Unitrans, Geoff Straw
Dear Madam Chair and Members of the Board:
I am writing on behalf of Unitrans, the transit system serving Davis, California, and the University of California at Davis, to express our concerns about the proposed revisions to the ADA Accessibility Guidelines for Buses and Vans.
We have five primary issues with the proposed Accessibility Guidelines:
- We encourage you to reconsider the abandonment of the current definition of a common wheelchair (30” x 48” and not exceeding 600 pounds including the passenger). While we recognize that the current definition may need to be revised, we fear that leaving the matter open-ended would mean that transit systems like Unitrans will need to make a case-by-case determination of every wheelchair user and each vehicle we operate.
- 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 global positioning systems in order to make the automated systems work. This provision, particularly for rural providers with flag stops, is will be very problematic.
- 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. Not only that, but in small communities such as the one Unitrans serves, it will be very difficult to deploy such a long ramp at many of our bus stops.
- 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, we fear that this dimension would limit the seating capacity of our vehicles.
- 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. Many small transit systems like Unitrans keep buses in service for as long as 25 years, so there will be an extended 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. Please call me at (530)752-6525 or email me at email@example.com if you have any questions.
One Shields Avenue
Davis, CA 95616