Livermore Amador Valley Transit Authority, Barbara Duffy
Dear Madam Chair and Members of the Board:
I am writing on behalf of the Livermore Amador Valley Transit Authority (LAVTA), to express our concerns regarding the Architectural and Transportation Barriers Compliance Board’s Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans, published April 11, 2007, at 72 FR 18179.
Our agency is concerned about the following parts of the proposed legislation:
- We are concerned about eliminating the current definition of a “common wheelchair” (30” x 48” and not exceeding 600 lbs including the passenger). We agree that the current definition may need to be revised, but leaving it undefined will create substantial amount of uncertainty and transit providers such as LAVTA will have to make case-by-case determination of every wheelchair user and each vehicle we operate.
- Under the proposal, compliant boarding ramps could not exceed a slope of 1:8 (from the current 1:4), which means that ramps will have to be twice as long as currently and the devices will need to have a bi-fold or other more complex mechanism.
- The proposal would require that all vehicles have doorways and clear pathway to the securement location that is at least 36” wide. This would require that all ramps and lifts need to be 36” wide as well, which would make nearly every current full sized transit vehicle and all mini-vans non-compliant.
Thank you for the opportunity to comment on the proposed Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans.
Livermore Amador Valley Transit Authority
1362 Rutan Ct. #100
Livermore CA 94551