1) On page 13 of the draft, Advisory T203.9, it says that seat and shoulder belts are provided for the 'convenience' of passengers occupying wheelchair spaces. The term "convenience" is inappropriate and incorrect. These belts, that must comply with applicable parts of FMVSS 209 and 210 per T404 are clearly made available for the "safety" of passengers who wish to use them, not the convenience of these people.
2) On page 24, T403.1 General, it says that "Securement systems shall be automatic or easy to operate by a trained person." The terms "easy to operate" and "trained" are vague. Is a four-point strap tiedown, which is the most universal way of securing forward-facing wheelchairs "easy to use?" Are some four-point strap tiedowns easy to use and some aren't? What constitutes someone who is "trained?"
3) The securement forces in T403.2.1 for large vehicles are too high while those in T403.2.2 for small vehicles are too low.
4) On page 25, T403.3 Movement, the term "normal vehicle operating conditions" is vague. Levels of vehicle acceleration or deceleration and their durations should and can be specified for different directions (lateral and longitudinal) based on data from several studies. Specifying these values will make the test verifiable.
5) The Advisory T403.3 Movement states that securement systems are provided for passengers who "want" their wheelchairs and mobility aids secured. This is a big change from the current version which encourages every reasonable effort to be made to effectively secure the wheelchairs. The current language was subsequently superseded by the FTA when it indicated that transit agencies could have written policies either requiring wheelchair securement or allowing wheelchair securement to be up to the individual user. However, the option of allowing transit providers to require wheelchair securement needs to be continued. Requiring wheelchairs to be secured is in line with the Access Board's claim that the the Access Board's stated primary purpose of these transportation guidelines, which is to achieve equivalency with people traveling seated in the vehicle seats that are fastened to the vehicle floor (rather than to insure the safety of the wheelchair-seated traveler).
6) T403.4 continues to allow only rearward-facing wheelchair stations in smaller vehicles. This is exactly backwards. Rearward-facing wheelchair stations should not be allowed in smaller public vehicles where the likelihood of a significant frontal impact is higher than in larger vehicles and where the likelihood of a vehicle-anchored head rest being in close proximity to the wheelchair passenger's head is small.
7) T403.5 Padded Head Rest provides dimensions for the location and size of this structure and the Advisory that follows states that the purpose of this head rest is to reduce the possibility of whiplash. This is inappropriate. The purpose of a forward structure for rearward-facing wheelchair passengers should be primarily to contain/restrain the wheelchair from forward movement and this requires considerably different dimensions that a head rest to reduce the likelihood of whiplash. Whether a portion of this structure extending up to the back of a passenger's head will do anything to reduce the risk of whiplash injury is highly dependent on the wheelchair design, on add=on wheelchair components, and on baggage that the wheelchair user may be carrying on the back of his/her wheelchair.
8) A rear-facing wheelchair passenger station is really a wheelchair "containment" station rather than a wheelchair securement station. The term "containment" should be used when referring to these rear-facing stations, rather than using the term "securement" to generally refer to both rear-facing and forward-facing wheelchair stations.
9) In T404, the "applicable" requirements of 49 CFF 571.209 and 210 should be specified. What specific parts of the FMVSS apply?