Dear Members of the Access Board:
I am writing to ask you to consider requiring manufacturers of mobility devices to have standard "D" rings or other designated areas for the devices to be secured in accessible vehicles. As it is now there is no uniformity in these devices. The poor operator of a public transportation vehicle is supposed to know how to secure everything from a standard manual wheelchair to three wheeled electric scooters. Much emphasis has been placed on the public transportation vehicles and next to none on the mobility devices themselves. Since the vehicles are required to have four point securement systems, it follows that manufacturers of mobility devices should have four easily identified securement places on their devices.
If you take away the standard weight limit for the wheelchair lift of 600 lbs you will be requiring larger vehicles with less fuel econcomy at a time when the increasing cost of fuel is limiting service for many providers already. The other advantage of having the existing weight limit is that it keeps drivers from being injured by even heavier mobility devices rolling over them in tight quarters. We have had several cases of drivers being injured on the job just doing the contortions necessary to secure existing devices in crowded vehicles. Drivers have reported electric wheelchairs running over their feet but with the existing weight limit we have not had a workman's compensation case due to this.
As a provider of both fixed route bus service and paratransit van service in the Boone area and demand response service through out Watauga County, AppalCART uses everything from minivans to 35 foot transit buses.Requiring rural providers to have gps stop enunciators would increase the cost of the vehicle by approximately $10,000 for no good reason. They are taking people where they want to go as it is demand response service. It would be more useful to require the navigation systems that cost less than $500 so the driver could find the addresses he is being sent to.
Our transit system is in the process of going from standard floor buses to low floor buses due largely to our desire to have a more reliable system of access than the wheel chair lifts. The low floor buses have the additional advantage of no steps at either door which in our mountainous environment prevents passengers from slipping on steps in the winter.Changing the ramp ratio would decrease the reliability of the ramps by making them more mechanically complex given they would have to fold more times to retract.
The one disadvantage of the low floor bus is it often must lose seats to the wheel wells. Requiring wider doors would subtract more seating thus increasing cost of service per passenger. The 36 inch door on a conversion van would require something other than the standard van chassis, which in turn would drive up the cost per vehicle. At some point we need to think in terms of the majority of the passengers while allowing reasonable access for the disabled. Our system, being one that caters to a university environment has many more people denied seats due to overcrowding than it does people with disabilities. Given our mountainous terrain there are limits on how large a bus we can operate. On many routes a 30 foot bus must be used to accomodate the narrow curvy roads. Lessening the capacity of buses would be a real hardship on our system as we would have to use more vehicles and drivers to carry the same number of people.
I think the manufacturers of buses and securement systems have improved their accessibility features greatly over the past 16 years. Having a constant standard has allowed them to keep improving what they had. The threat of a new standard might be enough to stifle innovation on their part.
Sincerely,
Christopher D. Turner
Transportation Director
AppalCART
P.O. Box 2357
Boone, N.C. 28607