.

In Louisville, a hotel shuttle was not accessible and I had to roll there on my own, which involved me crossing a bridge at night in the path of oncoming traffic. Had a police officer not received a call from a motorist, I may not have made it past the night.

In countless other cities, I have been forced to make my own way, driving my wheelchair on streets or even state highways where accessible ground transportation has not been available. This could open up another conversation which I think Heather may bring up in her presentation about the accessibility and availability of sidewalks, which are an important mode of transportation.

There is, obviously, an insufficient supply of accessible ground transportation, even in cities that have it. Once I was in Nashville, Tennessee, seeing a show at the Grand Ole Opry. And I had taken a taxi there. That taxi was supposed to pick me up but didn’t turn up after the show.

So I called for another taxi, and there was only one taxi driver operating at that time. He said that he would only pay – he would only come if I paid him $100. I refused on the grounds of my belief that that was extortion, and I decided to book a night at the hotel next to the Grand Ole Opry at a higher cost than $100 but to stand on principle.

In Los Angeles I was in a wheelchair taxi and I saw that my taxi driver had received a message: A wheelchair user had been waiting an extended period of time for a wheelchair taxi and no one had picked up his call. He made an offer to pay double the fare so that a driver would accept his call.

These are the sorts of things that are happening around the country even where accessible taxis do exist. Now, oftentimes I advise my readers to file complaints with the Department of Justice about clear ADA violations. Some years ago, before the pandemic, I supplied data points for what was a robust DOJ investigation into hotel shuttles and their inaccessibility. That investigation to me showed a lot of promise but ultimately stalled due to the pandemic and perhaps a lack of willingness on the part of DOJ leadership to follow through.

Disabled people, my readers often ask me, what is the return on the investment of the time that I will expend on filing complaints about the many ADA violations I encounter. And the challenge is in responding to that is if the DOJ will not act to prevent even a financial loss that occurs such as with that hotel in Fort Lauderdale, they passed on my complaint, if they will not act on these undeniable civil rights violations, what good are complaints? These are fair questions to ask, and yet I still encourage people to file those complaints so that there is a track record.

I would like to talk finally about the recommendations found in this report and how I think that if implemented, they could make a real difference and chip away at the inequity and inaccessibility of ground transportation in this country. Specifically, we need both new regulations to account for the innovation that is occurring in the transportation space, such as with rideshare operations and autonomous vehicle operations, and we also need enforcement of existing regulations.

As the report so aptly points out, taxi operators are not specifically required to purchase accessible vehicles, but when they do purchase vehicles that are vans or not automobiles, they are required to offer an equivalent service to disabled people. That equivalent service, so far as I can tell, with the exception of a few cities in this country, does not exist, and more than 90% of hotels, it does not exist.

We need enforcement of these regulations. I would encourage the Department of Justice to continue forthwith the investigation into hotel shuttles, because I believe these are critical steps that should be taken to improve accessibility and the experience of disabled people.

With respect to new regulations, I think that they should end loop holes in the requirements for purchasing accessible vehicles. I would encourage the Access Board, the DOT, to mandate wheelchair-accessible vehicles from the very first vehicle as a condition of providing transportation services in this country.

For shuttles, we need to enforce the existing ADA standards which are significantly more clear than with taxis. Hotel operators, if they provide a shuttle, must serve disabled people. There is no question about that. An equivalent service is required only in the sense that if a hotel operator or any other public entity, other private business, if they are providing a shuttle service and do not purchase an accessible vehicle outright, then their alternative must be equivalent.

I specifically believe, though, that the NCD’s most important recommendation is an engagement with state legislatures, which like in the case of the state of Florida, have retained all policy making authority on TNCs and rideshare. That has served as a firewall against local regulation for wheelchair-accessible vehicles. Many cities around the country, we’ve seen them step up and say to Uber and Lyft and other operators of the like that if you are going to operate here, you must provide service to wheelchair users. That is not the case in states that have preempted local authority on regulation of transportation services. Florida is a great example. I used to live there. There’s not a single wheelchair-accessible vehicle operated by Uber, Lyft, or other rideshare operators.

