Docket 2007 – 1
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
RE: Comments to Access Board Docket Number 2007-1
Madam Chair and Members of the Board:
I am writing on behalf of the Des Moines Area Regional Transit Authority (DART) to provide comment on the Architectural and Transportation Barriers Compliance Board’s Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans, published April 11, 2007, at 72 FR 18179.
About DART
DART serves the communities of Altoona, Ankeny, Alleman, Bondurant, Carlisle, Clive, Des Moines, Elkhart, Granger, Grimes, Johnston, Mitchellville, Pleasant Hill, Polk City, Runnells, Sheldahl, Urbandale, West Des Moines and Windsor Heights. Our service area encompasses all of Polk County here in Central Iowa. DART’s service area is both urban and rural with a large agricultural segment. There are 146 vehicles in our fleet providing traditional fixed, express service, paratransit and flexible route deviation service. DART’s fixed route and paratransit services have approximately 34,000 mobility device boarding’s annually. Our paratransit department provides more than 180,000 trips annually to persons with disabilities.
Physical Changes Being Discussed
As proposed, Section 1192.2(a) would deny DART’s passengers a means of transportation, since our equipment would not comply with new standards.
DART like many public transit agencies does not have funding to cover the costs of redesigning their facilities to handle the suggested changes. DART’s maintenance facility was not built to accommodate space for working on equipment with wheelchair ramps or lifts 8 foot long, nor is the lot around the facility large enough when operators are cycling their lifts and ramps during pre-trip inspections for other buses to maneuver around them. More importantly, the nature of our service area would simply not allow deployment of an 8 foot ramp or lift on many stops.
Phase-In Time Period Allowed; Greater Consideration of Impact
DART can see the advantage of the larger design, however greater consideration must be given to a phase in period as existing fleets are not compliant with the proposed section.
Automated Stop Announcement
Section 1192.35 is requesting the addition of automated stop announcements, and a visual equivalent, which is a wonderful option, but again requires additional funding to be able to achieve the new proposed standards.
The proposal would require such systems on vehicles that exceed 22 feet. This proposal does not recognize that many agencies utilize vehicles over 22 feet in length in route deviated, paratransit and flex & on call services where automated stop announcement systems would have no value (announcing a stop just before the bus deviates off its route). As automated stop announcement systems are relatively expensive, it is inappropriate to require this type of equipment on vehicles where it can not be effectively used. It is also inappropriate to utilize the length of vehicle to trigger this type of requirement. DART, based on passenger demand, utilizes 25 and 30 foot long vehicles for some paratransit routes and our flex & on call services.
Again, a future date can be established that would allow all public transit organizations to come into compliance where the use of such equipment would be effective. These provisions should only apply to newly manufactured vehicles purchased after a specified date and should not apply to used buses or existing fleet.
Universal Sizing for Mobility Aids
Uniformity is critical in handling the majority of passengers being transported. DART believes that any proposed rule should be based on need to accommodate a common wheelchair. Any changes should include amending the current definitions, not abandoning them.
The proposed standards would require exceedingly costly redesigns of nearly every commonly available vehicle and would effectively eliminate the mini-van as a part of our fleets. The impact of this proposal would be profound as the current DOT regulations would prohibit us from contracting with entities that utilize “non-compliant” vehicles (a contract is considered an acquisition). As nearly every accessible taxi is a mini-van, we would loose the very passenger friendly option of using taxi services as an augment or a primary provider of paratransit. We can not believe that the Access Board would want to adopt a standard that would effectively reduce the availability of accessible taxi services.
Allow Continued Use of Cutaways
The cutaway provides a cost effective means to provide transportation for both paratransit and low volume routes, along with mini-vans. The proposed section also does not reflect the reality that over-the-road coaches are sometimes used in public transit systems. The section does not define ‘van,’ ‘similar vehicle,’ ‘bus rapid transit vehicle,’ or ‘mini-van.’ Draft section 1192.21(d) was added to address bus rapid transit facilities without defining what bus rapid transit is.
DART believes there is much more information for the Board to review before any changes are acted upon.
Respectfully Submitted,
Bradford J. Miller
General Manager
Des Moines Area Regional Transit Authority
1100 DART Way, Des Moines, Iowa 50309-4530
515-283-8111 Fax 515-283-8135