Director, Disability Policy
United Spinal Association
November 18, 2015
Chairman Chrappah, and other distinguished members of the DC Taxicab Commission (Commission), thank you for the opportunity to offer public comment regarding accessible vehicle-for-hire service in the District. Welcome and congratulations to our new commissioners.
My name is Carol Tyson. I am the Director of Disability Policy for United Spinal Association. Founded in 1946 by paralyzed veterans, United Spinal is the largest disability-led nonprofit organization serving and representing the interests of more than a million Americans living with spinal cord injuries and disorders.
I would first like to thank the Commission, taxi companies, and operators for your continued efforts to provide accessible taxi service in the District. Ensuring access improves the quality of life for individuals, but also reflects the District’s priorities, and makes DC a better home and destination.
United Spinal commends the Commission on its successful grant program, and thanks the taxi companies and operators who have purchased vehicles, or applied for the rental or training grants. Thank you to the Commission for working to ensure disability service training is provided for all. United Spinal looks forward to working with the Commission and other stakeholders to address ongoing challenges, such as ensuring new wheelchair accessible vehicles are on the road providing service.
Regarding proposed rulemaking for the newly-created Chapter 20; thank you for assessing a fine on private sedan companies who do not comply with the zero tolerance anti-discrimination policy. Taxi drivers and companies must comply with similar anti-discrimination requirements under the DC Human Rights Act and the Americans with Disabilities Act. The fine sends a strong message to private sedan operators that discrimination will not be tolerated in the District.
Regarding the proposed rulemaking for Chapter 10 and Chapter 18 to expand the Transport DC program. United Spinal supports regulations that increase the number of wheelchair accessible taxis participating in Transport DC, and compliance with the percentage requirements for DC taxi companies. We recommend extending the provision of wheelchair accessible H-Tags to independent owner-operators as well.
It is United Spinal’s hope that taxi companies would view participating in the Transport DC program as an opportunity to provide vital transportation to a traditionally undeserved-community. Transport DC fills a large gap in service that is reflected in the ever-increasing ridership numbers each month. True demand responsive service was out of reach for many in the District until just this year. Thank you.
Section 1806.15 of the Chapter 20 rulemaking states that each trip shall be “between a MetroAccess approved location or facility in the District and another location in the District, or vice-versa.” United Spinal is concerned that the trip pick-up and drop-off location would be subject to MetroAccess rules versus allowing passengers to travel anywhere within the District. A recent academic study of MetroAccess sustainability suggested a gatekeeper approach to MetroAccess trips whereby each trip would need to be approved. United Spinal is concerned that this approach could be implemented. Transport DC passengers requesting demand responsive service in the District should be provided service to and from locations of their choosing.
Thank you for the opportunity to participate in the DCTC Accessibility Advisory Committee. As many of you know, the Committee submitted its third report on the state of accessible for-hire-vehicle service in the District and other jurisdictions. Thank you to the staff for posting the report on the Commission website. We hope, if you haven’t already, that you will take the time to read the report, most especially the first section which addresses the need for accessible service, and highlights committee members’ stories.
United Spinal thanks the Commission for its continued efforts and dedication to ensuring accessibility to vehicle-for-hire service in the District. We will continue to work in partnership with all stakeholders and advocate for an accessible fleet (both public and private) that will benefit drivers and all who visit, live in, and work in the District.