In a letter to Assistant Attorney General Clarke, the National Campaign for Transit Justice and transit groups from across the country called on the Department of Justice to adopt the Accessibility Guidelines for Pedestrian Facilities in the Public Right-of-Way (PROWAG).
The full text of the letter can be found below.
Dear Assistant Attorney General Clarke:
We write to you today to urge you to adopt the Accessibility Guidelines for Pedestrian Facilities in the Public Right-of-Way (PROWAG), which was finalized last year by the Architectural and Transportation Barriers and Compliance Board (Access Board). PROWAG does not become an enforceable standard until adopted by the Department of Justice (DOJ) and the Department of Transportation (DOT). The proposed DOT adoption of PROWAG represents a meaningful step forward to improve accessibility in the public space and to provide an accountability framework. To ensure that all facilities in the public right-of-way are accessible to those with disabilities, DOJ should act quickly to adopt PROWAG into its own regulations.
PROWAG’s standards are imperative for equitable access to mobility. All travelers deserve to safely and efficiently navigate their communities, yet too often, people with disabilities are prevented from reaching schools, shops, employment, healthcare, places of worship, and other destinations by inaccessible roads and sidewalks. Now, more than 30 years after passage of the Americans with Disabilities Act, the government must no longer delay taking action.
Enacting improvements to increase the accessibility of our transportation system is fundamental. Everyone in the United States must be able to navigate their communities safely in order to access the resources they need. As it stands, PROWAG adoption solely by the DOT limits enforcement to transit stops and shelters. While important, transit stops are only one component of transportation facilities. Roads, sidewalks, crosswalks, roundabouts, paths, and other features of the public right-of-way must also be addressed. We highly encourage the Department of Justice to also adopt PROWAG to ensure equity in accessibility for all users in the public right of way, as is intended by the ADA.
The current rendition of the Access Board’s PROWAG has been more than 30 years in the making, but even then it has its flaws. Changes in mobility technologies are not fully accounted for, nor are the full breadth and depth of disabilities that impact mobility. However, there is an urgent need to establish a baseline standard of streetscape accessibility from which to improve upon, which is why PROWAG should be adopted into DOJ’s regulations immediately.
We further urge you to coordinate with DOT to ensure that the regulatory framework on accessibility is clear and easily understood by policymakers, designers, and disability stakeholders. This will secure the ability for these partners to have a seat at the table for future renditions of PROWAG and other guiding documents which can continually improve the state of transportation accessibility around the nation.
In addition to the adoption of PROWAG in full, we urge you to:
- Coordinate with respective federal agencies for their guidance and faithful implementation of PROWAG standards
- Support USDOT and the US Access Board’s research and meaningful stakeholder engagement to solicit improvements to PROWAG that account for today and tomorrow’s mobility environment and the breadth and depth of disability community needs; and
- Regularly adopt updated PROWAG regulations, following a similar cycle to the Manual on Uniform Traffic Control Devices’ (MUTCD) 4-year update.
Accessible transportation networks are vital to the health, economic development, sustainability, and equity of our nation’s communities. That cannot be achieved without the enshrinement of nationally recognized accessibility guidance, such as PROWAG.
We cannot afford to wait any longer. Now is the time to ensure that all Americans have access to the transportation networks they deserve.
Sincerely,
Transportation for America
Alliance for a Just Society
America Walks
League of American Bicyclists
League of Conservation Voters (LCV)
National Association of City Transportation Officials (NACTO) 1000 Friends of Oregon
1000 Friends of Wisconsin
ACT-LA
Active Prince William
Aging and Disability Transportation Network Albuquerque Transit Riders Union
Autistic Women & Nonbinary Network
Better Eugene-Springfield Transportation (BEST) BetterTransitNOW (Baltimore)
Bike Durham
BikeLA
Boston Center for Independent Living
CALIF-ILC
California IHSS Consumer Alliance (CICA)
CASE Citizens Alliance for a Sustainable Englewood Cedar Lane UU Environmental Justice Ministry Center for Independent Living
Center for Neighborhood Technology (CNT)
Central Maryland Transportation Alliance
Circulate San Diego
Coalition for Economic Justice
CultureHouse
DC Transportation Equity Network
Democracy for America Advocacy Fund
Denver Streets Partnership
Detroit Greenways Coalition
Disability Rights California
Disability Rights Education & Defense Fund Disability Rights Maryland
Downtown Residents Advocacy Network (Baltimore) Elevator Action Group (Rise and Resist)
Elmont Cultural Center
Farm&City
GreenLatinos
Grow Smart RI
Health by Design
HollywoodDemocrats.com PAC
In the Public Interest
Independent Living Center of Hudson Valley Institute for Policy Studies Climate Policy Program International Parking & Mobility Institute (IPMI) LABAC
Labor Network for Sustainability
LivableStreets Alliance
Los Angeles Walks
Madison Area Bus Advocates
Maine People’s Alliance
Malone Complete Streets Advisory Board
Marin Center for Independent Living
Massachusetts Action for Justice
Metropolitan Planning Council
Move LA
Move Minnesota
Move Redmond
New York Communities for Change
Office of Council Member Jenny Brekhus, Reno NV Paralyzed Veterans of America
Pathway to Wellness Counseling Center Pittsburghers for Public Transit
Progressive Leadership Alliance of Nevada
Public Advocates
Reconnect Rochester
Riders Action Council
Riders Alliance
Safe Pass Ulster
Safety Accessibility Advocates
Seamless Bay Area
Self-Initiated Living Options, Inc.
Shenandoah Valley Bicycle Coalition
Southwest Energy Efficiency Project
Streets Are For Everyone
Streets For All
Sustain Charlotte
Syracuse United Neighbors (SUN)
TakeItBack.Org
Tampa Downtown PartnershipThe Funders Network
The League of American Bicyclists The Street Trust
The Transit Coalition
Third Act Maine
Together for Brothers
Transbay Coalition
Transform
Transit Alliance Miami
Transit Alliance of Middle Tennessee Transit Forward Philadelphia TransitMatters
Transportation Choices Coalition Transportation for Massachusetts Union of Concerned Scientists
Unite North Metro Denver
United Spinal Association
WakeUp Wake County
Walk Bike Nashville