To whom it may concern:
Please accept the comments listed below concerning the draft changes to the ADA Accessibility Guidelines for Transportation Vehicles, 36 CFR Part 1192.
In the state of Kansas, the state legislators in the early 1990"s passed regulations to establish "Coordinated Transit Districts". During the early to mid nineties fifteen districts were formed. Most of the work accomplished in the CTD meetings is education and communication. Much of Kansas is "rural" area and hence the services are provided by individuals that wear many hats and have many various tasks to accomplish.
The Notice of Proposed Rulemaking concerning the Revisions to the ADA Accessibility Guidelines for Bus and Vans has created anxiety among many of these transit providers due to the following factors:
1. The increased insurance costs due to exposure to increased risks.
2. The increased cost of the vehicle to meet these standards.
3. The time it will take vehicle manufacturers to develop a vehicle to the will meet the needs as stated.
4. The increased cost of a larger vehicle to meet these requirements.
5. The loss of fuel economy of smaller vehicles versus larger vehicles.
Additional information to assist in defining the above statements:
Insurance costs have increased greatly in the last five years due in part to the insurance companies taking a closer look at what vehicles with wheelchairs lifts are doing. Insurance companies create ratings via exposure and transporting larger chairs will increase this exposure. Most wheelchair manufacturers state in their warranty materials that the chair is not to be occupied during transit, yet to meet ADA the transit provider is required to provide the requested transportation. Most transit providers, at least in the rural areas, want to assist their friends and neighbors who have mobility issues. And reasonable expectations along with reasonable accommodations has never been a concern. However SAFETY is always on the mind of at least the manager.
The paratransit vehicle manufacturers are continually improving the vehicles. Most transit providers (at least in Kansas) currently take advantage of purchasing the largest lift available which is 34" wide X 53" long versus the ADA minimum which is 30" wide X 48" long. If the size of the lift is increased as drastically as stated in the proposal, the door opening will need to be reconfigured which will mean the whole side of the vehicle will need to change. Any major modifications to vehicles require that a prototype vehicle is manufactured and then taken to Altoona, PA where the vehicle can be tested to the point of destruction. The testing is to ensure safety of the vehicle. Changes are not impossible but they do take a considerable amount of time!
It is possible that to meet the proposed changes but a larger vehicle will be required. This could possibly increase the cost up to three times what they cost now. The proposal that is mentioned for the ramp accessible vehicles will rule out the use of mini-vans. This is because of the door opening requirements and the length of the proposed ramp length being twice as long as current. By eliminating the use of the mini-van, fuel economy becomes an issue.
It is my opinion that most, if not all, transit providers want to provide as much transportation as possible. But there needs to be reasonable accommodations which includes safety for both the individuals needing the transportation and those providing the transportation. To not define descriptions of what is and what isn't accessible leaves most transit providers in a gray area.
I am sure the intent of the proposed rule changes is to advance transportation across the United States. I feel this drastic of changes will doom many of the smaller rural providers. Many of the "rural" services are overseen by individuals that have retired from the corporate world and do something to keep them active. Additional requirements will change this picture!
Ron Straight, CCTM
Transportation Manager, DSNWK
P. O. Box 1016
1205 East 22nd Street
Hays, Kansas 67601-1016
(785) 621-2078 Office
(785) 621-2079 FAX
"I will live in such a way that no one will believe them" - Plato