Southeastern Pennsylvania Transportation Authority
Safety · Service · Continuous Service
1234 Market Street
Philadelphia, PA 19107
June 11, 2007
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, N. W., Suite 1000
Washington, DC 20004-1111
Re: US Access Board Docket #2007-1 (ADAAG Transportation Vehicle specifications)
Dear Mr. Cannon:
SEPTA provides the following comments on the proposed revisions to the Americans with Disabilities Act (ADA) Accessibility Guidelines (ADAAG) for Transportation Vehicles (Buses, Vans and Similar Vehicles), published in the Federal Register on April 11, 2007. SEPTA appreciates this opportunity to offer suggestions at what we trust is a preliminary stage, given that the operational, vehicle design, and cost impacts of your proposals compel extensive research and analysis.
As the fifth-largest transit agency in the United States, SEPTA has firsthand knowledge of accessibility issues and is committed to addressing them. Our historic network includes 143 bus, subway, light rail, and rail lines, as well as paratransit services. Our 2,661 vehicles deliver more than 300 million passenger trips annually throughout a five-county, 2,200 sq. mi. service area. With regard to paratransit service, in FY06 SEPTA CCT provided 1.7 million passenger trips using a fleet of 450 vehicles. In July, 2004, SEPTA’s bus fleet became 100% accessible using both low-floor and lift-equipped vehicles. Since that time, the number of riders using wheelchairs on our buses has tripled. This diversity of service makes SEPTA one of the few truly multi-modal systems in the country. Most of our network is composed of acquired routes, stations, and operational infrastructure (tracks, bridges, tunnels, overhead structures, etc.) that are close to or more than 100 years old. SEPTA’s operating environment consists of the city of Philadelphia and surrounding towns that have been settled for almost 300 years. Narrow streets, narrow sidewalks, varying curb heights, and restricted access are the norm. On-street parking and parking in bus zones is endemic. Since ADA’s passage, SEPTA has committed over a billion dollars to an ongoing, intensive, system-wide initiative to make its services, vehicles and facilities accessible. Accordingly, SEPTA is keenly interested in any proposals to amend ADAAG vehicle specifications not only for buses, but also for rail transportation.
The Board’s proposals have profound consequences for SEPTA’s bus and paratransit vehicle design and deployment, and for the customers we serve. Operating on our existing roadways, the proposed ramp slope and wheelchair volume standards are unachievable using SEPTA’s present vehicle designs. When the Vehicle Specifications changes are viewed as the precursor to Accessibility Guidelines for other transportation vehicles, concerns increase. For SEPTA, the proposed vehicle accessibility requirements will compel significant alterations in fixed route and demand-response vehicle deployment, requiring additional vehicles, operators and supervisory/maintenance personnel to serve the same number of riders we now transport, while also carrying a staggering price tag, the full extent of which has not yet been calculated.
For regular fixed route buses, we estimate that removing four additional seats to accommodate the new “wheelchair volume standard” would require adding approximately 150 buses to our fleet, a 12% increase. At a price of at least $500,000 each for standard hybrid buses, this would require SEPTA to seek an additional $75M in capital funds to meet this obligation, plus operating costs of drivers, fuel, and maintenance. These added vehicles would be required simply to accommodate our existing ridership and would not account for new riders. Most disturbing of all, however, the new standards would force SEPTA to abandon low-floor, ramp-equipped buses and revert to lift-equipped buses with rear entry, which the disability community would strongly oppose.
For paratransit, the new standards will eliminate use of not only minivans but the entire class of vehicle (single rear wheel minibus) upon which SEPTA CCT now depends, forcing a shift to dual rear wheel vehicles with flat floors and virtually eliminating direct service to/from narrow streets. Even with wider, larger paratransit vehicles, these standards will result in loss of seating, meaning that we will have to add almost 30 vehicles, use more drivers and fuel and incur added operating expense merely to serve our current ridership — while paratransit ridership continues to escalate. At a cost of about $50,000 each (more for larger vehicles), vehicle replacement simply to meet existing ridership would require an additional $1.5M in capital funds. Unlike the 12-year useful life of a transit bus, our paratransit fleet replacement follows a 5-year cycle, making this increased expense immediate and ongoing.
