February 2026 Comments on NHTSA Safety Portfolio

February 25, 2026

Jonathan Morrison
Administrator
National Highway Traffic Safety Administration
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590-0001

Filed via regulations.gov

RE: Safety Research Portfolio, National Highway Traffic Safety Administration, Docket NHTSA-2025-0325

Dear Administrator Morrison:

Thank you for the opportunity to participate in the annual Safety Research Portfolio and the Automated Driving Systems (ADS) workshop. NHTSA is developing important safety research for new transportation technologies, and we strongly believe there is ample opportunity to incorporate the access and safety needs of people with disabilities into the research on an ongoing basis.

The American Foundation for the Blind (AFB) is a national nonprofit that creates equal opportunities and expands possibilities for people who are blind, have low vision, and are deafblind through advocacy, thought leadership, and strategic partnerships.

Integrating accessibility into safety evaluation and standards will allow more people to travel safely, frequently, and affordably. Currently, many people are unable to use or operate vehicles that conform to the Federal Motor Vehicle Safety Standards either because they have disability that prevents them from being able to drive or because vehicles are not built accessibly. For the most part, people who are blind cannot drive, and those who have the added experience of using a mobility device often cannot even ride in a vehicle on their own, not to mention the difficulty many people face in affording or renting an adapted vehicle. In light of these barriers using private automobiles, people with disabilities may be more likely to depend on walking or using transit than nondisabled people, yet they often face excessive accessibility and safety barriers accessing the pedestrian environment.

Autonomous vehicles have long been touted as a means of solving independent transportation for many people with disabilities who cannot drive today. However, as much as this potential exists, AVs’ effect on transportation access depends on accessible design. In a forthcoming research study, AFB found that 74% of blind and low vision survey respondents believe that AV development is important, yet only 49% of those who had used an AV found the ride to be fully accessible.¹ The most recurring accessibility challenges included difficulty finding the vehicle, lack of auditory cues, and the need for safe pick-up/drop-off, including safe places to exit. These participants described accessibility as a reason that AVs could be transformative but also a reason that AVs could fail in practice.

Notably, accessible design is safer design. If Automated Driving Systems end up being safer than human drivers, then people with disabilities will be safer when they are able to use and access AVs. If the pedestrian environment is accessible, then people who use wheelchairs will be better able to ride on the sidewalk instead of along a lane of car travel. These are just two examples of how safety and accessibility go hand in hand.

These comments raise questions around some of the research needs to get to a safer, more accessible autonomous vehicle ecosystem. However, these concerns are often relevant to the human-driven vehicle as well. If the safety standards accommodate accessibility, it may be easier for original equipment manufacturers to produce more accessible vehicles without seeking exemptions, or at a minimum, it may also ensure that the adaptive vehicle market is equipped with the knowledge to retrofit vehicles in a way that maximizes safety for occupants.

The mission of NHTSA is to create a safer roadway environment. However, the current vehicle standards do not generally take into account specific disability-related safety needs, and much of the behavioral safety programs do not address the safety perspective of pedestrians with disabilities (e.g. NHTSA’s pedestrian safety emphasizes literally ‘looking’ for and avoiding danger)². We encourage NHTSA to do more to emphasize the safety and access needs of millions of people with disabilities that limit their transportation access. Given the need for evidence to support safe interventions, NHTSA’s research program plays a crucial role in understanding, iterating on, and designing roadway, vehicle, and environmental interventions for safety and accessibility. We urge NHTSA and other agencies to conduct, invest in, and prioritize the following types of safety and accessibility related research that can improve access to autonomous vehicles.

In general, AFB urges NHTSA to adopt accessibility standards for the entire human-machine interface. As part of this objective, we encourage the agency to advance research into the appropriate amount of safety related information that should be made available to people with diverse sensory disabilities. Certain indicators and controls that are currently made available to drivers visually via FMVSS 101 should also be made available to blind passengers of AVs. While blind passengers may not, for example, need to operate the signals or understand the gas levels, it is helpful to know if a tire is suddenly flat or to know the cause of a sudden stoppage. In addition, blind passengers should still have access to interior vehicle controls. For example, requiring some tactile controls helps blind riders operate the temperature control system or quickly find the operator call button.

