November 1, 2024
Christopher Kuczynski
General Counsel
United States Access Board
1331 F Street, NW, Suite 1000
Washington, DC 20004
RE: Docket No. ATBCB-2024-0001, RIN 3014-AA48
Dear Mr. Kuczynski:
The National Federation of the Blind is the premier membership and advocacy organization of blind Americans. As such, we have been the vanguard in advocating for accessible transportation options for the blind. In 2011, I participated in our Blind Driver Challenge, where I successfully drove a car that had been modified to communicate information to me nonvisually around the Daytona International Speedway road course. With the more recent advent and promulgation of fully autonomous vehicles, we have maintained our position at the forefront in advocating that these vehicles, and all aspects associated with them, be completely nonvisually accessible because the blind of the United States are likely to benefit as much, if not more, than any other group.
It is for these reasons that the National Federation of the Blind supports the Access Board’s proposed rule regarding EV charging stations. We are particularly pleased with the Access Board’s proposed approach of requiring 100 percent of EV chargers to have an accessible user interface. We are also pleased with the EV charger communication elements and features set forth in section 709, especially the provisions in sections 709.3, 709.4, and 709.5, which require high-contrast text for display screens, nonvisual status indicators for charging, and prohibiting the sole use of color coding to convey information, respectively. The inclusion of these elements in the proposed rule demonstrates an effort to ensure that blind and low-vision passengers were considered when these provisions were created.
However, we encourage the Access Board to take the provisions of section 709 further and specifically require that all elements of the charging station intended to communicate information to the user be nonvisually accessible. As previously mentioned, with the proliferation of autonomous electric vehicles, blind Americans stand to benefit more than perhaps any other group when it comes to improving independent transportation, but if we face the barrier of an inaccessible charging station, then we will be once again relegated to second class status. This cannot, and should not, be an oversight in an accessibility regulation.
If the Access Board ensures the full nonvisual accessibility of EV charging stations, then the provisions set forth in this proposed rule will benefit blind vehicle owners and passengers now, when we exit our EVs and those of our friends and family to operate those charging stations, and in the future when blind and low-vision Americans will be able to experience true transportation freedom as they traverse the nation’s highways and side streets on our own terms, without having to rely on others. As always, we appreciate the opportunity to provide feedback on the proposed rule, and we are ready to provide any assistance to the Access Board should further questions arise.
Sincerely,
Mark A. Riccobono, President
National Federation of the Blind