It defies logic to invest billions nationwide in facilities and vehicles to accommodate the Common Wheelchair standard and then, without rigorous examination, render these facilities and vehicles non-accessible by instituting greatly increased volumetric and slope standards before it has been determined that the present standards are inadequate for most wheelchair users and the new standards are technically and operationally feasible. SEPTA strongly urges that all proposed changes remain at the draft stage until studies have determined that inability to accommodate the existing Common Wheelchair using existing vehicles and low-floor bus ramps does in fact represent a major national problem, sufficient to warrant changing the national design standard. In addition an engineering study is needed to examine wheelchair volumes and shapes to determine if, and how, volumes larger than 30" × 48" can be accommodated within low-floor buses with their existing doors, fare boxes and wheel wells. Finally, a nationwide impact analysis is recommended to determine the cost of implementing the proposed changes. It is necessary to keep in mind that the transit industry and bus manufacturers and suppliers must be afforded reasonable time to incorporate any design changes that are adopted. And a realistic transition period must be allowed after the effective date of any new regulation. These issues are not addressed in the Access Board’s draft.
Fundamentally, we question why transit vehicles should be regarded as infinitely expandable to accommodate ever-larger mobility devices. Simply saying “people are getting larger and need more space” ignores recent technological developments. An Internet check shows that manufacturers offer wheelchairs within or near the Common Wheelchair dimensions that accommodate individuals weighing 450 lbs. or more. Meanwhile, advances in miniaturization mean that even very sophisticated new technologies can now be accommodated in devices meeting the Common Wheelchair footprint (stair-climbing wheelchairs, for example). The answer is to educate consumers regarding which devices are transit-usable nationwide, and to encourage new technologies, not to keep expanding transit vehicles with cascading negative consequences for costs and service for all passengers. This “tail wagging the dog” approach is short on reason and rationality. We believe that the best approach for all parties would be to create a “transportable mobility device” standard that would clearly spell out the dimensions of the devices that could be carried on public transit vehicles, and that those vehicles must be designed to transport. With such a standard, there would be no confusion as to what size devices consumers should purchase if they intend to use public transportation.
SEPTA’s current bus fleet (1300 vehicles) consists of about 50% low-floor, ramp-equipped vehicles. In addition, low-floor trackless trolleys are on order and low-floor high-capacity (articulated) buses are in the exploration/development stage. Low-floors have been strongly championed by the regional disability community and SEPTA’s policy is that whenever possible new vehicles will continue to be low-floor rather than lift-equipped. For SEPTA, low-floor buses have substantially increased the number and speed of wheelchair boards while negating the possibility of lift failure, at the same time affording our mobility-impaired riders a new security of service. Unfortunately, the proposed new ramp slope requirement, which is unachievable on most Philadelphia streets, will force SEPTA to abandon low-floor, ramp-equipped buses and return to lift-equipped vehicles. This step, which triggers major cost, service and security impacts and carries a high potential for route delays, will severely compromise the gains of recent years.
Section 1192.23 (c) proposes a maximum slope of 1:8 in all cases, including when deployed to the ground. The Board’s commentary states that new ramp designs make this possible. SEPTA does not believe this slope is achievable in a real-life transit environment, even using accordion ramps.
Curb heights vary greatly in Philadelphia due to its old streets, road surface buildup, and depressed curbs. SEPTA requires bus operators to assist wheelchair users in boarding or exiting when the ramp slope becomes difficult. This assistance is usually sufficient and when it is not, the operator is instructed to move the bus to a nearby location for boarding. We strongly urge that the present ramp standards be retained. The following table shows why.
|OPTIMUM conditions (sidewalk boarding) in Philadelphia||Whenever bus must board/discharge riders in road, driveway, non-standard curb or curbcut, or with no sidewalk|
|Bus height from ground||14"||14"|
|Less 3" for kneeling feature (must be activated before ramp can deploy; current bus designs do not permit kneeling lower than 3" without bottoming out)||11"||11"|
|Less 6" curb||5"||n/a; see above|
|Ramp length required to achieve new 1:8 standard||40" (3 ft. 4 in.)||88" (7 ft. 4 in.)|
|Ramp length now used on SEPTA low-floor buses||44.51" (3 ft. 8 in.)||44.51" (3 ft. 8 in.)|
SEPTA low-floor buses feature a 44.5" ramp, which exceeds the ramp length currently required when the ramp is deployed to the curb. SEPTA require bus operators to board/discharge passengers to the curb whenever possible. If the curb is obstructed due to parked vehicles (as is often the case) or snow/ice accumulations, as previously noted, operators are required to move the vehicle to an accessible spot nearby. As shown above, the new maximum ramp slope requirement of 1:8 to the ground will require an 88" ramp to cover all contingencies. However, we are not aware of any ramp in design or production that can achieve a length greater than the Ricon BiFold’s 58.4".
