King County Metro Transit, Kevin Desmond
January 20, 2009 [email]



Dear Chair and Members of the Board:

As General Manager of King County Metro, I am writing to provide comments on the Architectural and Transportation Barriers Compliance Boards Draft Revisions to the Americans with Disabilities Act (ADA) Accessibility Guidelines for Buses and Vans, published
November 19, 2008 at 73 FR 69592.

King County Metro, a division of King County, Washington, operates a fleet of about 1,300 vehicles including standard and articulated coaches, electric trolleys, dual-powered buses, hybrid diesel-electric buses, streetcars and paratransit vans that serves an annual ridership of over 100 million within a 2,134 square file area.

King County Metro submitted detailed comments to the Boards 2007 draft, but would like to reiterate a few of the major concerns with the latest draft.

The access standards for transportation vehicles should not exceed those for architectural standards

King County Metro believes that without comparable requirements adopted for architectural standards and the public rights-of-way, incremental increases in public transit vehicle requirements would provide no meaningful improvement to persons with disabilities. It may, in fact, by creating additional financial burden on transit authorities, mean a decrease in overall availability of public transit.

The definition of a common wheelchair should not be abandoned

Abandoning this definition would create substantial uncertainty over the transportability of mobility aids among vehicle manufacturers, suppliers, transit agencies and wheelchair providers. Without clear regulations, transit agencies are left with setting arbitrary maximums without sound evidence or rationale for their decisions, and this would foster disputes over compliance.
Automated stop announcement requirements should include a phase-in period and hardship and small fleet exceptions

King County Metro strongly recommends that there be some accommodation provided to transit agencies given the expense and complexity of implementing automated stop announcements. In 2010, King County Metro will have this capability, so we understand the difficulties and challenges these systems can create for transit agencies. We would propose this requirement be waived if a system can demonstrate that the stop announcement by operators is meeting the needs of their disability community. Further, we believe this requirement should not apply to agencies using less than 100 vehicles in the peak. We also support that a reasonable phase-in period be granted to any size transit agency.

The proposed changes are premature

This is the most significant comment. In discussions within our agency and those we have had with other agencies, it is this comment that comes up repeatedly. Lack of details in the recommendations themselves, as well as the lack of supporting research, leaves many questions about the feasibility, wisdom and practicality of the recommendations. In addition, the increase gained in accessibility is minimal for some of these recommendations. In the best of financial times, these recommendations would be difficult to achieve given the present capabilities of the design and manufacturing industry. In our present financial climate, the financial burden seems unnecessary given the effort that will need to be expended by the transit agencies to pay for the development of new technology, as well as the lack of a competitive field of vendors for reasonable pricing to be achieved.

Closing statement

King County Metro prides itself on its responsiveness to all our customers unique needs, from being an early developer of the first lifts used in transit buses, to equipping all buses with bicycle racks, and having one of the largest van pool programs in the country. We will continue to strongly support innovative approaches to accessibility and desire to work with you in continuing your efforts.

Sincerely,

Kevin Desmond
General Manager
King County Metro Transit



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