Mr. Cannon:
Comments on ACCESS BOARD Draft Update of Guidelines for Buses and Vans
Submitted by: Access Services Inc.
INCREASED WEIGHT LIMIT
Current regulations require transit operators to accommodate mobility devices weighing up to 600 pounds (including the rider). The new regulations would increase this by 10% to 660 pounds. Barring any specific, quantifiable rationale to increase this limit by 10%, ASI requests that the current standard (600 lbs.) not be changed. As pointed out in the draft Guidelines issued by the Access Board, the NHTSA has performed extensive testing based upon the 600 pound limit. To arbitrarily increase this limit would invalidate the work done by the NHTSA.
RAMP SLOPE
Current ADA regulations define maximum slope angle based upon vehicle floor height from the top of a 6" curb. The floors of ASI’s minivans are 10" above the ground, which is 4" above a 6" curb. Current regulations for this floor height require a 1:6 maximum slope which results in a minimum ramp length for these minivans of 24" (4" times a factor of 6 [1:6]). The proposed regulation would require a maximum 1:8 slope for all vehicles for all conditions, including when deployed to the roadway. This would require that the ramp platform for these minivans be increased from 24" to 80" (10" times a factor of 8 [1:8]). This would require a folding or telescoping ramp.
ASI’s Fleet Administrator predicts that the maintenance of such a device would be significantly greater than the current, comparatively simple ramp which meets the 1:6 slope requirement to a 6" curb. In addition, an 80" extended ramp could pose a hazard to bystanders, as it would extend well into a roadway or sidewalk when fully deployed. In fact, in many situations, an 80” ramp would extend beyond the sidewalk, which might require the vehicle to be positioned into the roadway so as to allow sufficient maneuvering room for the rider on the sidewalk to access the ramp. Such positioning would not only be unsafe but, most likely, would be illegal as well. It is anticipated that this length ramp would add significant weight to the vehicles, which in conjunction with the potentially heavier mobility devices (increased weight limit to 660#), could cause the GVWR to be exceeded. ASI recommends that this new ramp slope guideline be rescinded and that the current guideline, which permits measurement of slope to a 6” curb, be retained.
COMMON WHEELCHAIR DEFINITION
ASI believes that the proposed elimination of the definition of a common wheelchair in the draft guidelines will lead to more confusion among riders as to what devices are permitted or required, and will lead to increased administration in determining the applicability of specific mobility devices to the new regulations. The guidelines’ proposed required 3-dimensional space (30" wide, 48" long, 40" high) can be accommodated aboard ASI’s vehicles, which consist of minivans, modified vans and cutaways, and the required clear width of 36” and clear height of 40” is available from inside the accessible entrance to the mobility device securement position(s). However, the requirements for a 60” wide securement position effectively precludes the use of the minivans and modified vans, and would probably result in a significant reduction in the seating capacity of the cutaways.
In addition, ASI believes that the ambiguity caused by the lack of a definition for a common wheelchair will result in confusion, misunderstanding and, potentially, unsafe situations. By way of example, recent rulings have advised transit operators to accommodate Segways, although, the device is treated as a mobility aid, such as a walker. Under the draft guidelines, it is possible that an individual could mandate that they be allowed to "ride" the Segway as a mobility device onto the vehicle, and be secured with the device. This would clearly be an unsafe action aboard ASI’s vehicles such as low-floor minivans. ASI urges the Access Board to reconsider the draft guideline with respect to defining common wheelchairs, and to provide more specific guidelines for the benefit of both the transit operators and riders who use such devices. In reconsidering the guidelines, ASI requests that alternative vehicles such as minivans and modified vans be given full consideration, as these vehicle types comprise a significant portion of the fleets that provide mandated ADA paratransit service.
John Helm