Dear Mr. Cannon,
The Gillig Corporation appreciates the opportunity to provide comments on the Architectural and Transportation Barriers Compliance Board’s Draft Revisions to the ADA Accessibility guidelines for Buses and Vans published April 11, 2007.
The Gillig Corporation is a manufacturer of heavy duty buses, primarily for transit operations. The Gillig Corporation is a privately owned company and produces about 1300 heavy duty transit bus a year.
In addition to the comments below that apply specifically to Gillig vehicles, Gillig is a member of the American Public Transportation Association (APTA) and we have reviewed and agree with their comments.
The Proposed Revision has very significant vehicle implications.
We believe the proposed changes were not adequately researched in the area of how the Revision would impact existing vehicles and some of the implied extraordinary changes that will be required to accommodate the Revision. The changes to the vehicle vary from minor issues, to those that require extensive redesign and to others that would effectively eliminate certain bus models that do not have the spatial requirements to meet the proposed regulation. It appears that the ADA requirements for buildings are being imposed on vehicles without due consideration of the vehicles that are involved. The result could impact manufacturing businesses and jobs in a very adverse manner.
Gillig manufactures a variety of bus models to support the public transit vehicle market of the United States. Our review of the draft revisions reveal that several of the smaller models that are typically used by small transit properties or on more rural route structures of larger properties, would be eliminated by these requirements. Specifically, 96 inch wide transit buses which are simply not wide enough for the spatial accommodations required for entry and aisle width requirements in 1192.23.
Additionally, less than 30 foot low floor buses would also be eliminated because of the new length requirements for parallel approach bay dimensions. In this bus the low floor section is predicated by the wheel base which drives the overall length of the bus. The Draft Revision would require a 2 foot increase in bus length which is a whole new design that would then require Altoona test – a very costly process. It would also yield to the end user a larger, heavier, less maneuverable, and more expensive bus that would be more difficult and costly to operate. In some cases Union contracts require higher driver salaries for vehicles longer than 30 feet. We believe these are unintended but damaging consequences of the proposal.
In all of our other bus models there would be a minimum of a 10% reduction in the number of seats available do to the spatial requirements. On one bus model there would be a 22% reduction in the number of passenger seats.
Section 1192.23 also requires a clear 36 inch path to the mobility aid position. This would require the redesign of all buses for a larger front door from the current 30 to 31 inch door opening. Due to the length laws in place these would be all new vehicles with less occupant space. The result is huge design and tooling costs for manufacturers along with the required series of Altoona tests and the cost of model changeover – several million dollars worth of expenditure for each manufacturer. Buses are designed to maximize occupant space at the time they are designed and to accommodate all the applicable regulations at that time. Front door width is a very powerful factor in the design of a bus. It establishes front end overhang, approach angles and along with length laws determines the effective size of the passenger compartment. The reduction of just a few inches from the passenger compartment yields unacceptable hip to knee dimensions and results in lost passenger seats.
The aisle width is problematic over the range of vehicles existing and the huge cost of vehicle redesign to accommodate a clear 36 inches thru the door and to the mobility aid position. We do have a few customers that have us test aisle access with a 30 inch wide by 48 inch long by 30 inch high box with 11/2 inch radii on all corners equipped with casters. We roll this box in the bus and to the mobility aid area. It should be noted not all buses will accommodate this- the customer has to compromise on a small fare box and other details. This is simply their approximation of the 30x48 inch required space and attempts to simulate some mobility device. We know of no mobility aids that are like it. We suggest researching and adapting a standard as seen in FMVSS and other regulations were standardized test sleds etc. are defined. Gillig believes the definition of common the common wheelchair or mobility aid is required. The ever increasing variety and size of mobility devices challenge the intent of the guaranteed access and securement provided by the ADA as applied to vehicles.
We know there will be many responses to the practicality of the proposed 1:8 vehicle ramp specified in 1192.23. We believe it is very impractical from a vehicle design standpoint. There is simply not enough room within the vehicle so the resulting device would extend far past typical sidewalk edges and become a hazard to pedestrians. We also question the consideration of exempting them from the two inch containment edge that has been required of lifts and ramps from the beginning to aid in the retention of the mobility device.
We are aware of proposals for recommending a 1:6 ramp. Gillig is perhaps unique in that we have manufactured specialized vehicles for non transit customers with a rear door ramp of 1:6. It requires extraordinary structural changes and required the user to accept considerably less breakover angle and ground clearance than required by the APTA Standard Bus Procurement Guidelines. Our investigation shows that a 1:6 front door ramp would require a significant structural change to the curbside front structure and would significantly weaken the chassis in this area. This would result in significantly greater vehicle damage and repair cost from typical front end collisions. A 1:6 can be achieved but it will yield a compromise that will increase operators cost significantly. Gillig has no issues with the increase to 660 lbs for the ramp as long as maximum deflection is clearly defined with an easily measured methodology.
Proposed section 1192.23 reduces the width of the rear facing barrier from 18 to 10-12 inches. Gillig recommends against rear facing positions and has not built any buses with this feature due to various safety concerns. We do not feel the definition of the barrier in 1192.23 would provide adequate support for the mobility aid user. Despite the European practice of compartmentalization Gillig believes proper securement must be provided and we are not sure that making the barrier smaller does anything but fuel experimentation with rear facing positions at the operation level. We question what research and testing has been done in the U.S. to verify that this type of barrier arrangement should be codified in to law.
Proposed Section 1192.35 requires automated stop announcements. This equipment is not only very costly but it is technically very challenging for all transit operations to implement. Many of the smaller properties simply do not have the resources to deal with this additional complexity and we question if the need has been proven. We would recommend a fleet size threshold for this part of the proposal.
The Gillig Corporation appreciates the opportunity to provide these comments, and we remain available to provide any further assistance on the evaluation of these drafts. However, Gillig is very concerned about the adverse impact this Revision will have on existing and future vehicle designs and about the very significant cost of compliance.
Sincerely
Charles E. Koske
Sr. Vice President of Engineering
cc: B. Macleod