Amalgamated Transit Union
5025 Wisconsin Ave., N.W., Washington, D.C. 20016-4139
202-537-1645 / Fax 202-244-7824
Office of the International President
June 11, 2007
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board 1331 F Street, NW, Suite 1000
Washington, DC 20004-1111
Re: Docket 2007-1; Americans with Disability Act (ADA) Accessibility Guidelines for Transportation Vehicles; Draft Revisions to Guidelines
Dear Sir or Madam:
The Amalgamated Transit Union (ATU), which represents over 180,000 members maintaining and operating bus, light rail, ferry, intercity bus, school bus and paratransit vehicles in the United States and Canada, submits the following comments in response to the above-referenced notice of draft revisions to the ADA accessibility guidelines for transportation vehicles.
The ATU has a long history of working with various disability rights groups to advocate for the expansion of transit services and other available transportation options for individuals with disabilities. We have also worked to educate our members on the requirements of the ADA and their rights and obligations under the Act.
The ATU strongly supports the draft provisions which would require certain vehicles to be equipped with automated stop announcement systems and stop request systems. Specifically, we supports the proposed language in Section 1192.35 and 1192.37 of the draft revisions.
Current Department of Transportation (DOT) ADA regulations, found at 49 C.F.R. §37.167(b) and (c), require that stops be announced at transfer points, major intersections. destination points, other intervals along a route, and upon request of any individual with a disability. These regulations are confusing and burdensome for vehicle operators who are already tasked with the safe operation of their vehicle. Well-meaning bus operators can easily be distracted by passengers or traffic and forget to call out stops, or a driver’s voice may simply be drowned out by other passengers or surrounding vehicles.
Compounding the problem even further, opinions differ as to what is considered a “major intersection” or “destination point” and what is considered an appropriate interval along a route. Guidance from transit agencies is often lacking and drivers are left to make their own judgment calls regarding which stops to announce.
The unfortunate consequence is that hearing and vision impaired passengers are denied the level of service they deserve. Without question, these passengers would be best served by taking the burden away from the driver and equipping vehicles with pre-programmed, audible and visible stop announcements. These systems would enable drivers to focus on the road while at the same time allow passengers to find their chosen stop without relying on the judgement of the driver or the volume of the driver’s voice.
The ATU is of course wary of any additional requirements which may pose a financial burden on transit agencies. For that reason, we encourage Congress and the Department of Transportation to make available the necessary funds to allow transit agencies to implement the proposed new requirement.
Thank you for your consideration of our comments on this matter. If you require additional information, please do not hesitate to contact this office.
Warren S. George