Golden Gate District, Celia G. Kupersmith
Madam Chair and Members of the Board:
The following is a letter of comment on the Architectural and Transportation Barriers Compliance Board(Access Board)’s Draft Revisions to the Americans with Disabilities Act (ADA) Accessibility Guidelines for Buses and Vans, dated April 11, 2007.
The Golden Gate Bridge, Highway and Transportation District (District) (P.O. Box 9000, Presidio Station, San Francisco, CA 94109) is a State of California special district that operates the Golden Gate Bridge and provides public bus, ferry and paratransit services between portions of the City and County of San Francisco and locations in Marin, Sonoma and West Contra Costa Counties.
As a member of the American Public Transit Association (APTA), this District participated in the development of, and concurs with the comments in, APTA’s letter of comment on the above Draft Revisions sent to the Access Board under separate cover. APTA’s comments can be briefly summarized as follows:
- The proposed changes are insufficiently supported by technical research;
- Section 1192.21(a) would render virtually every existing transit bus and van inaccessible;
- There is a need to address the impact of mixed fleets and paratransit eligibility based on the “original” versus the “new” vehicle standards;
- There is a need for a phase-in period as well as hardship and small fleet exceptions to any automated stop announcement requirement;
- A clear wheelchair definition should be retained;
- There should be flexibility on updated height and securement area dimensions to allow continued use of cutaway vehicles, vans and minivans; and
- The proposed revisions lack definitions for “van”, “similar vehicle”, “bus rapid transit vehicle,” or “minivan.”
This District also has the following additional comments:
- Because of the rapid advancement of technology and the complexity of dealing with fleet changes such as the Access Board is recommending, the Access Board is urged to recommend that the Federal Transit Administration review its 12-year bus replacement cycle to consider something shorter that would allow buses or fleets to be rolled over more frequently.
- Mountainous terrain or reception problems should be included in the list of acceptable grounds for an exception to any Automated Stop Announcement requirement.
- Any definition of wheelchair and mobility aid should include parameters both for size and description to provide a basis for determining which devices can be transported on a vehicle and around which to design accessible vehicles.
- A definition of “minimum back and forth movement” [used in Section 1192.23(2)] is also needed.
- Section 1192.23(d)(3) “Mobility Aids Accommodated” should read: “The securement system shall secure wheelchairs and mobility aids that can enter, maneuver and be secured within a vehicle complying with this subpart…”
- In addition to APTA’s comments that flexibility on updated height and securement area dimensions is needed to allow continued use of cutaway vehicles, vans and minivans, the Access Board should consider that perhaps a “one size fits all” set of standards for all vehicle types might not be the most appropriate. Any new proposed standards should be adjusted based on sound research and should be tailored to the type of vehicle involved (e.g., large bus, small bus, van, minivan). We understand that Canada has adopted different standards for different vehicle types. These standards might serve as the basis for a similar approach in the U.S.
- Ramps are more reliable and easier to maintain than lifts, reducing public transportation costs. However, the proposed new 12% maximum ramp slope requirement [Section 1192.23(5)] would discourage the use of ramps on transit vehicles. Ramp lengths necessary to meet this requirement would leave no space for the wheelchair user to maneuver once he/she got off the bus, even where an 8-foot lift deployment location is available. Furthermore, many bus stops do not have an 8-foot lift deployment location.
- Any final Access Board rules should acknowledge the need for consistent design standards for wheelchair and mobility devices. We understand that these standards are being pursued by a separate Project Action effort, which should be referenced.
- Section 1192.23(a)(2) calls for one route to each securement location to have a clear width of 36 inches minimum. However, in the next sentence, the draft guidelines get much less specific regarding where a turn is required, stating “sufficient maneuvering space shall be provided.” Given the size constraints found on a typical transit vehicle, the Access Board should allow buses to be designed to no stricter standard than is allowed for an accessible path of travel in buildings and facilities. For buildings and facilities, an accessible path of travel can be as narrow as 32 inches through an interior doorway. For buildings and facilities, the width required at a turn is clearly stated as 36 inches.
- Illustrations should be provided to display the standards that are being called for by the proposed guidelines.
Very truly yours,
Celia G. Kupersmith
P.O. Box 9000, Presidio Station
San Francisco, CA 94129-0601
(415) 923-2212 Work
(415) 923-2236 Fax
c: Janet Tarantino
Alan R. Zahradnik
Shayna van Hoften
Cynthia B. Petersen
Bill Millar, APTA