Relatedly, NHTSA should conduct research into promoting accessible emergency communications and responses for people with sensory disabilities, including people who are blind, have low vision, or are deafblind. Current AVs allow riders to call for assistance for any reason, but especially in the case of an emergency. We urge NHTSA to specifically consider how to communicate with people with disabilities when first responders are on site and how the vehicle, app, or company may facilitate communication in the appropriate format (e.g. deaf riders may prefer text or ASL). In addition, emergency response equipment must be accessible to people with disabilities. That means an emergency door release must be operable by someone without good hand strength, findable by a person who is blind, and understandable by someone with a cognitive disability.

Another aspect of communication that will be different in AVs is communication between the ADS driver and people outside the vehicle. We recommend that NHTSA invest in research that tests interventions for improving communication between autonomous vehicles and pedestrians. Currently, NHTSA safety information for pedestrians emphasizes making eye contact between drivers and pedestrians.³ Many blind pedestrians are already unable to use this means of communication, yet in the absence of a driver, it will be important that AVs be not only predictable around pedestrians but also capable of signaling planned or unexpected movements in an accessible way (e.g. visually and audibly).

Relatedly, another important area for research is how ADS can identify and enable safe and accessible curbside pick-ups and drop-offs that facilitate access to a final destination. Getting to an AV and finding the passenger’s destination are two of the biggest challenges for blind people using AVs currently. When using ride hail services, many people who are blind rely on human drivers to spot them and orient them to the vehicle. With ADS, people who are blind will need to have a clear understanding of where the vehicle is in relation to the curb, whether there are any obstacles between them and the curb (e.g. bike lanes or poles), and where the vehicle is relative to their location or destination. It is not uncommon for current AVs to pull up to a curb but, in doing so, find a parking spot that is far from the destination. This situation requires a tricky balance between easy navigation and safe exit from or entry into the vehicle. While there may be no single answer, it is worth having all entities involved in AV safety and accessibility consider how to address the complicated balance. Since solutions may range from curb-use policy and better curb mapping to programming ADS to respond to user directions and preferences, various agencies at USDOT, local transportation agencies, and AV companies themselves will need to be thoughtful in helping develop an approach that is inclusive of blind AV users.

To ensure that AVs expand transportation access to the whole disability community, NHTSA must continue to fund and conduct research that furthers the safe design and development of autonomous, independent wheelchair or mobility device securement and restrain systems. Such research is vital to ensure that people who cannot transfer from a chair or lift their wheelchair into a vehicle themselves can use autonomous transportation. This research should inform the development of FMVSS rules and incentivize AV manufacturers to develop accessible designs with clear regulatory directions for implementing these features safely. In addition, it is worth noting that there is a similar desire to have independent wheelchair securement on airplanes and advance air mobility, so this research could dramatically improve transportation access for people who use wheelchairs across multiple modes.

Finally, we urge NHTSA to continue to develop test measures and rules for Automatic Emergency Braking, forward collision warnings, and other advanced crash avoidance technologies that accurately detect and safely respond to pedestrians with disabilities, including wheelchair users. We also noted the research presented to improve test methods for understanding ADS safety around pedestrians. We encourage NHTSA to always include people with diverse disabilities in the test procedures whether they are physical or simulated. With simulated research, it should be relatively easy to vary the size, appearance, and behavior of test pedestrians with different disabilities. We greatly appreciate the current pedestrian crash avoidance research that has been done in this space and encourage the agency to continue it for the safety of all people with disabilities.

Again, we appreciate the foundational work that is underway to bring ADS safety testing and regulatory needs to maturity. We hope you will always think of ways that this research can better include the millions of people with disabilities who rely on America’s roadways. If you have any questions about this issue, please contact Sarah Malaier, smalaier@afb.org.

Sincerely,

Stephanie Enyart
Chief Public Policy and Research Officer

Footnotes

¹ Silverman, A. M., Whistler, A. L., Shock, A., & Heydarian, C. H. (2026). The AI Quagmire: Benefits, Risks, and User Aspirations Through a Disability Lens. American Foundation for the Blind. [Unpublished] Results will be published in March 2026 at www.afb.org/AIresearch.

² NHTSA (undated). Pedestrians. https://www.nhtsa.gov/road-safety/pedestrian-safety

³ Id. “Some drivers may be distracted. Do not step into the roadway until the driver has stopped. If you can’t see the driver, the driver can’t see you — wait until you can make eye contact and the driver has stopped the car.”