And I think another example, it’s not in my remarks that I had prepared but I experienced just earlier this week in Atlanta, Georgia, we may have heard of the autonomous vehicle company Waymo which operates in San Francisco and Phoenix. I’ve used Waymo in San Francisco. The company doesn’t have a wheelchair-accessible autonomous vehicle, but they do provide a relatively equivalent service to wheelchair users with a driver-operated wheelchair-accessible van. However, their operation in Atlanta provides no such accommodation; only the autonomous vehicles which are inaccessible are available. As I was outside my hotel plotting my journey on public transportation to a conference I recently attended, I saw three or four Waymo vehicles pass by, and there’s not a single wheelchair taxi in the city of Atlanta. So this is the real impact of regulation falling behind innovation in this country.

I think maybe as a final statement I will say that I recently moved from the city of Boston, which has wheelchair-accessible vehicles and not only the traditional taxi completes but in Uber and Lyft, and I was able to get around very well in that city.

I moved to St. Louis, and that is now a city where sometimes if my flight is delayed, I have to spend the night in the airport even though I have a home to go to.

This cannot be acceptable in our country. We can do better, with thoughtful policy and regulation. And I hope and pray that NCD’s report will be taken seriously by government agencies responsible for setting policy and legislation to guide accessible design and infrastructure.

If these policy recommendations are enacted, I am confident that we will create a more accessible and more equitable world that allows people to enjoy equal access – maybe not everywhere, but in more places than we currently do – and to help people truly open their world as they enact, interact with society at large. Thank you very much.

ANA TORRES-DAVIS: Thank you so very much, John. Everything you said was so much of what we have learned, what we have experienced, and we really appreciate your coming and your contributions to this and to the national conversation that we’re having right now.

JOHN MORRIS: Thank you, Ana.

ANA TORRES-DAVIS: Our next panelist is Heather Ansley, the chief policy officer for PVA, or Paralyzed Veterans of America. Heather’s years at PVA have given her a close up and personal view of what the state of ground transportation is for wheelchair users. From PVA events, to work travel with colleagues, to PVA’s advocacy efforts, Heather is an important contributor to the national conversation as well. Welcome, Heather. I’ll turn it over to you.

HEATHER ANSLEY: Thank you, Ana. Good morning.

And good morning to the committee. Thank you for the opportunity to be here to discuss this important issue. As you mentioned, I am with the Paralyzed Veterans of America or PVA. We are a congressionally-chartered nonprofit veteran service organization. We started nearly 80 years ago by paralyzed veterans who were returning from WW II ready to live with their injuries and illnesses thanks to medical advancements, but they discovered a world that was not ready for them and decided to form an organization that would fight for the care, benefits, and the rights that they had earned through their service to our nation.

Today, our organization has approximately 16,000 members across 33 chapters in the continental U.S. and Puerto Rico. All of our members are veterans with spinal cord injuries or disorders such as ALS or MS, and the vast majority use wheelchairs, scooters, or other assistive devices for mobility.

As an organization, we provide free assistance in helping veterans obtain their benefits and care from the Department of Veterans Affairs, and we also work to break down barriers that prevent people with disabilities from living full lives in their community, and that’s the work that we do more broadly on transportation that brings us here today.

So as John has so eloquently already stated, a major barrier that we hear from our members – and other individuals with mobility disabilities – is the lack of wheelchair-accessible transportation options. And this includes every form of transportation, from sidewalks that are broken up, inaccessible, don’t exist, all the way to developments in things like autonomous vehicles and advanced air mobility that is going to whisk people from airports to city centers, don’t include the needs of wheelchair users.

Those are so – as we look at some of these exciting new opportunities coming online and are emerging, many wheelchair users, particularly those who use power chairs or who are simply unable to transfer from a manual wheelchair don’t have that level of accessibility.

As I said, problems include not just barriers with things like sidewalks but also the lack of accessible taxis and rideshare vehicles all the way to buses with lifts that don’t work, inefficient and unsafe ways to try to access rail or subway stations, elevators are out or don’t exist, low-level boarding, lots of opportunities.

And what happens is we see people with disabilities often drive great distances because of the lack of accessible transportation. They want to know that they have their vehicle and they have a way to get around wherever it is that they’re going, even if that means driving from Maine to California, which some of our members do, to participate in our events.

Recently I had the opportunity to speak with several PVA members who use wheelchair for mobility. I just got back from our healthcare conference yesterday in New Orleans and took the opportunity to talk to some of our leaders who were there. As you can expect, when I open the conversation, everybody had – they didn’t have a story; they had multiple stories.

THEO BRADDY: Yes.

HEATHER ANSLEY: Can I get an amen from Theo.

