June 11, 2007
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, suite 1000
Washington, DC 20004-1111
On behalf of the Consortium for Citizens with Disabilities, we would like to thank the Access Board for the opportunity to comment on the draft revisions to the Americans with Disabilities Act (ADA) Accessibility Guidelines for Buses and Vans. Technology and the mobility needs of people with disabilities have advanced so far from 1991, when the Board issued their original guidelines, that it is prudent to revisit the guidelines to update them.
The Consortium for Citizens with Disabilities is a coalition of approximately 100 national disability organizations working together to advocate for national public policy that ensures the self determination, independence, empowerment, integration and inclusion of children and adults with disabilities in all aspects of society.
Mobility Aid Accessibility
We applaud the Board’s efforts to simplify the way transit operators and vehicle manufacturers address the size limits of mobility aids. Moving away from the definition of “common wheelchair” and instead focusing on the space that needs to be available for wheelchairs and other mobility devices is a good approach.
The standards requiring a route from the entrance to securement locations is also a good one. However, we agree with the Board that a wholesale application of the building standards to buses and vans might not be achievable, especially when it comes to turning circle. We encourage the Board to consider setting scalable standards that would have an accessible route requirement for larger vehicles with some exceptions for smaller vehicles that would still allow for a basic level of access within the constraints presented by a vehicle like a minivan or van.
Depending on drivers to call out stops has been a significant barrier to fulfilling the promise of the transportation provisions of the ADA. Technology has advanced to a point where this barrier is relatively easily removed by having the stop announcement process automated. We encourage the Board to include the public information system language that is in the draft in the final version of the guidance.
In addition, members of the Task Force have been alerted to systems that do use automated stop announcements that are able to be turned off by the driver. Too often these systems are deactivated for the convenience of the driver and leave passengers who need access to the system without it. We ask that the Board add a provision that automated stop announcements should not be able to be deactivated by the driver.
Ramp Rises and Operations
Simplifying the rise ratio for ramps on buses and vans will greatly ease the confusion that currently exists about what boarding technology will work for riders with disabilities. We encourage the Access Board to continue these simplified approached to the guidelines. The boarding approach for Bus Rapid Transit (BRT) vehicles with multiple entryways is also a logical approach.
Bus Rapid Transit
Bus Rapid Transit is an important emerging mode and applying the ADA standards to it will make sure that riders with disabilities are included as usage of this mode increases. The Task Force encourages the Access Board to continue monitor Bus Rapid Transit and identify any additional standards needed as the technology advances.
We appreciate this opportunity to comment and look forward to working with the Access Board to achieve final guidelines that will increase the mobility of people with disabilities.
Disability Policy Collaboration