June 11, 2007
June 11, 2007
DOCKET 2007-1
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 “F” Street NW, Suite 1000
Washington, D.C. 20004-1111
Re: Comments to Access Board Docket Number 2007-1
Madam Chair and Members of the Board:
ElDorado National, California offers both 96” wide conventional floor buses and 102” wide low floor buses. Each style of bus requires different considerations for handling the requirements of the persons with disabilities community.
Therefore, we are responding to your comments on the draft revisions to the guidelines for each vehicle type as follows:
A. 96” Conventional Floor Bus
1. If the vehicle is equipped with a front door instep lift, the widest access we could provide between the wheels is 34”-35”. The requirement for 36” would be impossible. Furthermore, in order to provide the 34” – 35” access, we would need to eliminate the passenger seats over the wheels and reduce overall passenger capacity.
2. Vehicle Lift Design Load – The commercial buses that ElDorado National produces are accessible for persons with disabilities. These buses are designed with Level change mechanisms for loading and unloading persons with disabilities. Last year, Federal Motor Vehicle Safety Standard 403 promulgated regulations which specify standards for vehicle lifts. A great deal of time and effort went into the development of this particular standard, and the design load for these lifts was set at 600 lbs. We believe that although the 600-lb. design load may not be ideal, all Federal Standards should maintain continuity and recommend that the lift design load be revised to be in line with the Federal Motor Vehicle Safety Standard (FMVSS) of 600 lbs. which already covers the safety aspect of this important accessibility equipment for vehicle lifts. Most providers have already tested to this FMVSS requirement, and we believe additional testing would put an undue burden on the lift manufacturers and installers, and would increase the cost to the end user.
3. Removal of the space allowed under the seats and panels, and the extension of the securement area will cause elimination of seated passengers in some seat design configurations.
B. 102” Wide Low Floor Bus
1. With a wheelchair ramp in the front door, the widest access we could provide between the wheels is 34” with flip seats on the wheelwells. With fixed seats on the wheelwells, the widest access we could provide is 30”. The requirement for 36” would be impossible. Furthermore, any requirement over 30” would restrict the seat model we could offer and in some cases eliminate the availability of seats on the front wheelwells, which would reduce the overall passenger capacity.
2. Vehicle Ramp Design Load – The commercial buses that ElDorado National produces are accessible for persons with disabilities. These buses are designed with Level change mechanisms for loading and unloading persons with disabilities. We believe that although the 600-lb. design load may not be ideal, all Federal Standards should maintain continuity and recommend that the design load be revised to be in line with the Federal Motor Vehicle Safety Standard (FMVSS) of 600 lbs., which already covers the safety aspect of this important accessibility equipment for vehicle ramps. Most providers have already tested to this FMVSS requirement, and we believe additional testing would put an undue burden on the lift manufacturers and installers, and would increase the cost to the end user.
3. Vehicle Ramps-Slope – ElDorado National California manufactures accessible transit buses. The buses include a ramp for loading and unloading passengers in wheelchairs and other mobility aids. We provide the ramp in a powered and a manual version. These are folding type ramps that mount in the doorway and fold out to the side of the vehicle. This vehicle provides important access for persons with disabilities for our transit buses. This includes kneeling the bus so we can meet the door height requirement for ADA and provide for the lowest floor possible for ease of loading and unloading non-ambulatory passengers. Appropriate clearance under the vehicle and ramp slope are the main factors that determine ramp length. While ElDorado National understands the advantages of the longer slope on the ramp, we would like to petition the Access Board to consider a less restrictive slope of 1:6. This will improve the present requirement while not making it extremely restrictive.
4. Removal of the space allowed under the seats and panels, and the extension of the securement area will cause elimination of seated passengers in some seat design configurations.
We are strongly requesting your consideration of our concerns with your draft revisions.
Sincerely,
Gentry C. Shaw
Director Transit Sales
GS:sdr