Ramps 88" long will present significant operational and safety challenges if used on Philadelphia streets. All ramps in planning or production are designed to be deployed to their full extent, regardless of the length actually required. Thus, a ramp of this extreme length may not be deployable in many locations even when the bus is at the curb, as it may exceed the width of the sidewalk or boarding area, particularly in historic areas, driveways, or when the bus is boarding passengers from a traffic island (where SEPTA has already had difficulty meeting the requirement of a 60" turning area for wheelchairs). In these instances, the bus would have to be positioned far enough from the curb or island so that the ramp could be fully extended. As a result, any ambulatory passengers would have to board or exit in the street. The only other option would be to double-stop, which would have an egregious impact upon on-time performance. As a tripping hazard, deployment of an extra-long ramp represents a safety concern for passersby and other riders waiting at the stop. We also wonder whether a ramp of this length would require handrails, rendering it even more cumbersome and less capable of being folded to stow.
Imposition of the proposed ramp slope requirement will have the practical effect of forcing SEPTA to revert to lift-equipped buses. This would be strongly opposed by our disability community, which enjoys the convenience and reliability of front entry using ramps. SEPTA views the proposed ramp slope requirement with the utmost concern.
1192.3 Definitions Of Terms; 1192.23 (d) (3) 1192.21 (c); 1192.3 Common Wheelchair
”Common Wheelchair“ — deleted from Definitions: We strongly urge that a definition be retained and updated, perhaps as follows:
“Transportable Wheelchair” …belonging to a class of wheeled devices, usable indoors, designed for and used by persons with mobility impairments, which, when occupied, do not weigh more than 660 lbs. and whose dimensions are no greater than 30" in width and 48" in length measured from the ground or floor up to a height of 40".
It seems disingenuous for the Board to argue that its Guidelines do not have the force of regulation and that therefore its standards should not be viewed as regulatory. Obviously, by statute the Board is not a regulatory body. Rather, it is the Board’s statutory responsibility to develop and issue design standards that when adopted through Rule Makings by departments become regulations. Likewise, we find unconvincing the Access Board’s contention that because the Common Wheelchair design standard has been misused to deny transit service to eligible individuals, the Access Board should abandon this universal standard. Improper application of a design standard to a service provision issue is an issue for USDOT to address. As the nation’s accessible design standards board, it is essential that the Access Board continue to maintain this iconic design standard around which all public services and facilities, building design and engineering, public road design, telecommunications and banking facilities, in addition to transportation facilities and vehicles, are designed and built. This is the Access Board’s statutory responsibility.
The Board may elect to relocate this standard from Sec. 1102.3 (Definitions), and insert it instead in Sec. 1192.21 as a Space Requirement. This is acceptable provided the design standard itself remains a standard and carries a universally understood title.
It is also understood that the Access Board has no statutory authority to regulate wheelchairs or mobility aids. Nonetheless, the Board and its members do exert considerable influence. We strongly urge the Access Board to apply this influence to open a dialogue with the mobility aid industry about the desirability of designating as “transit-accessible” those mobility aids that meet the standards for use on transit publicizing availability of securement kits for ready installation where the product otherwise lacks built-in securements; and designating “not for public transportation use” those devices which are not usable on public transit.
SEPTA opposes the Access Board’s attempts in these proposed standards to apply its own facilities requirements to transit vehicles. This apples/oranges premise does not take into account the reality that, unlike built structures, transit vehicles are not readily expandable. Vehicles’ width, length, height, weight and interior layout are constrained by the infrastructure within/on which they operate (city streets, roadways, bridges, tunnels, tracks), their means of propulsion, and available technology. On any transit vehicle, every inch is at a premium. Each component is complex and interrelated. Often one can increase a building’s size to meet new needs; for a transit vehicle, this may be impossible to achieve, even with today’s advances in miniaturization. Meeting the new space requirements proposed by the Access Board unavoidably reduces the number of passengers vehicles can carry. Decreasing capacity means transit agencies must add more vehicles, with more operators, supervisors, and maintenance personnel, and consume more fuel, to serve the same number of customers. Thus, applying facilities design standards to transit vehicles will significantly increase fleet size and hence, operating, maintenance and capital costs, while generating no additional revenue.
