June 8, 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
Dear Madam Chair and Members of the Board:
I am writing on behalf of The Tri-State Transit Authority (TTA), which provides regular route bus service and paratransit service in Huntington, West Virginia and surrounding suburban and rural areas. Our comments are addressed to the concerns we have for the proposed revisions to the ADA Accessibility Guidelines for Buses and Vans.
Overall, if the entire NPRM were to be implemented, there would be no vehicle in existence designed to meet the requirements. Vehicles that meet the accessibility guidelines at this time would be obsolete. Thus, there would be no accessible mass transit service in America.
I do not for one moment question the merit or worthiness of the goal of the Architectural and Transportation Barriers Compliance Board to ensure as much accessibility for the disabled as time and money will permit. What we see here, however, really puts the cart before the horse. If the Board has sound evidence of the need to so dramatically modify accessible design, then we need to start with a design period for the manufacturers and maybe even consider some design competition after an appropriate span of time for their development.
Then we need to research the availability and cost of the technology required to implement such sweeping changes. The universe of small transit systems in America is much larger than the number of large transit systems in huge metropolitan areas like Washington, D.C. and Chicago. These rules would kill the small transit systems. As noted already, there would then be no accessible mass transit.
I am confident that my peers in other small transit systems will address many of the specific concerns in the minutia of the NPRM. We cannot abandon the current definition of a common wheelchair and leave only a condition on transit systems to make a case-by-case determination of every wheelchair user. That is suicidal.
The requirement that all vehicles longer than 22’ must be equipped with an automated stop identification system with visual and audio announcements is a great theoretical concept. However, in reality, many of the nations small urban and rural operators just plain don’t have the tech staff or financial resources to accomplish this task. You cannot do it without GPS or the automated systems will not work. This provision is probably impossible to implement for small urban and rural “flag stops.”
The proposal to change the definitions for compliant boarding ramps from those that meet the current requirement to be twice as long and have a bi-fold mechanism require a whole new vehicle design. Retrofit would likely be impossible. Even if they did exist, they would be impossible to use at many of our stops in the Huntington area.
Again, the proposal for vehicle doorways that lead a clear pathway to a securement location that is at least 36” wide and ramps and lifts 36” inches wide are the cart before the horse. If there is a mass transit vehicle or paratransit vehicle in existence this day that meets this requirement, I have never seen or heard of it. The day this requirement was published, all of TTA’s fleet would be non-compliant. Then the disabled would have no accessible transportation.
Please keep in mind in assessing the comments on this NPRM that smaller transit systems like TTA keep vans in service for at least seven years and heavy duty buses in service for as long as 20 years. The implications of the requirements in the NPRM for the nations fleet of transit vehicles are numerous and seem to overlook the lessons we have learned over the past 16 years.
Thank you for the opportunity to comment on the proposed Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans.
Chief Executive Officer
The Transit Authority
Phone: 304 529-6094
Fax: 304 529-7300