CyRide, Sheri Kyras
Dear Madam Chair and Members of the Board:
The purpose of this letter is to describe the affect that the proposed revisions to the ADA Accessibility Guidelines for Buses and Vans would have on the Ames Transit Agency (CyRide). CyRide is a small Iowa transit system serving the community of Ames and students of Iowa State University. The system has a total fleet of 66 vehicles and peak hour bus requirement of 47 buses. The average age of the fleet is more than twelve years with CyRide currently operating vehicles in excess of 35 years of age as it has been financially unable to purchase newer vehicles.
As a small transit system, the proposed accessibility guidelines would have a significant impact on the transit system and its ability to operate the level of service currently enjoyed by its residents. Specifically, CyRide is concerned with the following proposed guidelines:
- The elimination of the common wheelchair definition would have a large financial impact upon the transit system by requiring fleet accessibility plans for each individual user. CyRide has a small administrative staff (5 individuals) making this virtually impossible in a university transportation setting as the student population is extremely transient.
- The proposed changes should be prospective as opposed to retrospective and require that only new vehicle purchases after a certain date meet the new guidelines as was the phase-in period under the current requirement. With the extreme age of CyRide’s fleet, the local financial commitment could not be supported and CyRide’s federal formula funds would not come close to funding such a requirement.
- The requirement for automated stop announcement technology which operates from GPS technology is also cost prohibitive for small transit systems from its initial purchase to its ongoing maintenance which can require substantial technical expertise and time commitment to properly operate the technology. CyRide has had a desire for this technology for several years, but has been unable to secure funding without reducing service levels to accommodate this large technology expense.
A recently completed statewide study of GPS needs found that it would cost CyRide approximately $1,600,000 to equipment the fleet with this technology. Additional operating costs would also be incurred which could not be accommodated by the operating budget. Applying this requirement to transit systems serving populations under 200,000 is cost prohibitive.
- The requirement for 36” clear doorways and pathways would render the entire CyRide fleet in non-compliance with the proposed regulation. CyRide questions the logic behind this requirement as this has been a non-issue for disabled customers in Ames, Iowa. Again, this may be an issue for larger urban systems with over 200,000 population.
Thank you for the opportunity to comment on the draft revisions. We look forward to further investigation of these issues prior to modifications of the ADA Accessibility Guidelines.
1700 W. 6th St.
Ames, Iowa 50014
Tele: (515) 239-5563
FAX: (515) 239-5578