Wisconsin Department of Transportation, David Lowe
June 11, 2007  [via Email]

Revisions to ADA Accessibility Guidelines for Buses and Vans
June, 2007

Definition of “common wheelchair” removed

The presence of a definition has allowed transit system and paratransit providers to
refuse service to certain oversized or     unusual mobility devices.  Our system allows
mobility devices that do not fit the definition of “common” to be transported; however, if we run into an unusually large device (i.e. a recliner on wheels) or one that cannot access the securement area, we invoke the “common wheelchair” regulation. I would suggest leaving the definition of a “common wheelchair” and adding language to the effect that a larger mobility device that can access the securement area and be safely transported must be accommodated.

Adds a measurable path at least 36” wide from boarding area to securement area from floor level to a height of 40”

Seems to conflict with the language that specifies “an unobstructed volume …30 inches wide minimum”. Our current vehicles are 102” wide, outside dimensions. Distance through door and between wheel wells is just under 36” The wider widths may be achievable for buildings and sidewalks; however, they are not necessarily practical for inner-city vehicles. The larger securement areas and aisles also make for less passenger seating.

Changes design load of the lift/ramp from 600 to 660 pounds

Drivers are expected to provide assistance to passengers with loading, unloading, and securing passengers in wheelchairs. There is already a concern with drivers who are physically unable to maneuver a manual wheelchair at or near 600 pounds (the current limit and equipment rating). This rule would compound the problem, putting drivers at a greater risk of injury. There would also be more stress on the equipment.

Changes ramp slopes as follows to 1:8 for all ramps

Likely to be an issue for lowered-floor vehicles, requiring longer ramps. Longer ramps would make access to certain stops difficult. It may also necessitate changes to the standards for bus stops/shelters (widths and clearances)

Changes “common wheelchair” to “wheelchairs and mobility aids which can enter and maneuver within a vehicle” complying with this subpart.

See comment on “common wheelchair”. I do like leaving the door open for larger wheelchairs/scooters that can enter and maneuver into the securement area. I do not like the vague term of “mobility device”. Likely to mean that more unusual mobility aids will have to be accommodated, and these are likely to be more difficult to secure safely. i.e. A passenger with a Segway claims a disability and requests to bring it on board, even though it cannot be secured or transported safely.

Change
Requires that vehicles longer than 22’ used in fixed-route service with multiple stops must have an automated stop announcement system

New requirement—will add expense to the cost of all FR buses

Change
Requires that “same or equivalent information included in automated stop announcements shall be provided in a visual format.”

Additional expense

Change
Requires characters on head signs to be 4” in height and on boarding side signs requirement for boarding side.

Head sign requirement was 2” with no requirement for boarding side - slight cost increase. Will not be able to convey as much information in as short a period of time.