Office of Technical and Informational Services,
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW, Suite 1000
Washington, DC 20004-1111
RE: Comments on the Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans:
Subpart B – Buses, Vans and Similar Vehicles
1. 1192.23 Mobility aid accessibility, (b) Vehicle lift, (1) Design Load
Champion Bus, Inc. manufactures handicap accessible commercial buses. These buses are designed with level change mechanisms for loading and unloading persons with disabilities. Last year, Federal Motor Vehicle Safety Standard (FMVSS) 403 promulgated regulations which specify standards for vehicle lifts. A great deal of time and effort went into the development of this particular standard, and the design load for these lift was set at 600 lbs. We believe that although the 600 pound design load may not be ideal, all Federal Standards should maintain continuity and we recommend that the lift design load be revised to be in line with FMVSS 403.
2. 1192.23 Mobility aid accessibility, (c) Vehicle ramps and bridgeplates, (5) Slope –
Champion Bus, Inc. manufactures accessible commercial buses. The requirement for a 1:8 maximum slope will significantly impact our low floor model bus.
When the bus is kneeled, the bus has a floor height of 12”. In order to meet the 1:8 slope to the ground, the ramp would have to be 96” in length! The height of the floor is dictated by the frame rails on the International 3200 chassis. This is not an area that we can modify.
If such a ramp was available, and if it was possible to package in the bus, (which is not currently the case), the ramp would extend 8’ from the side of the bus. When you add another 4’ to allow the wheelchair user to maneuver onto the ramp, the bus would be blocking two lanes of traffic. This could result in an increase in traffic accidents.
Transit Sales Manager
Champion Bus, Inc.
331 Graham Road ~ P.O. Box 158 ~ Imlay City, Michigan 48444 ~ 810.724.6474
Fax: Sales - 810.724.1844 ~ Purchasing - 810.724.7661 ~ P & S - 810.724.3734 ~ Accounting - 810.724.3734