Please find attached our responses to the Access Board Docket Number 2007-1 ADA draft guideline changes. ElDorado National California appreciates the opportunity to provide these comments. ElDorado National California will be available to provide any further assistance on the evaluation of these or future drafts.
Sincerely,
Tony Wayne
President
ElDorado National California, Inc.
9670 Galena Street
Riverside, California 92509
909-591-9557
January 19, 2009 sent via e-mail cannon@access-board.gov & Certified Mail
DOCKET 2007-1
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 “F” Street NW, Suite 1000
Washington, D.C. 20004-1111
Re: Comments to Access Board Docket Number 2007-1
ElDorado National, California builds both 96” wide conventional floor buses and 102” wide low floor buses. The majority of the buses produced here are from 30’ to 32’ in length. Each style of bus requires different considerations for handling the requirements of the persons with disabilities. The purpose built 30’ to 32’ buses that ElDorado National, California manufactures do not have the flexibility of floor space that a 40’ bus has.
Therefore, we are responding to the draft revisions to the guidelines and the problems they create with the vehicle models built here:
T502.2 Clear Width: The proposed increase to 34 inch minimum clear width of circulation paths connecting wheelchair spaces to doorways will prohibit many of our floor plans in all bus models while reducing the number of ambulatory passengers and wheelchair occupants.
T402.4.2 Side Approach: The proposed increase to a 30 inch by 60 inch minimum wheelchair space could be devastating in some models and applications. It would eliminate our 30’ low floor bus model. The 30’ model was created for the end user to be more maneuverable, lighter-more fuel efficient and be less expensive. It would eliminate the ability to carry a 3rd wheelchair occupant in our Passport & E-Z Rider II model buses. This change would eliminate many of our floor plans in all bus models while reducing the number of ambulatory passengers and wheelchair occupants.
T303.8.1 Slope: The proposed change to 1:6 slope would eliminate our Passport model due to the bus design. This is a purpose built bus on a GM 5500 chassis that offers a low floor design in diesel, gasoline, CNG & LPG at less cost than the conventional rear engine low floor design.
ElDorado National is very concerned that these proposed changes will result in transporting fewer passengers per bus. Transit agencies would be forced to run additional buses to meet the growing ridership with increased costs and increased emissions. These proposed changes could be devastating with the current status of deficits in most State and Federal budgets. We would recommend that smaller buses have different requirements than 40’ bus have.
Sincerely,
Tony Wayne
President
ElDorado National California, Inc.
Click here to see the attached file.