1. We encourage you to reconsider the abandonment of the current definition of a common wheelchair (30” x 48” and not exceeding 600 lbs including the passenger). While we recognize that the current definition may need to be revised, we fear that leaving the matter open-ended would mean that transit systems like CATA will need to make a case-by-case determination of every wheelchair user and each vehicle we operate.
2. The requirement that all vehicles longer than 22’ must be equipped with an automated stop identification system that includes both a visual and audio announcements will mean that even the smallest transit system will need to equip their vehicles with GPS in order to make the automated systems work. This provision, particularly for rural providers with flag stops, is will be very problematic - and expensive.
3. The proposal to change the definitions for compliant boarding ramps from a maximum slope of 1:4 to a slope that does not exceed 1:8 means that ramps will have to be twice as long as they currently are and the devices will need to have a bi-fold or other more complex mechanism. Not only that, but in small communities such as the one CATA serves, it will be very difficult to deploy such a long ramp at many of our stops.
4. The proposal requires that all vehicles have doorways and a clear pathway to the securement location that is at least 36” wide, and also ramps and lifts 36” inches wide. Not only would this requirement make nearly every current full sized bus and all mini-vans non-compliant, we fear that this dimension would limit the seating capacity of the small buses we use in our neighborhood service to the point that we could no longer run such vehicles.
5. In addition to the above, we believe that much more attention needs to be given to the phase-in period for any and all of the proposed changes. Many small transit systems like CATA keep buses in service for as long as 20 years, so there will be an extended period during which transit systems will be operating a mix of "old rule" equipment and newer fully-compliant vehicles.
Thank you for the opportunity to comment on the proposed Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans.
Sincerely,
Hugh A. Mose