[NFBOH-Cleveland] From President's, Riccobono's Desk

Tue Apr 21 14:19:31 UTC 2026

>From the President's Desk

>From the Editor: The following are recent letters that President Riccobono
sent to key senators and to the administrator of the Office of Information
and Regulatory Affairs (OIRA), an executive agency. The first letter urges
Senate action to advance legislation that would establish a national
framework for the advancement of autonomous vehicle technology, including
important nondiscrimination and accessibility provisions. The second seeks
to protect the integrity of the forthcoming regulations applying Title II of
the Americans with Disabilities Act to websites operated by state and local
government entities, including K-12 school systems and institutions of
higher education. OIRA has issued an announcement that, while vague, signals
that it may delay, amend, or otherwise undermine the new regulations which,
as the letter documents, were well over a decade in the making. Here are the
letters:

February 2, 2026

The Honorable Ted Cruz 
Chair
Senate Committee on Commerce, Science, and Transportation
167 Russell Senate Office Building
Washington, DC 20510

The Honorable Maria Cantwell 
Ranking Member
Senate Committee on Commerce, Science, and Transportation
511 Hart Senate Office Building
Washington, DC 20510 

Dear Chairman Cruz and Ranking Member Cantwell:

The National Federation of the Blind is the nation's transformative
membership organization of blind people. We advance opportunity, equality,
and independence for our members and all blind Americans. We write to ask
the Senate Committee on Commerce, Science, and Transportation to include an
urgently needed national autonomous vehicle framework in the Surface
Transportation Reauthorization Act.

You have a truly historic opportunity to expand transportation access for
seven million blind and low-vision Americans and millions more with
travel-limiting disabilities. The blind community, the autonomous vehicle
industry, and the public need congressional leadership to establish a clear
federal framework for this pivotal technology.

Many members of the National Federation of the Blind's state affiliates and
local chapters across the country have ridden in SAE Level 4 fully
autonomous vehicles, including those functioning with the technology
spearheaded by Waymo in the states where the service commercially operates
today.

For blind Americans, fully autonomous vehicles can provide a convenient,
private, flexible, reliable, and discrimination-free transportation option
that supports access to work, education, and community engagement. However,
the autonomous vehicle industry needs regulatory certainty and a framework
within which to expand. A national autonomous vehicle framework would create
a necessary baseline for this technology, ensuring innovation continues to
move forward.

Congress faces a watershed moment. The United States must lead globally in
autonomous transportation policy rather than allowing other nations to
define the future of this technology. We urge the committee to seize this
bipartisan opportunity to demonstrate American leadership while expanding
transportation access for all.

As you develop this framework, we ask that you explicitly protect the civil
rights of blind people by including a provision that prohibits requiring a
driver's license-for any human operator-to hail or use a fully autonomous
vehicle. This protection is reflected in the AV Accessibility Act (H.R.
4419), introduced in the United States House of Representatives, and is
essential to ensuring that blind people can benefit from this technology on
equal terms.

For more than eighty-five years, the National Federation of the Blind has
worked collaboratively with Congress to ensure that the lived experience of
blind people informs public policy. We are positioned to continue that
partnership and eager to work with you to develop a national autonomous
vehicle framework that will shape transportation access and independence for
generations to come.

Sincerely,

Mark A. Riccobono, President
National Federation of the Blind

March 5, 2026

Mark Paoletta
Administrator 
Office of Information and Regulatory Affairs 
New Executive Office Building
725 17th Street, NW 
Washington, DC 20503

RE: Nondiscrimination on the Basis of Disability; Accessibility of Web
Information and Services of State and Local Government Entities Final Rule

Dear Mr. Paoletta:

The National Federation of the Blind is the transformative membership and
advocacy organization of blind Americans. Throughout the course of our
eighty-six year history, we have sought to advance the lives of all blind
people in the United States. A major driver of that advancement during our
existence has been equal access to information, particularly digital
information. It is for this reason that we oppose any attempt to delay,
rescind, or otherwise undermine the effectiveness of the Americans with
Disabilities Act (ADA) Title II website regulation that is set to take
effect on April 24, 2026.