A second consequence of the proposed new “Wheelchair Volume Standard”, which must be achievable from vehicle entry to wheelchair area, is that it will force SEPTA and many other transit agencies to return to rear-door wheelchair lifts on buses. SEPTA believes this standard as proposed is unsuitable for buses used in older cities, and cannot be attained using 102’ low floor buses unless major modifications can be made to the bus width, or the wheelchair entry is relocated to the rear door. Surely the Access Board is aware that rear-door entry is detested by many disability advocates, who regard it as conveying second-class citizenship. SEPTA transit operations note that rear-door entry creates security and fare collection problems, significantly slows service, and amplifies difficulties of curbing vehicles on city streets by requiring that not just the front door but also the rear door be close to the curb, which can be almost impossible to achieve. In addition, environmental barriers at rear doors (signage, newspaper boxes, parked vehicles) present daily challenges for bus operators and customers — problems SEPTA has no power to change, as we own or control only a handful of our more than 15,000 bus stops.
The increased floor space required by proposed accessible path standards for approach and maneuver will result in the loss of four fixed route bus seats. Reducing peak hour capacity means that to serve the same number of riders, we will have to add vehicles to the load line, which will require more vehicles, drivers and fuel, and increase operating costs — without generating new revenue.
For SEPTA CCT paratransit, the impact is equally grave. Proposed approach/maneuver standards will eliminate use of not just minivans but the entire class of vehicle (single rear wheel minibus) upon which we now depend. These vehicles’ dimensions and wheel well placement will not permit the required larger wheelchair berths, aisles and turning radius. Unavoidably, service will have to be provided exclusively by dual rear wheel vehicles with flat floors. We will be unable to access many more locations on narrow streets. In addition, the new lift requirement of 660 lbs. and the increased frame structure the manufacturer must add to strengthen the vehicle will increase base vehicle weight. Because our present paratransit vehicles are already close to the maximum allowable Gross Vehicle Weight Requirements (GVWR), we will be required to purchase larger, wider vehicles. Nonetheless, a larger, wider vehicle designed to meet the proposed standards will not provide any added capacity — rather, it will result in the loss of one or more seats while costing more to purchase and consuming more fuel than present vehicles. The resulting lower peak hour paratransit capacity will require more vehicles and drivers, and increase operating expenses.
With regard to paratransit service provision, negative consequences for customers would include reduced seating capacity in each vehicle and more use of fold-away or flip seats. More important, 56% of SEPTA’s paratransit trips originate or terminate in areas of the city where the streets are 15 ft. wide or less. After allowing for a parking lane, this dimension is too narrow for the next larger class of paratransit vehicle to access. An enforced shift to even wider vehicles would prevent door to door, or even curb to curb, service to many SEPTA customers. “Next-street” service is certainly not customer-friendly (especially not for customers with disabilities), nor does it generate productive, cost-effective scheduling. And when low productivity requires more vehicles and drivers to deliver the same volume of service, some of the added expenses must be passed on to customers.
ADA paratransit is the most costly public transportation mode. Operations costs already range from about $12 to $55 per trip nationwide. For SEPTA, the cost to provide each paratransit trip is approximately $26.70. Therefore, any design changes impacting cost of service cannot be undertaken lightly as being forced to shift to more and larger vehicles would increase capital costs (purchase of larger numbers of more expensive vehicles) and operating costs (drivers, supervisory and training staff, fuel, vehicle maintenance).
