Docket 2007-1
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
Dear Madam Chair and Members of the Board:
I am writing on behalf of Transfort/Dial-A-Ride, the transit system serving the City of Fort Collins, Colorado, to express our concerns about the proposed revisions to the ADA Accessibility Guidelines for Buses and Vans.
The following is a list of our 5 major concerns:
1. We urge you to reconsider the abandonment of the current definition of a common wheelchair (30” x 48” and not exceeding 600 lbs including the passenger). While we understand that the current definition may need to be revised, we fear that dissolving the clear guidance already established would mean that transit systems like Transfort/Dial-A-Ride will need to make a case-by-case determination of every wheelchair user and each 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 small or 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. Our ramp equipped buses would have to extend 112” at their current height in order to be deemed compliant; which will require excessive boarding distances to curbs. This would make many of the bus stops in Fort Collins inaccessible.
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. This would effectively render our entire fleet of full sized transit buses non-compliant.
5. In addition to the above, we believe that much more attention needs to be given to the phase-in period for any and all of the proposed changes. It is our hope that any phase-in period would allow transit providers to continue their “accessible” status on previously compliant vehicles.
Many transit systems like Transfort/Dial-A-Ride keep buses in service for as long as 12 to 20 years, so there will be an extended period during which transit systems will be operating both compliant and non-compliant vehicles.
Thank you for the opportunity to comment on the proposed Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans.
Sincerely,
Marlys Sittner
General Manager