While reflecting a compromise between the needs of people with disabilities
and the resources of covered entities, the clarity provided by the website
regulation is important to the lives of people with disabilities, in
particular to blind students in public and higher education. Blind students
are too often excluded from the curricula their sighted peers experience
because educational materials are offered digitally through inaccessible
websites and mobile applications. As a result, they are often unable to
compete on a level playing field with their peers, are unable to benefit
fully from their education, and are delayed in attaining their degrees and
entering the workforce. The inaccessibility of educational materials is one
of the most significant barriers to blind people being able to achieve their
full potential and make their rightful contribution to American society. 

The website regulation provides exactly the clarity state and local
government institutions have been requesting regarding their obligations
under Title II of the ADA to make their websites and mobile applications
accessible. Since 1990, Title II of the ADA has required state and local
governments to ensure their communications with individuals with
disabilities are "as effective as" communications with nondisabled
individuals. Since 1996, the Department of Justice has made clear that this
obligation includes their communications via the internet and mobile
applications.

Moreover, the communications of recipients of federal funding have been
subject to that same requirement pursuant to Section 504 of the
Rehabilitation Act since 1973. In the decades since, courts and other
federal agencies have agreed, and the Department of Justice has issued
several guidance documents providing technical assistance to covered
entities. 

Yet, educational institutions and other state and local government entities
have claimed to be unclear exactly how they should comply with the "equally
effective communication" obligation. In 2024, more than thirty years after
the signing of the Americans with Disabilities Act into law, the Department
of Justice issued the website rule. Far from being a surprise to covered
entities, the Department first issued an advance notice of proposed
rulemaking ("ANPRM") in 2010, which sought information from covered entities
and individuals on what should be included in the rule. The Department
received approximately four hundred comments.

In 2016, the Department issued a supplemental ANPRM, again soliciting public
input, which received more than two hundred comments. In 2023, the
Department issued a notice of proposed rulemaking regarding website and
mobile application accessibility requirements, setting forth the
Department's proposals and including more than sixty questions for public
comment. The Department received nearly three hundred fifty comments. In
addition, the Department attended a variety of listening sessions to gather
additional input. The final rule was issued on April 24, 2024.

The final rule clarifies what is required to meet Title II's equally
effective communication requirement in the context of state and local
government websites and mobile applications. It provides a clear technical
standard based on an internationally recognized and widely adopted consensus
standard. It also provides flexibility by allowing covered entities to
achieve equivalent facilitation and preventing liability for inaccessible
elements that do not substantively affect the usability of a website or
mobile application.

Notably, the website rule also provides a series of exceptions, presumably
implemented at the behest of covered entities, establishing web and mobile
application elements and content that do not have to be made accessible.
These exceptions are not available under the pre-existing equally effective
communication requirement. Although the equally effective communication
requirement has been in effect for decades, the final rule also provides
delayed effective dates of two or three years, depending on the size of the
affected government. Thus, rather than burdening state and local
governments, the rule actually reduces the burdens on those entities.
Further, the rule included a comprehensive and careful analysis of the
benefits and costs of the regulation, showing that the benefits
substantially outweigh the costs. 

The website regulation reflects exactly what public entities have been
seeking since the passage of the Americans with Disabilities Act in 1990-a
clear, transparent shared understanding of the applicable legal
requirements. The final rule is clear and comprehensible, does not stray
from legislative intent (which made clear that the effective communication
requirements of the Rehabilitation Act should be incorporated in the ADA),
accurately estimates the costs and burdens, and provides clear safe harbors.

There is no basis for reconsidering the website rule, which has already gone
through fourteen years of consideration, public input, and adjustment, and
which is based on a requirement in existence for nearly fifty years.
Additionally, public entities have had nearly thirty-six years to prepare
for the requirements that were initially established in the ADA, clarified
by the final rule, and have been actively requested by stakeholders on all
sides. Conversely, delaying or amending the regulation at this point would
severely harm blind and other disabled Americans by denying us access to
important civic information. 

Thank you for your attention to this important issue.

Sincerely,
Mark A. Riccobono, President
National Federation of the Blind

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