[Laughter]

So it was the opportunity to really get that feedback on the state of ground transportation for wheelchair users in America. So for example, our Senior Vice President, she uses a power wheelchair. She was the first to tell me about an experience she had trying to rent an accessible van for a business trip earlier this year. She knew there were two companies in this large metropolitan area on the west coast that rented accessible vehicles, and she called the first one. She was going to arrive on the weekend, and they said, well, we don’t work weekends and we don’t deliver vehicles to the airport. She said, what if I change my travel time; maybe I’ll come in on Monday. They said, well, we also don’t pick up customers who are renting vehicles; you have to call another company to get yourself to where we are to get your vehicle.

So then she’s like, okay, thanks.

Called the other company. And they were willing to deliver a vehicle to the airport and on the weekend. Nearly $200 just to deliver the vehicle. Over $100 a day for the rental. There’s also many times mileage. A rental car, good old standard compact car, you can drive that thing anywhere you want. Not the case with the accessible vehicle. For many folks that is cost prohibitive because that also doesn’t incur the parking fees and so forth for the rest of the week as you’re traveling around.

Our Chief Operating Officer who travels extensively uses a manual wheelchair, and he relayed a situation that happened just a few weeks ago. He was trying to attend a business dinner with some outside partners. He said he called every number he could find for a wheelchair-accessible ride, taxis, in this, again, large metropolitan area in a Midwest city.

Because the dinner event was associated with a larger PVA event, he finally just gave up and called our colleague who we normally have come along with the accessible vehicle and said, I’m sorry to impose after hours but can you take me.

And he’s like, it frustrated him that he had to do that. It frustrated him that he couldn’t figure out on his own how to get to a business dinner that he was more than capable of traveling to independently, simply because there was no transportation available.

He also relayed numerous problems that he had in attempting to rent a vehicle with hand controls. He’s been told that he shows up and that his car with hand controls has been rented to another customer. He always wonders how that’s going to work. He’s been told that his reservation can’t be guaranteed because they can’t guarantee there will be an accessible vehicle. And it’s very limited in the types of vehicles that are even available to rent that rental companies will install hand controls then. And of course none of this is just I show up and do it. I’ve had to tell them in advance that I’m coming. They also don’t install hand controls on the weekends. I guess people with disabilities don’t travel on the weekends so we don’t have that option.

Another example that’s personal to me, one time I flew with a colleague of mine from Washington, D.C., all the way out to San Diego. Or, I’m sorry, San Francisco. So excited. Never been to San Francisco.

After getting there, we were assured that the airport hotel shuttle was accessible, so we went out to wait for it. Thank goodness, it was San Francisco, weather was nice.

First shuttle approaches. Is this accessible?

Oh, no, but the next one.

So we waited an additional 30 minutes. Oh, no, it wasn’t accessible either.

So we called the hotel to find out the accessible shuttle was broken. Which led to our next odyssey of trying to find a wheelchair-accessible vehicle we could find. No such luck. So then we ended up in the regular taxi line. Many of the taxis were SUVs. My colleague, who uses a manual wheelchair, can’t transfer into an SUV; he can only transfer into certain types of vehicles.

We finally found one of those vehicles. It took us hours to get off the airport property to go one mile to the hotel who then when we arrived told us that they had a shuttle that could take us to the accessible transit, the BART, the transit station, to which we had to remind them that the accessible shuttle was broken so we would not be taking it over there.

Now, my colleague who uses a manual wheelchair for over 40 years was resigned to being left at the curb. He’s like, I’m left waiting. I’m just used to it. Whereas I was like, what do you mean? We can’t get off this airport property. We could have flown there faster.

We had an event earlier this year, to echo what John was saying, flight canceled late at night, we won’t get into the issues with the air travel, but once the flight got canceled at 1:00 a.m., those with power wheelchairs couldn’t transfer to the baggage area. They had no way off the airport property. It’s just unacceptable in the year 2025. So again, that’s why many of our members who have accessible vehicles choose to drive. Our national President who uses a power wheelchair told me that it’s just too much trouble otherwise.

Other times individuals who have like a manual wheelchair and a power wheelchair will travel with their manual chair even if it’s not the best option for their mobility because it increases their transportation options. It’s also why wheelchair users sometimes resist moving to a power chair because it just severely limits their options for travel.

So it’s really hard to narrow down, you know, what are some of the greatest areas of need as there are just quite frankly so many transportation barriers that continue to make life difficult not only for people with disabilities, but their families, their colleagues, and their friends, anybody who is traveling with them. People with disabilities have communities with them.

