Comments of the Ann Arbor (Michigan) Transportation Authority on Docket 2007-01, Advanced Notice of Proposed Rulemaking (ANPRM) – Revisions to the ADA Accessibility Guidelines for Buses and Vans
Submitted by:
Christopher White
Manager of Service Development
Ann Arbor Transportation Authority
The Ann Arbor Transportation Authority has long been a leader in providing accessible public transportation. When the Americans with Disabilities Act (ADA) became law in 1991, the entire AATA fixed-route fleet was already lift-equipped, and the AATA provided paratransit service that exceeded many aspects of the ADA requirements for complementary paratransit service. In 1992, the AATA was the first U.S. transit operator to put ramp-equipped buses into fixed-route service, and the AATA fleet became entirely ramp-equipped in 2004. In 1997, AATA’s advanced operating system including automated audio and visual bus stop announcements and automated internal and external route announcements.
AATA has consistently demonstrated commitment to providing equal access for people with disabilities to public transit service. We hope that this lends some credibility to the following objections to the provisions of the ANPRM. Our objections are based not on an attempt to obstruct, or even based on cost, although some of the provisions would add significant expense. Rather, based on our significant operating experience, the following provisions, if enacted, would be counterproductive to solving the problems they are intended to address.
Specifically, the AATA objects to the following provisions.
1192.3 Elimination of the definition of common wheelchair.
1192.23(a)2 Specification of dimensions of path to securement area
1192.23(c)5 Change in ramp slope requirement
1192.23(d)2 Change in the size of securement area
1192.23(d)3 Change in securement devices to accommodate any mobility aid
The AATA has viewed the definition of “common wheelchair” as a minimum standard. That is, we accommodate all people using mobility aids that conform, and attempt to accommodate other mobility aids. It is noteworthy that the great majority of mobility aids that we see still fit within this definition, and that we have been successful in accommodating most other mobility aids.
The common wheelchair definition has provided a reference point for transit providers and people with disabilities. Each of us know the dimensions of mobility aids that we can certainly accommodate. For devices that exceed this definition, we can work with users on whether they can board with it and be secured and how. We have tried to educate users on this definition so that they can talk to us about our ability to accommodate a mobility aid that doesn’t conform before they purchase it.
However, different designs for mobility aids continue to proliferate, and they are much more varied, and growing larger, and more complicated. Accomodating riders and the growing variety of mobility devices challenges transit operators every day. Some of these mobility aids were not designed to be secured, and lack the structural integrity to be properly secured.
The provisions above are each an overly simplistic solution to a complex set problems. They mandate that the transit operators and bus manufacturers develop solutions. The actual solutions require the involvement of mobility aid manufacturers and dealers, and standards for mobility aids that are designed to be transported with a user.