Vehicles and facilities purchased, built or modified, or on order, that comply with current regulatory standards under the present Common Wheelchair definition do not conform to this new standard. This will adversely affect both fixed route and demand-response transportation. It will preclude purchase of used vehicles by paratransit providers, many of which depend on this cost-saving strategy. On the bus side, setting aside the operations and cost impacts described above, there are further consequences: Agencies, and particularly bigger transit agencies, will have to rebuild or retool their maintenance facilities to accommodate larger fleets of wider buses. And what about our riders? During a 12 year transition period (useful life period for buses on order and in use), this “dual universe” will create confusion for bus customers and operators as some vehicles accommodate extra-large mobility devices and others, not. How will riders keep track of which facilities and buses they can access, to avoid traveling to a facility they cannot enter, or waiting for a late-evening bus that cannot accommodate them? At SEPTA, having attained 100% bus accessibility we are unwilling to return to partial accessibility.
1192.21(c) Wheelchair And Mobility Aid Space Requirements
The Access Board requests comments on the wording of this new section. Discarding the concept of a Common Wheelchair design standard and moving to a volumetric standard — an Unobstructed Volume, or a Universal Mobility Aid Envelope, perhaps — new paragraph (c) specifies the minimum 30" × 40" × 48" envelope which must be available within the vehicle, from entrance to securement locations, for it to be deemed accessible. To these dimensions the Board adds a weight limit of 660 lbs. Having defined this envelope, the Board then requires a 36" accessible path from vehicle entry to securement locations. Further provisions require wheelchair areas 60" long. We recommend that, instead, consideration be given to what can be achieved. — We recommend that this section begin with a separate introductory provision stating that the objective of these standards is to accommodate mobility aids meeting the Transportable or Common Wheelchair standard. A possible addition might define a “transportable” wheelchair as able to pass through a 32" doorway and turn 90 degrees from a 32" corridor into a 32" corridor without backing up. Alternatively, the new Mobility Aid Envelope might more accurately be described and illustrated as a 60-degree ellipse extending 30" × 48" and measuring 40" in height from the ground.
1192.23(a) (2) Maneuvering Clearance (onboard accessible routes, including width, vertical clearances, and handrails and handholds); 1192.23 (d) (2) Mobility Aid Securement Space Size And Location; 1192.25 (c) Door Height – Vertical Clearance (vehicles 22' or less)
On SEPTA low-floor buses, the onboard accessible path horizontal dimensions are: ramp width, 30"; width inside entry, 32"; after 45-degree turn, adjacent to wheel wells, 34.3" at the floor, 35" measured 30" up. However, Paragraph 2 of Sec. 1192.23 (a) requires a route at least 36" wide from door through to securement locations. This is a major change. This ADAAG facilities design standard has not previously been applied to vehicles with their unavoidable spatial constraints. The proposed new 36" accessible path standard is unachievable for SEPTA using existing fleet vehicles. Meeting the new standard would require the following actions:
Further Constrict Driver’s Space: New technologies such as Mobile Data Terminals and identification/smart card readers have already necessitated incursions into the operator’s space. Further decrease of the space allocated for the safe, comfortable occupation by all driver body types is simply out of the question.
Shrink or Remount Fare box Assembly: Hopefully new technologies and miniaturization can shift this unit further out of the path of travel. Its bulk, however, is unavoidable. Like many transit properties, SEPTA still collects tokens and cash fares and thus its fare boxes must include a removable fare vault, which eliminates the possibility of an “arm” mounting rather than a pedestal. The Board is also aware that because the fare box must meet ADAAG reach standards for riders in wheelchairs, it cannot be moved completely out of the way.
Redesign Front Doorway/Use Wider Buses: Providing a 36" accessible path on vehicles requires increasing the space between the wheel wells. This might be achievable using a 120"-wide bus (with mirrors, occupying 144" — 12' — of roadway) instead of the current 102". However, a number of factors (lane width restrictions, narrow streets, turning radius, wide load constraints) make 120" buses unsuitable/infeasible for use in older cities. Many Philadelphia streets are less than 20' wide. External constraints such as lane width restrictions prevent use of buses wider than 102" (with mirrors, 126") in most urban and suburban settings. In Philadelphia, 102" is the maximum width we are permitted to operate, and only on specified major streets. SEPTA buses now find it difficult to make certain turns onto some city streets. Using wider buses will increase the turning radius, further restricting the streets on which we can schedule service. In some regions (Minnesota, California, for example), 120" constitutes a wide load, which is then subject to local and state clearance limits. A permit is required for travel, pilot cars and/or police escorts may be required at times, bridge and tunnel access may be restricted, and hours of travel are limited — no wide load movement is permitted within certain cities during rush hours.