And this makes it so difficult to complete every day work tasks like going to work, accessing healthcare, which I’ll talk about in a few more minutes, flying, picking up groceries, being able to take your kids to sports practices. All of the things that many of us do on a daily basis and just take for granted.

You know, mentioning healthcare, there are some particular benefits for veterans as relates to transportation I’ll talk about in a moment, but not all veterans are able to access some of those. I attended – we do site visits every year at the Spinal Cord Injury and Disorder Centers around the country. There are 25. We were in a major metropolitan area. I was on the site visit. And while we were there, we speak to doctors, social workers, cleaning staff, we talk to everybody. And every single group of people coming in, the top thing they were raising to us was the transportation problems they were having getting the veterans to care. Which while VA has some programs that can provide transportation support, many veterans have to depend on the transportation options in their community.

And so, again, particularly for veterans with power wheelchairs, these options can be limited. And just like you can be stranded when you don’t have the taxi that you reserved show up, we have veterans who contract to go pick them up to get a therapy appointment at the VA only to get a call 30 minutes before their appointment to say, oh, the transportation isn’t coming. And so now you not only didn’t get that but you’ve missed your appointment. And all of that has ripple effects.

So we really want to make sure that we’re trying to address these issues. And really the top issue, again, that people face is that they need access to whatever the main transportation options are in their community.
I grew up in a town where my great aunt, when she wanted to go do her shopping, she had to rely on an older American bus that came to town once a week to take you to the town that had the Walmart and the grocery store and be able to get your daily needs met. That was it. There is no taxi or public transportation. And that is still the case today. So you either need a personal vehicle to depend on something like that, or you do without.

Now we have you can order things online, stuff like that, but sometimes that’s also more expensive. So then that creates additional costs for people with disabilities. So that means we need access, better access, for everything from sidewalks if you have to get yourself uptown to buy whatever you need from the store there. Public transportation, rideshares, personal vehicles, whatever the predominant form of transportation.

Now if a payer is a violation of the ADA, we do try to work with the entity, address the issue, or file a complaint with the relevant jurisdiction agency. One area that we have filed complaints in in recent years is with the FAA regarding inaccessible airport properties. We chose this topic because, as John mentioned, the DOJ is quite frankly overwhelmed with ADA complaints. I’ve learned if you didn’t file a complaint, it didn’t happen, so we encourage folks to file them, but we try to look for whatever other avenues we can use. And in this case, while we were attempting to get reservations to attend a conference, we kept calling hotels. Do you have an accessible shuttle? We were trying to make our arrangements. Nope.

Well, the ADA applies to airports which regulate entities that come on to their property. Many times they have contracts with them. Well, guess what? If they’re contracting with folks who are not meeting the requirements of the ADA, the airport can be held accountable. So we filed ADA complaints against the airport with the FAA office, and we got them to take action on those complaints, and to enforce against the property by going to the airport. So sometimes we try to be creative in looking at where is the issue that’s happening and what can we do to try to resolve it.

Now, we consistently advocate on Capitol Hill to try to improve accessibility and compliance. We’ve worked in recent years in particular to try to improve access to accessible vehicles for veterans with significant disabilities. A few years ago we were able to successfully advocate for additional access to vehicle grants through the VA. Previously, the Department of Veterans Affairs, if you have a disability related to your military service and you have a disability like a spinal cord injury or ALS, one time in your life they would give you a grant to buy an accessible vehicle.

Now, still today it doesn’t meet – it doesn’t give you enough money to buy the vehicle. It’s kind of like here’s a down payment to buy a vehicle, and that grant helps with the purchase of that vehicle.

We were able to get the law changed so that now it will be if you haven’t received a grant for 30 years, you can receive an additional grant, and then in the future as we get toward the 10-year spending window, it will be every 10 years you can get a grant.

The VA does already pay for the full cost of adapting a veteran’s vehicle and will do so on a more frequent basis, so our members more likely have more access to an accessible personal vehicle than many people with disabilities.

But as I mentioned, that’s also for veterans who have their disability related to their military service. VA will provide healthcare for any veteran who is deemed what they call catastrophically disabled. That means if you have like a spinal cord injury that occurred later in life, it’s not related to your military service, they’re not going to provide you with an auto grant. They will pay to adapt your vehicle, but only so you can get in and out of it; they will not pay for you to drive it. So even if you hear a veteran sometimes has access to things, it can depend on the veteran’s status. And so this is a great benefit obviously to particularly our veterans who live in rural areas, but there are still limitations in the private vehicle market.

