Dennis
Attached in New Flyers submission for comments.
A Hard Copy of the letter is enroute to you.
Headquarters/ Customer New Product Crookston St. Cloud
Winnipeg Facility Services Development Facility Facility
711 Kernaghan Ave. 25 DeBaets St. Unit 7, 45 Beghin Ave. 214 5th Ave. SW 6200 Glenn Carlson Dr.
Winnipeg, Manitoba Winnipeg, Manitoba Winnipeg, Manitoba Crookston, Minnesota St. Cloud, Minnesota
R2C 3T4 Canada R2J 4G5 Canada R2J 4B9 Canada 56716 USA 56301 USA
Ph: (204) 224-1251 Ph: (204) 982-8400 Ph: (204) 982-8413 Ph: (218) 281-5752 Ph: (320) 203-0576 www.newflyer.com
14 January 2009
Dennis Cannon
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F St. N.W. — Suite 1000
Washington, DC 20004-1111
Ref: Docket No, 2007-1, RIN 3014-AA38
Subject: Comments on the second draft of revisions to the ADA Accessibility Guidelines for
Transportation Vehicles
Dear Mr. Cannon:
In accordance with the requirements laid down in the Federal Register, New Flyer of America and New
Flyer Industries Canada ULC (together, New Flyer) is supplying the following comments regarding the
subject draft. Comments are in order to their appearance in the draft. New Flyer is a manufacture of
heavy duty transit buses.
T203.2.2.2 Bridgeplates and Ramps. — Both advisories to this section indicate that the slope of the ramp
or bridgeplate must not exceed 1:8 when deploying to station platforms. As a manufacturer New Flyer is
obliged to build to the specifications stated in regulations once effective. However, as a vehicle
manufacture New Flyer does not control the height of station platforms. This leaves two options, either
that a tolerance be stated for station platform height, so that New Flyer can design to meet the tolerance,
or that New Flyer design a ramp or bridgeplate as close as possible to the requirements, given the
ambiguity in the requirements, and states that it can only meet the ADA requirement for platforms
between a specific height range. The second option may create unfair competitive advantages for vehicle
manufacturers who have designed for a range of platform height which is not available in a specific city or
county. It is therefore requested that the definition of compliance to the 1:8 slope also include a height
range for the station platform, so all manufactures can design to the same requirements.
T203.4.2.2.1 Doorways on One Side of Vehicle. — This paragraph references two sections not found in
the document (T203.4.3.1.1 and T203.4.3.1.2).
T402.4 Size (Graphics). — The metric dimensions on all the graphics in this section read “min” and
should read “mm”, unless indicating a “minimum” dimension, in either case it should be clarified. In the
second graphic, the dimensions from section T402.4.1 are improperly represented.
2
T403.3 Movement. — Please clarify if this paragraph also applies to rear facing wheelchairs or mobility
aids as designing securement for all rear facing users may not be possible. Those who prefer a rear
facing seat do so because securement is not required.
T403.5 Padded Head Rest. — There are no specifications for testing or structural capability for this
component (e.g. …backrest must withstand 2 G’s of force on the longitudinal plane to a 600 lb load …).
T403.5 Padded Head Rest (Graphic). — There is no minimum thickness specification for the padded
head rest, just that it protrudes into the space by 9 to 12 inches. Also the graphic appears to indicate that
all the G loading in a stop would be absorbed in the mid-back of the wheelchair user. The graphic does
not obviously represent the required distance from the “wheel or device stop” to the front of the back rest.
T502.2 Clear Width. — The increase in dimension causes some concern, not for design, but for testing. In
the past with the smaller dimensions, most would try to qualify or disqualify the space via the nonrecognized
“box test”. The path being compliant only if a 30 (W) x 40 (L) x 30 (H) box could maneuver
from the door to the securement location. If box is now increased in size to 32 (distance between door
grab handles) x 48 (implied length) x 40, it will most likely not fit. The Advisory T502.2 indicates that a 3D
model be used to determine if an occupied wheelchair can maneuver from doorway to securement
location, it does not mention the dimensions of the occupied 3D wheelchair (hopefully, it is not box
shaped), perhaps a suggested 3D model form could be made available, or the dimensions supplied so
one can be created.
706.1 General. — This specifies that visible stop request indicators should only be located at the front of
the vehicle. Rear facing passengers will not see these. We would suggest a second sign towards the rear
of the vehicle or a special visual indicator located at the rear facing position(s) should be incorporated.
T802.2 Slip Resistance. — a minimum and maximum tolerance for the level of slip resistance (coefficient
of friction, wet/dry or static) should be stated for both normal flooring as well as non-skid flooring for
designated areas like the ramp. Some non-skid flooring is too aggressive and may actually cause people
to stumble. Some non-skid flooring is ineffective or becomes ineffective after extended use. Previous
recommendations from the US Access Board have indicated that a minimum 0.8 coefficient of friction for
ramps and other designated areas. For general flooring, OSHA recommends a minimum static coefficient
of friction to be 0.5. Typical bus flooring material has a static coefficient of friction of 0.6.
I thank you for the opportunity to supply comments for consideration. If you have questions or require
clarification on the items above please contact me.
Sincerely,
Kerry Legg
Safety & Compliance Manager
Customer Services Head Office
(204) 934-4876
Click here to see the attached file.