Nationally, mandating extra-wide buses also could preclude provision of deviated fixed route service (paratransit provided using regular transit buses which go off-route), which is typically offered in rural and suburban areas where 120" buses may not be usable or welcome.
Rear Door Entry/Lift-Equipped Vehicles: SEPTA began buying low floor vehicles and provides front door bus entry for wheelchairs at the specific request of our disability community. Abandoning these is unacceptable. It would negate all the gains of a low floor fleet, while also requiring redesigning the rear door to make it wider, removing seats at the rear door to create wheelchair areas, and continuing to provide priority seating up front. SEPTA’s experience is that forcing wheelchair users to enter at the rear bus door delays schedules at peak hours and creates obvious and significant cost, service and security concerns.
The Access Board requests comments on the feasibility of a 32" minimum width. As reported, SEPTA low-floor buses already achieve, with great difficulty, a 32" accessible path from inside the door to the wheelchair areas. Requiring that the door opening and ramp meet the 32" minimum, however, would require redesign. We do not know whether this dimension could be met. We do know that a 36" accessible path throughout, as proposed, cannot.
A second proposed change to Section 1192.23 again applies facilities standards to transit vehicles’ more constricted spaces. In considering the right angle turn past the fare box after front door entry, the Board asks: In building standards, a 42-inch minimum aisle is required to turn into a 36-inch wide aisle. Can this be achieved in a bus? How can the maneuvering and turning space be defined so that compliance is more verifiable? The Board does acknowledge, the available space is constrained by the fare box, driver seat, modesty panels and wheel wells. A 5-foot turning circle is not possible. Here, please note that being able to make a 90-degree turn in a mobility device on a transit vehicle also depends on the placement of wheels on the device and the skill of the individual using it. Accommodating turning space for a rectangle is not actually the issue. In reality, a wheelchair or scooter chair’s footprint is shaped like a 60 degree ellipse, not a rectangle. This difference is meaningful because the operating envelope of an ellipse requires less space and is easier to accommodate in tight quarters. This is why we urge consideration of a functional definition such as Transportable Wheelchair (for example: able to pass through a 32" doorway and turn 90 degrees from a 32" corridor into a 32" corridor without backing up).
SEPTA recognizes that in restricted bus space, it can be difficult to move a second mobility device into a securement area when one wheelchair is already on board, or into a space enclosed on three sides. Nonetheless, the Board has elected to revise securement location/size requirements using ADAAG Facilities requirements for alcoves. Again, we question the application of building specifications to vehicles, where space is finite.
The proposed requirements for approaches and maneuvering clearances will require additional floor space for securement locations. While the Board does not change the dimensional requirements of 30 × 48 inches for the securement location, if adopted, these proposals will require clear approaches [aisles] up to 36 inches [formerly 30"] and floor space for securement location up to 36 × 60 inches for maneuvering purposes. For the reasons previously outlined in this letter, this proposal has profound service and cost implications.
1192.3 Definitions Of Terms
“Bridgeplate”: SEPTA has no objection to the newly-added definition of “bridge-plate”.
“Fixed route system”: SEPTA strongly opposes the unnecessary addition of “or having a general frequency or headway, which may vary according to time of day”. ADA’s definition (Sec. 221, (3): Fixed route system. — The term “fixed route system” means a system of providing designated public transportation on which a vehicle is operated along a prescribed route according to a fixed schedule) is brief and straightforward, and should be retained. The proposed added language ignores the critical statutory distinction between regular fixed route service and limited/express/commuter/shuttle service (which often varies with time of day). That important distinction determines whether a transit agency is obliged to provide ADA Complementary Paratransit mirroring a particular route. SEPTA believes the proposed wording relates to service provision, not vehicle design standards, and does not belong here.
1192.4 (c) Miscellaneous Instructions – General Terms
SEPTA has no objection to the proposed change in wording from “if” to “where, when”.
Subpart B title and 1192.21(a) Buses, Vans and Similar Vehicles
Please define “similar vehicles”.
1192.21(d) Specifications For Bus Stops And Stations Based On Updated Facility Guidelines
SEPTA supports this proposal. It is essential that all bus stops, stations and terminals conform to the same ADAAG requirements. Unfortunately, because SEPTA does not own or control most of its bus stops, SEPTA cannot always enforce their accessibility. Equally, SEPTA has no control over curb heights, or even whether curbs and sidewalks are present, except at its own facilities.
