Ohio Department of Transportation, Office of Transit, Marianne Freed
The Ohio Department of Transportation, Office of Transit submits the following comments and questions to the Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans.
The new guidelines eliminate the definition of common wheelchair and mobility aids (T104.4). There should still be guidelines defining a common wheelchair; otherwise, systems may be required to transport individuals who cannot be properly secured or should be transported via medical transportation, ie chair that must be leaning back or can be leaned back for prone transport.
The new requirement for automated route announcement system for vehicles at stops which serve multiple routes for vehicles greater than 22’ in length (T704). No instructions on how long systems have to equip vehicles and come into compliance.
The new guidelines provide guidance on front or rear and side approach (T402.4.1 and T402.4.2). Does this apply to Section 5311 vehicles? Must vehicles be retrofitted if needed? If so, by when?
The new guidelines require handholds and stanchions on the backs of forward and rear facing seats directly adjacent to the aisle (T505.5). Must current vehicles be retrofitted if needed? If so, by when?
The new guidelines have character spacing and line spacing requirements for signs. Must current vehicles be retrofitted if needed? If so, by when?
The new guidelines require automated stop announcement systems (T705). Must current vehicles be retrofitted if needed? If so, by when?
The new guidelines require fare collection devices for operable parts on fare collection devices (T806). Must current vehicles be retrofitted if needed? If so, by when?
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