And one of our PVA Vice Presidents who I just spoke to tells me she sunk $20,000 into her decades’ old van because she is very limited in the type of vehicle she can access due to her height. She’s a tall woman and she has a very large power wheelchair. She hasn’t flown in years because her chair was damaged and she was injured the last time she tried. She told me that even though she will soon be able to access her second grant from the VA, she’s only been able to find one van that will allow her to sit in the passenger space of her vehicle next to her spouse. And our Vice President has no ability to use her limbs, so having someone next to her who can assist her is very important to her. She also wants to be able to sit next to her spouse when they’re driving, not, you know, back in the back. And the only option that she’s been able to find that would allow that won’t allow them to tow the trailer of equipment that she needs to travel for the work of the organization. That’s why she spent money on rehabbing her decades’ old van. And she is very frustrated that she effectively has no choice in the private vehicle market because of her disability. So she’s actually working with her medical professionals to see if she can reduce her wheelchair height by I believe it was an inch and something, something minute, because it would give her more options.

So I throw that in there just to say sometimes even if you have the ability to access vehicle equipment, her disability is related to her military service, she has had a lot of difficulty navigating that.

In addition to our work with the VA, we are also interested in improvements that can be made through the next service transportation reauthorization bill. This legislation addresses transportation options from highways to buses to trains to sidewalks. Last reauthorized in 2021. And we’re really fighting for dedicated funding in that next reauthorization to remove barriers including sidewalks, curb cuts, crosswalks, other modes of travel, because really most modes of travel are related; they’re all interconnected.

That includes, again, trying to get funding for communities related to sidewalks that often have decades’ long waits to try to be able to get all parts of sidewalks and curb cuts to looking at extending programs that would make fixed guideway public transportation systems more accessible.

We also support legislation that would improve access to paratransit and help communities identify gaps in accessible transportation.

We also weighed in on accessible transportation not only with filing complaints or trying to work on Capitol Hill, but we have been active in the courts. We did join two amicus briefs class actions against Lyft in New York for their failure to provide services, and I know Sabrina will talk more about that case.

Travel remains difficult for many wheelchair users, difficult and expensive for many wheelchair users, 35 years after the passage of the Americans with Disabilities Act. There’s still far too many barriers in travel, and people with wheelchairs in particular are not being included in the development of new transportation forms, whether that’s autonomous vehicles or, like I said, advanced air mobility which is the next thing happening in the air. And we must address this gap in order to ensure that people with mobility disabilities are not left depending on just a few forms of transportation to be able to navigate when many other people have an ever-growing number of ways that they can navigate their community.

Some of the recommendations in the report that really spoke to me in terms of the work that we do are asking that Congress would pass legislation to require all transportation network companies, taxi companies, and companies that deploy robotaxis to provide and maintain an active percentage of wheelchair-accessible vehicles in the community. This will ensure the process isn’t piecemeal. It’s just so much work to try to figure out what are the transportation options going to be that are available. And people with disabilities shouldn’t have to do that.
I traveled to an air travel conference in Madrid, Spain, in April. And when I landed, I pulled out my app and used the same rideshare app that I use here in the U.S. and I knew when I get there, it will pull me up in Access Mode, translate it to euros, here we go, I’m off. You can’t do that in America traveling as a wheelchair user.

The other recommendations that I thought were extremely important were for the DOJ and Civil Rights Division of enforcement for equivalent services for taxis and also as it related to shuttle services that are offered by hotels or rental car companies, whoever the case may be that have this requirement. Because without the possibility of enforcement action, too many regulated entities are not going to prioritize the requirements of the law. Customer service and the right thing to do only take you so far. And the example I like to give is that if you drive a car, you’re more likely to let up on the gas if you see a police officer setting up there because you think I might get caught. Even if my best intentions are to go the speed limit, it does give me pause to double check the speedometer.

If you don’t have that in terms of the regulations you set out, well, if you don’t know there’s a stick out there, while we love carrots, human nature says it’s probably not going to be your top priority amongst all the priorities that you have to do.

So again, we thank NCD for this important report and for raising this issue. I always say, when I can go into a room of our members and just throw out a question and I am inundated with responses, that’s my crowdsourcing. This isn’t an individual, oh, that part of the country. This is everywhere in the country. And we’re grateful for the progress that has been made, but we are here today to say that much more needs to be done. Thank you.