Please find comments from Motor Coach Industries, Inc. in the enclosed attachment.
January 21, 2009
BY EMAIL AND
BY OVERNIGHT DELIVERY
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, N.W. Suite 1000
Washington, DC 20004-1111
RE: Comments to Access Board Docket Number 20007-1
Dear Chair and Board Members:
Motor Coach Industries, Inc. (MCI) is pleased to have the opportunity to comment on the draft revisions to the “Americans with Disabilities Act Guidelines for Buses and Vans” of November 19, 2008 at FR 69592.
Motor Coach Industries, Inc. is the nation’s largest manufacturer of Over The Road Buses (OTRB’s) and has been pleased to have constructively contributed also to the Board’s original development of accessibility guidelines for OTRB’s. We look forward to continued dialog.
At this time, we offer comments on two broad topics, followed by detailed item consideration which will be identified by applicable paragraph numbers.
A.) Definition of “Common wheelchair and mobility aids”
MCI suggests that this definition is an indispensible part of the “Guidelines” as it is absence will cause ambiguity of the detailed design, construction and reasonable use requirements, especially for OTRB’s.
B.) Differentiation of typical OTRB’s
Secondly, we find that inclusion of OTRB’s in a now broad category of buses and vans creates conflicts with conventional ORTB designs and configurations. One must consider that most OTRB’s are engaged in service applications that are distinctly different from the short range, repetitive route service of transit buses and vans. Please consider that the predominant business engagement of OTRB’s is in charter and tour work, where an OTRB may not repeat its route and stops for long periods of time, if ever.
MCI’s detailed paragraph comments are as follows:
T104.4 Defined Terms
Remanufactured Vehicle: Please be advised that due to the very long life expectancy of OTRB’s (Which can exceed twenty (20) years), a substantial mid-life overhaul is not uncommon. Confusing this work with remanufacture (and reman requirements as proposed) would unnecessarily diminish such important work and could also cause obsolescence.
T203.2.2 Additional Requirements for Level Boarding Systems
This is not a practical or reasonable requirement for OTRB’s which may also on occasion utilize the same level boarding areas.
T203.12 Automated Route Announcement Systems
T203.13 Automated Stop Announcement Systems
Clearly, the requirements of the paragraphs are an unnecessary feature for the normal and frequent charter and tour service of OTRB’s.
T 203.7 Handrails, Stanchions, and Handholds
In the OTRB market there is a distinction between those vehicles utilized primarily in traditional tour and charter service and those utilized primarily in suburban commuter service.
A) Tour and Charter: Handholds on each aisle side seat back have not found favor among operators and passengers as their use has been perceived as an invasion of the respective seated passenger's zone of privacy.
B) Suburban Commuter: Hand holds mounted on the top of the aisle side seats, inboard of the aisle are relatively common as standees can be found riding those coaches. Alternating right-hand, left-hand installations on every other seat have also been found to be acceptable as they allow the passenger grab RH then LH as they proceed their way down the aisle. This alternating pattern has the added benefit of spreading the standing passengers out more evenly along the length of the aisle.
For either application, stanchions along the center aisle would either encroach upon the industry's standard fourteen (14) inch aisle width, or they would reduce passenger seat width. Also we urge cautious consideration that stanchions along an OTRB's center aisle may well be disadvantageous in a high speed crash situation.
T302 Lift Requirement
Please note that these guidelines are subject to FMVSS 403 requirements.
T302.4 Emergency Operation — Manual Operation
Permissibility of manual wheelchair lift door operation from inside and outside may create a dangerous feature on the high speed capable OTRB’s, especially in conjunction with the requirements of T805.3.
T302.5.4 Threshold Ramps and T802.5 Surface Discontinuities
The beveled edge requirement conflicts with the important existence of the door guidance and securement track at the bottom of the wheelchair lift portal.
T303.11 Gaps (at Bridge Plates)
The decrease in the allowable gap from 5/8” to ½” is troublesome, especially with increased lift loading. This is due to the normal flexing of the weight conscious lift designs we enjoy today. (See also T802.3 requirements).
T402.4 Size (Wheelchair Space)
This text should also include seats designed to afford wheelchair position space by sliding and locking in two (2) or more positions.
T402.4.1 Front and Rear Approach
Whereas the extended space requirement can be accomplished with some structural redesign, it would result in diminished seat spacing. MCI’s wishes to note that there have not been any reports of inconvenience expressed by our customers with the present configuration. Please note also that the typical six inch (6”) front to back, nine inch (9”) high floor (kick) space afforded by OTRB’s seats forward of the wheelchair position is historically and should continue to be included in the available space measurement.
This restriction of movement would prevent challenged passengers with the ability to rise up and out of their wheelchair from moving their mobility device so that they could stand up and move down the aisle to utilize the on-board lavatory.
T505.4 Circulation Paths
As discussed previously, MCI does not recommend this. Limited handholds/rails as configured now along the ceiling parcel racks as well seat back hand holds serve well to facilitate stable passenger movement down the OTRB’s aisles. Encroachment into the OTRB’s normal fourteen inch (14”) aisle is not favored, nor is the reduction of seat width in the long distance travel market for OTRB’s.
T704 Automated Route Announcement Systems
T705 Automated Stop Announcement Systems
This should not apply to OTRB’s due to the distinctively different tour and charter service previously cited.
T706.2 Stop Request
T805.2 Operable Devices
Please consider that the priority seating spaces include aisle side seats where the stop request switch is appropriately in the overhead parcel services module the same as on an aircraft.
T802.5 Surface Discontinuities
This proposal exacerbates the effect of discontinuities and surface rise as it effectively increased the vertical dimension or a bridge plate transition area as it bridges the door track area.
Ease of Operation is not always desirable especially for emergency egress equipment were conscious effort is a desirable safety feature.
Thank you for the opportunity to comment and we look forward to dialog as we consider the issues of lead time to accomplish the work necessary as we approach the final definition of the requirements.
MOTOR COACH INDUSTRIES, INC.
Michael P. Melaniphy
By: Michael P. Melaniphy
Vice President, Public Sector
c: Harold Zuschlag, MCI
Timothy Nalepka, MCI
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