Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
Re: Comments to Access Board Docket Number 2007-1
Dear Madam Chair and Members of the Board:
I am writing on behalf of Hall Area Transit (HAT), the transit system serving Hall County, GA and the Cities of Gainesville, Flowery Branch and Oakwood, to express our concerns about the proposed revisions to the ADA Accessibility Guidelines for Buses and Vans. Each of the changes will greatly affect the size and usability of our fleet. Currently our county wide fleet is seven vehicles however with the changes we would need to increase our fleet to 9 vehicles just to carry the same number of riders. As we all know the expectation is we need to prepare for greater numbers of riders and dwindling financial resources to provide for them. This would greatly diminish our ability to meet the communities need for service
We have three primary issues:
1. We encourage you to reconsider the abandonment of the current definition of a common wheelchair (30” x 48” and not exceeding 600 lbs including the passenger). While we recognize that the current definition may need to be revised, we fear that leaving the matter open-ended would mean that transit systems like HAT will need to make a case-by-case determination of every wheelchair user and each vehicle we operate.
2. The proposal to change the definitions for compliant boarding ramps from a maximum slope of 1:4 to a slope that does not exceed 1:8 means that ramps will have to be twice as long as they currently are and the devices will need to have a bi-fold or other more complex mechanism. Such a long ramp at many of our stops would be very difficult to use.
3. The proposal requires that all vehicles have doorways and a clear pathway to the securement location that is at least 36” wide, and also ramps and lifts 36” inches wide. Not only would this requirement make nearly every current full sized bus and all mini-vans non-compliant, we fear that this dimension would limit the seating capacity of the small buses we use in our neighborhood service to the point that we could no longer run such vehicles.
Thank you for the opportunity to comment on the proposed Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans.
Janice a Crow