1192.23(a) (1) When Level-Changing Mechanism Must Be Provided
SEPTA believes adding specific requirements here is useful.
1192.21(c); 1192.23(b)(1) Lift Design Loads
At present, if a mobility aid will fit on the bus lift or ramp, and if the lift can lift it, SEPTA buses will transport it. Adopting 660 lbs. as the new standard would promote uniformity between ramp and lift load capacity, recognize the maximum threshold now available for lifts, and promote accommodation of customers using the heavier chairs more prevalent now.
SEPTA feels strongly that, from a safety standpoint, ramps, lifts and bridgeplates, and all components of each, must be rated to be able to accommodate the same required uniform maximum load.
1192.23 (b) (6); 1192.23 (c) (2) Slip Resistance Requirement – Lift Platforms; Vehicle Ramps And Bridgeplates
Instead of the present generalization that ramp, lift and bridgeplate surfaces must be "slip-resistant", SEPTA strongly recommends that for all vehicles, the Access Board specify the coefficient of friction and that this be at least 1.4 dry and 1.1 wet for surfaces such as bus ramps and bridgeplates that are exposed to wet weather. After field testing wet and dry surfaces by wheelchair users, SEPTA increased the slip resistance requirement for its bus ramps to these standards. Because wheelchair tires may not always be brand-new, wet conditions can promote wheel-spinning and sliding, and low-floor bus ramp slopes in urban settings are not always optimal, requiring substantial slip resistance enhances rider safety.
1192.23 (c ) (9) Requirement For Manual Operation Of Ramps/Bridgeplates
SEPTA’s low-floor buses all feature ramps that can be flipped open manually as well as operated mechanically. We have no objection to this proposal.
1192.23 (d) (1) Mobility Aid Securement Force Standard; Specifications For Seat Belts & Shoulder Harnesses
SEPTA seat belts and shoulder harnesses comply with 49 CFR 571. We have no informed opinion as to whether the Society of Automotive Engineers standard should be adopted.
1192.23 (d) (4) Rear-Facing Securement – Padded Barrier Dimensions
SEPTA does not provide rear-facing securements and has no objection to the reworded provisions clarifying required size of padded barrier behind such securements.
1192.23 (d) (6) Stowage Of Securement System Components
SEPTA already observes the proposed requirement that the securement device cannot protrude into the required clear floor area, and has no objection to it.
1192.27 (c) Priority Seating – Signage Specifications
Again, this proposal incorporates signage specifications from the “new ADAAG” for Buildings and Facilities. It also requires that signs above wheelchair height use larger characters. SEPTA has no objection to this provision.
1192.29 (b), (c) Stanchions And Handrails
SEPTA already provides both aisle-side seat-back hand-holds and overhead handrails. We have no objection to paragraph (b)’s proposed increase in maximum handrail diameter to 2".
1192.31 (c) Exterior Lighting
SEPTA has no objection to deleting the requirement of a specific location for exterior lights.
1192.33 Fare Box
In its Federal Register announcement, the Access Board states, …changes are proposed to accommodate new technology…. Nonetheless, this unaltered section does not reflect new technologies such as swipe or proximity card readers. It should.
1192.35 Public Information System
SEPTA has no objection to the new requirement that buses more than 22' long be equipped with automated audio and visual stop announcement systems. Our vehicles already comply. We recognize, however, that this provision will be costly and entail a considerable transition period for some smaller systems to implement.
In addition, we recognize that it can be difficult for riders who are blind or visually impaired to identify their vehicle for purposes of filing a service complaint or commendation. Because automated stop announcement systems can malfunction, a requirement that all vehicles must be equipped with such systems will heighten visually impaired riders’ need for vehicle ID information. SEPTA recommends that the Access Board require that on all buses/vehicles, regardless of size or type, the vehicle ID number be displayed in accessible formats in a standard location inside the bus near the front (on the back of the driver partition is suggested).
1192.39 (b) Exterior Destination And Route Signs: Character size
SEPTA has no objection to these changes and new requirements.
SEPTA believes implementation of these proposed standards should be deferred pending resolution of the major and significant cost and vehicle engineering questions these raise.
Faye L.M. Moore