Rock Island County Metropolitan Mass Transit District (MetroLINK)
1515 River Drive
Moline, IL 61265
Re: Comments to Access Board Docket Number 2007-1
Dear Madam Chair and Members of the Board:
I am writing on behalf of the Rock Island County Metropolitan Mass Transit District (MetroLINK), the transit system providing service to Rock Island and Henry Counties (the town of Colona) in Illinois to express our concerns about the proposed revisions to the ADA Accessibility Guidelines for Buses and Vans.
Our primary issues:
1. We recognize that the current definition of the common wheelchair (30” x 48” and not exceeding 600 lbs including the passenger) may need to be revised, but encourage you to reconsider leaving the definition open-ended. In doing so would mean that transit systems would need to make a case-by-case determination of each wheelchair user and vehicle we operate.
2. The requirement that all vehicles longer than 22’ must be equipped with an automated stop identification system that includes both a visual and audio announcements will mean that even the smallest transit system will need to equip their vehicles with GPS in order to make the automated systems work. This provision, particularly for rural providers with flag stops, will be very problematic.
3. The proposal to change the definitions for compliant boarding ramps from a maximum slope of 1:4 to a slope that does not exceed 1:8 means that ramps will have to be twice as long as they currently are and the devices will need to have a bi-fold or other more complex mechanism. This would make it difficult to deploy such a ramp at many of our stop locations due street widths and conditions. Not only that, the slope would affect the ability of the drivers to be able to push the wheelchair up the ramp.
4. The proposal requires that all vehicles have doorways and a clear pathway to the securement location that is at least 36” wide, and also ramps and lifts 36” inches wide. Not only would this requirement make nearly every current full sized bus and all mini-vans non-compliant, the requirement would limit the seating capacity and larger wheelchairs could reduce the passable aisle width.
Also, we believe that more consideration needs to be given to the phase-in period for any and all of the proposed changes. Many transit systems keep buses in service for as long as 20 years, this means there will be a longer time period during which transit systems will be operating a mix of "old rule" equipment and newer fully-compliant vehicles.
Thank you for the opportunity to comment on the proposed Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans.