Comment from PEAC

Docket No. FTA-2026-0232 Comment from Programs to Educate All Cyclists (PEAC) Re: Request for Information on Family Friendly Transit Programs to Educate All Cyclists (PEAC) appreciates the Federal Transit Administration’s (FTA) effort to look beyond minimum ADA compliance and examine what makes transit functionally usable. For over 30 years, our organization has empowered individuals with cognitive, intellectual, and developmental disabilities to travel independently using active transportation and public transit. Our core position is that transit accessibility must be measured by successful independent use, which requires robust travel training programs and continuous, lived-experience accessible audits of the "first and last mile" networks connecting to transit. Area #1: Safety and Security For riders with cognitive and developmental disabilities, safety extends far beyond station incident reports. True safety is the ability to navigate the built environment with confidence. Through our street-level accessible audits, riders frequently report profound anxiety tied to confusing intersections, aggressive vehicle traffic, and a lack of secure bicycle parking. A transit system is not safe if the route to access it forces a vulnerable rider to navigate a "mean street." The FTA should require agencies to measure safety by auditing the pedestrian and cyclist infrastructure immediately surrounding their transit hubs. Area #2: Cleanliness and Maintenance Maintenance metrics must account for how infrastructure impacts a travel-trained route. When an individual with a cognitive disability undergoes travel training, they learn a specific, safe path. An unplowed landing pad, a debris-filled bike lane, or a broken crosswalk signal is not merely an inconvenience; it breaks a learned route and severs access to the system. Ongoing maintenance of active transportation infrastructure connecting to transit stops is a critical component of transit usability. Area #3: Universal Accessibility The RFI rightly notes the gap in data regarding intellectual and developmental disabilities. Cognitive accessibility is highly measurable, and lived expertise is the gold standard for gathering this data. Through our Nice Streets. Mean Streets project, we partnered with the University of Michigan to have students with intellectual disabilities evaluate and classify commuting routes based on their direct, lived experience. This framework highlights that the street-level path to a stop is an inseparable part of trip accessibility. We urge the FTA to require: Lived-Experience Accessible Audits: Agencies must fund and implement street-level audits led by individuals with disabilities to determine the true accessibility of connecting infrastructure. Travel Training as Core Infrastructure: Infrastructure alone does not create independence. The FTA must measure the availability and success rates of dedicated travel training programs that teach individuals to safely navigate transit and active transportation networks. Supportive Physical Infrastructure: Continuous bike lanes and fully functional bike-on-bus infrastructure accommodating non-traditional bicycles (e.g., adult tricycles or tandems) must be standard. Area #4: Real-Time Service Data Availability Usable information is the foundation of independent travel and a vital part of travel training. When a travel trainee encounters an unexpected detour, accessible real-time data prevents them from becoming stranded. Wayfinding and transit updates must be provided in accessible, plain-language, non-smartphone-dependent formats so all riders can safely adjust travel plans. Area #5: System Reliability For an individual who has completed travel training, reliability is the linchpin of independence. A missed connection for a rider with a cognitive disability who depends on a bicycle can derail a carefully practiced route. Reliability should be measured by total door-to-door trip time—including the time it takes to cycle or walk to the stop. Conclusion True family-friendly transit requires a commitment to the entire journey. We urge the FTA to mandate community-led accessible audits like Nice Streets. Mean Streets and prioritize travel training to empower all cyclists and transit riders to travel with dignity and independence. Respectfully, John Waterman Executive Director Programs to Educate All Cyclists (PEAC) 110 North River Street Ypsilanti, Michigan 48198 jwaterman@bikeprogram.org