Please see attached response to proposed rulemaking for Docket number 2007-1.
Mechanical Engineering Manager
January 19, 2009
Office of Technical and Transportation Barriers Compliance Board
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
Subject: Gillig LLC comments to Access Board Docket Revisions November, 2008
Docket number 2007-1, RIN number 3014-AA38
Attn: Dennis Cannon
Dear Mr. Cannon,
Gillig LLC appreciates the opportunity to provide comments on the Architectural and Transportation Barriers Compliance Board’s Draft Revisions to the proposed ADA Accessibility guidelines for Buses and Vans published November 19, 2008. Gillig previously commented on the earlier proposal in June, 2007.
Gillig is a manufacturer of heavy duty buses, primarily for transit operations. Gillig is a privately owned company and produces about 1300 heavy duty transit bus a year and employs over 750 people.
The Proposed Revision has very significant vehicle implications.
Gillig manufactures a variety of bus models to support the public transit vehicle market of the United States. Our review of the draft revisions reveal that several of the smaller models that are typically used by small transit properties or on more rural route structures of larger properties, would be eliminated by these requirements. Specifically, 96 inch wide transit buses which are simply not wide enough for the spatial accommodations required for entry and aisle width requirements in T502. Also, other smaller designs would require redesign of the entire vehicle.
We believe the proposed changes were not researched in the area of how the Revision would impact existing vehicles and some of the implied extraordinary changes that will be required to accommodate the Revision. The changes to the vehicle vary from minor issues, to those that require extensive redesign and to others that would effectively eliminate certain bus models that do not have the spatial requirements to meet the proposed regulation. It appears that the ADA requirements for buildings are being imposed on vehicles without due consideration of the vehicles that are involved and the space claims for drivers stations, fareboxes, and wheel wells in low floor design buses. The result could impact manufacturing businesses and jobs in a very adverse manner
Smaller transit buses would be eliminated
Our analysis of the proposed regulations (T402) shows that low floor buses smaller than 30 foot would be eliminated because of the new length requirements for parallel approach bay dimensions. In this bus the low floor section is predicated by the wheel base which drives the overall length of the bus. The Draft Revision would require a 2 foot increase in bus length which is a whole new design that would then require Altoona test — a very costly and time consuming process. It would also yield to the end user a larger, heavier, less maneuverable, and more expensive bus that would be more difficult and costly to operate. In some cases Union contracts require higher driver salaries for vehicles longer than 30 feet. We believe these are unintended but damaging consequences of the proposal.
In all of our other bus models there would be a minimum of a 10% reduction in the number of seats available do to the spatial requirements. On one bus model there would be a 22% reduction in the number of passenger seats.
T502 requires a clear 34 inch path to the mobility aid position. This would require the redesign of all buses for a larger front door from the current 30 to 32 inch door opening-if it includes the door opening. Due to the length laws in place these would be all new vehicles with less occupant space. The result is a large design project and tooling costs for manufacturers along with the required series of Altoona tests and the cost of model changeover — several million dollars worth of expenditure for each manufacturer.
The aisle width is problematic over the range of vehicles existing and the huge cost of vehicle redesign to accommodate a clear 34 inches thru the door and to the mobility aid position. We do have a few customers that have us test aisle access with a 30 inch wide by 48 inch long by 30 inch high box with 11/2 inch radii on all corners equipped with casters. We roll this box in the bus and to the mobility aid area. It should be noted not all buses will accommodate this- the customer has to compromise on a small fare box and other details. This is simply their approximation of the 30x48 inch required space and attempts to simulate some mobility device. We know of no mobility aids that are like it. We suggest researching and adapting a standard as seen in FMVSS and other regulations where standardized test sleds etc. are defined. Gillig believes the definition of the common wheelchair or mobility aid is required. The ever increasing variety and size of mobility devices challenge the intent of the guaranteed access and securement provided by the ADA as applied to vehicles. The deletion of the definition of the “common wheelchair” does not solve this contentious issue.
Proposed section T302.4 requires doors which must be opened to allow the lift to operate have interior and exterior manual releases. Bus door systems are typically only operated from inside the bus. We believe this is a potential security problem and requires redesign of door systems.
Proposed Section T203.12 requires automated stop announcements. This equipment is not only very costly but it is technically very challenging for all transit operations to implement. Many of the smaller and rural properties simply do not have the resources to deal with this additional complexity and we question if the need has been proven. We would recommend a fleet size threshold for this part of the proposal. There are no specifications as to the quality of announcements.
T203.7/T505.5 requires handholds on all aisle side seat backs. Not all transit buses use low seats that accommodate grips. Suburban and commuter buses use high back recliners as used on over the road coaches and these grips are not appropriate
on that type of vehicle.
T802.2 requires the use of slip resistant surfaces without definition or specification. A specification is required. Excessive slip resistance causes stumbling.
Gillig appreciates the opportunity to provide these comments, and we remain available to provide any further assistance on the evaluation of these drafts. However, Gillig is very concerned about the adverse impact this Revision will have on existing and future vehicle designs and about the very significant cost of compliance.
Manager Mechanical Engineering
cc: B. Macleod
Click here to see the attached file.