Disability Rights Education and Defense Fund (DREDF), Marilyn Golden
January 27, 2009 [email]



Disability Rights Education and Defense Fund (DREDF)

COMMENTS FOR DOCKET NUMBER 2007-1 or RIN NUMBER 3014-AA38

AMERICANS WITH DISABILITIES ACT (ADA) ACCESSIBILITY GUIDELINES FOR TRANSPORTATION VEHICLES

U.S. ACCESS BOARD

PUBLISHED IN THE FEDERAL REGISTER ON NOVEMBER 19, 2008

DREDF is in substantial agreement with the draft guidelines, and applaud the many positive changes in them. While we hoped to see a larger wheelchair envelope and higher design load, we think there are many good features in this draft that should be maintained, including but not limited to:

" Provisions requiring visual contrast.
" Explicit maneuvering clearances for wheelchair locations on the vehicle  these are very necessary.
" Clearer provisions for doorway vertical clearance on accessible vehicles. This doorway clearance wording is important and will hopefully increase the accessibility of accessible taxis and similar vehicles which have often run afoul of the doorway vertical clearance requirement based solely on how they are measured.
" Ramp slope of 1:6 rather than 1:4. There have been many problems with drivers not pushing chairs up steep ramps, and small drivers bring unable to push heavy wheelchairs/riders up steep ramps.

The following comments express DREDFs concerns and questions with the draft, many of which are merely for greater clarity.

1) Advisory T101 General: Entities should be clarified (e.g. the transportation providers required to follow these guidelines). The frequently used term covered entities is hard enough to understand for people unfamiliar with the ADA, but at a minimum, would be better than entities alone.

2) T203.5.4 Signs: While we appreciate the concept behind this requirement that the eventual expectation should be that all buses are accessible and thus, only accessible doorways should be signed when not all doors are accessible, it is unfortunately not the case that all buses are accessible. For example, not all over-the-road buses are accessible, and there are occasions when it would be good to know if a particular one is. DREDF is not sure how to organize a requirement where an International Symbol of Access would reflect both accessible doorways and the bus itself, but we hope the Board and staff will at least consider ways to do so.

3) T503.3 Doorways on Over-the-Road Buses: Insert the word wide in three locations, as follows:

T503.3 Doorways on Over-the-Road Buses. On over-the road buses, doorways with steps shall provide a clear opening 760 mm (30 inches) wide minimum from the lowest step tread to a height 1220 mm (48 inches) above the lowest step tread. Where compliance is not structurally feasible, the clear opening shall be permitted to be 685 mm (27 inches) wide. The clear opening shall be permitted to taper to 457 mm (18 inches) wide minimum from a height 1220 mm (48 inches) above the lowest step tread to the top of the doorway. Hinges and other door mechanisms shall be permitted to protrude 100 mm (4 inches) maximum into the clear opening.

4) T706.2 Operation (of Stop Request Systems): The minimum height provision for operable parts is too low for stop request systems.

5) 218.2 New and Altered Stations: The phrase for level boarding bus systems should be at the end (that is, the last item in the list), to clarify the intent. Similarly, in F218.2 New and Altered Stations, the phrase for level boarding bus systems should again be at the end (last item in the list). Also, in 810.5 Station Platforms, the language in level boarding bus systems should be at the end (last item on the list).

Further, see point 6 of this DREDF comment, below.

6) 810.2 Bus Boarding and Alighting Areas: This title should be Bus Boarding and Alighting Areas on Sidewalks and At Street Level, to clarify the same intent as in point 5 above. And similarly, in 810.5 Station Platforms, this title should be Bus and Rail Station Platforms. Without these changes, it appears that the requirements only apply to level boarding, and that there are no requirements where there is not level boarding.



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