June 7, 2007
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
RE: Comments to Access Board Docket Number 2007-1
Madam Chair and Members of the Board:
Thank you for the opportunity to comment on the proposed revisions to the ADA accessibility guidelines for transit buses and vans.
The draft guidelines propose simplifying Section 1192.23 (c) by no longer tying ramp slope to the height of the vehicle floor above a 6” curb. Instead, a slope of 1:8 is proposed for ramps, regardless of whether they are deployed at a curb or in the roadway.
While we agree that ramp designs that reduce ramp slope would be beneficial, we are concerned that a ramp with a slope of 1:8 when deployed to the roadway may be infeasible.
The San Francisco Municipal Transportation Agency (SFMTA), which operates the Municipal Railway (Muni), has not purchased low floor vehicles until very recently, in part because of concerns about the slope of the ramps that were available on the market. Ramp slope has been a particular concern for Muni buses because of operational constraints.
Many of Muni’s coach stops are pole stops where buses load passengers in the street. Even at bus zones, the operator is sometimes unable to reach the curb because of illegally parked cars, delivery vehicles, etc., and must board passengers in the street. The topography of streets and sidewalks in San Francisco in some locations may make boarding using a ramp even more challenging.
The SFMTA recently procured a fleet of Orion hybrid low-floor vehicles after extensive research to find vehicle and ramp designs that would mitigate concerns about ramp slope. The coaches are equipped with state-of-the-art Ricon bi-fold ramps. The bi-fold ramps, at 58.5” long, are about 10” longer than most transit vehicle ramps.
The Orions are equipped with a kneeler that lowers the coach floor to 11” – 12”. Deployed to a 6” curb, the slope of the bi-fold ramp is significantly less than 1:8. When the Ricon ramp is deployed in the street, however, the slope is approximately 1:5.
We are aware that a new ramp configuration, Lift-U’s “Fold-out Plus,” is becoming available. This ramp achieves a functional length of 76.3” because part of the ramp platform is in the interior of the vehicle. However, according to the manufacturer, even this very innovative design may only achieve a slope of 1:6 when deployed to the street. We are not aware of any fixed route low floor buses with ramps that, when deployed in the street, have a slope of 1:8. Nor are we convinced that such a ramp can realistically be constructed.
There is a finite space within the bus to stow a ramp, and the innovations of Ricon and Lift-U have pushed the limits of ramp platform length. Further innovations to extend platform length to achieve a slope of 1:8 in all circumstances would be difficult because of storage space limitations and potential impacts on the vehicle chassis. In addition, a ramp platform of sufficient length needed to achieve a 1:8 slope would project so far from the vehicle that it could be difficult to accommodate on a sidewalk or in a traffic lane. A ramp platform extending from a coach kneeled to 11” would be 96” long, the same length as an ADA compliant bus stop pad. Maneuvering room for a wheelchair user attempting to access the ramp to board would be severely constrained whether the ramp was deployed on the sidewalk or in the street.
Based on our tests of ramps over the past 10 years, we believe that a 1:5 to 1:6 ramp slope for a ramp deployed in the street will meet the needs of most wheelchair users and will be a huge improvement over what has been available in the past. We propose that the vehicle requirements continue to specify different slopes for ramps deployed in the street and ramps deployed to a curb. For curb deployment, a slope of 1:8 seems achievable; for roadway deployment, a slope of 1:5 is more reasonable.
Access to Securement Areas
It is unclear in section 1192.23 whether the proposed requirement of a 36” wide route to the 60” long securement area applies to vans as well as to buses. These dimensions are not achievable on minivans; thus, the proposed requirements would effectively exclude minivans from use as public transit vehicles. This would have an adverse effect on paratransit operations, for which the minivans provide flexibility because they can be operated on narrow streets.
Moreover, it could also prove difficult to provide a 36” wide path of travel to a securement area even on larger transit vehicles because of pinch points created by fare boxes, stanchions, wheel wells, etc. A clear width of 32” should be permitted at such constrained areas, in conformance with the ADA/ABA guidelines for accessible routes.
Regarding the proposal to require 60” long securement “bays” on transit vehicles, we believe this provides more space for a “common wheelchair” than is needed. A 55” long area would be adequate and is a more realistic minimum dimension. In the Muni fleet, the two securement areas generally differ in length, with a longer area on the curb side of the vehicle. In our ETI trolley coaches, a street side area of 55” in length has proven adequate. Regardless of the length of the securement areas, we have found that the maneuvering room for a wheelchair user can be maximized by staggering the securement areas rather than placing them at the same location on each side of the aisle.
The draft guidelines, in section 1192.29 (c), include a requirement that, on vehicles longer than 22’, operators provide handholds adjacent to the aisle on the back of each forward or rear facing seat. We understand that this rule would replace the requirement for overhead handholds. We seek assurances on whether vertical stanchions attached to the seat back would also meet the new requirement, as they provide an even more stable handhold for standing passengers.
Some of the proposed regulatory changes, particularly those relating to ramp slope, require further research before they are implemented. Also, we recommend that the regulations be tailored to particular vehicle types, such as minivans, so that vehicle characteristics are taken into account. Possible height and path of travel clearances are quite different for a small ramped minivan compared to a 40’ bus.
As the Access Board proceeds with the update of the vehicle regulations, the Board should provide information about how the regulations will be implemented. For example, we assume that the updated guidelines would apply only to vehicle procurements commenced after the new guidelines are enacted.
Thank you for the opportunity for the San Francisco Municipal Transportation Agency to comment on the proposed revisions to the ADA Accessibility Guidelines for Buses and Vans. I hope this Agency's experience in the area of transit vehicle accessibility advances the Access Board’s process in updating these important requirements.
Nathaniel P. Ford Sr.