June 11, 2007
Dear Access Board Representative:
We are concerned that the proposed revisions to the ADA Accessibility Guidelines for buses and vans may actually reduce fixed route transit options for everyone. Any reduction in fixed route transit would adversely affect people with disabilities who use any mode of public transit.
First, it is important to maintain a definition of a “Common Wheelchair” so that there is a consistent level of understanding of what dimensions can be accommodated in any transit district in the country. This ensures nationwide access to public transit for those of us who use mobility devices. It also provides some guidance for manufacturers and purchasers of mobility devices. All mobility devices cannot be accommodated on public transit vehicles and many larger devices actually limit indoor mobility in homes, stores, restaurants, etc. An increase in weight to 660 pounds along with the removal of the number of wheels that a “common wheelchair” has would provide sufficient guidance and allow for newer mobility aids such as Segways or IBOT.
In addition, the practical implications of the proposed changes in aisle width, turning radius, and storage requirements for new vehicles cannot be overlooked. Transportation entities are regulated by a number of federal agencies. Recently, new clean diesel regulations required the installation of an exhaust burning system that in application will eliminate at least four passenger seats on every bus. The new ADA regulations would also likely eliminate a minimum of four passenger seats per bus. The combination of the two regulations would result in the passenger carrying capability of a standard 40-foot bus being reduced to that of a 35-foot bus.
On many bus lines the size of the bus selected is based on passenger load conditions. Many properties design the fixed route systems based on internal service standards, which include geographical, travel time, and passenger comfort criteria. When system capacity levels reach maximum levels, transportation officials face a choice of two difficult alternatives:
Add buses / Decrease headway times – or
Lose potential ridership, and public confidence in the system’s ability to serve.
Many operators are functioning under significant local funding constraints, and cannot absorb the additional costs of increasing the amount of rolling stock on the street on a regular basis. Many therefore seek lesser performing routes to eliminate in order to better serve those routes where significant demand exists. This has the effect of reducing the footprint of the system with significant impacts to both fixed route riders and those who utilize complementary Paratransit service, which is based on the ¾ mile boundary around fixed route service that is required in the ADA regulations.
It will take considerable time to replace vehicles to meet the proposed standards. In places such as St. Louis, rolling stock was designed to achieve the standards set forth in the ADA regulations. A high percentage of our rolling stock is less than midpoint in its anticipated 15-year lifecycle. It will take a full 15 years to integrate these new requirements into our fleet. For customers using larger mobility devices, this will make seamless travel on transit impossible, as some vehicles will be able to accommodate them while others will not. If these regulations are adopted, the new requirements should not become mandatory until such time that all rolling stock will have achieved its normal life cycle and can be replaced with equipment necessary to achieve the regulatory objectives.
The requirement that automated audible and visual bus stop and major cross street announcements is something that many transit systems, including Metro St. Louis are striving towards. This is the only way to ensure consistent announcements, but again, there are several factors that must be considered. These systems usually are part of an AVL (Automatic Vehicle Location) system, which includes a GPS navigation system as well as a basic on board knowledge of both the street grid and bus route the unit is operating on.
The communications infrastructure necessary to support the operation of these systems is not insignificant. These systems usually involve voice over data transmission equipment, and whole new Communication System and Information Technology backbone equipment. Again other federal agencies are requiring interoperability with emergency (fire/life safety) as a basic requirement in obtaining funds for new communications equipment.
This means that not only do transit companies need to apply for multi-year grants for new system funding, but that they can only proceed as fast as their new partners in the emergency services arena.
In addition, the FCC has been issuing new standards for operating frequencies used by many transit companies. In most cases, their needs to be a series of communication channels “cleared” in order to make room for the new public institution radio frequencies. In some transit companies such as Metro St. Louis, the unit operates within or next two different FCC districts. The complexity of bringing up new radio systems in such areas cannot be understated. All told, the cost of providing the communication networks necessary to have a fully functioning AVL system capable of providing the automated on-board messaging in the St. Louis market is in excess of $30 million dollars, and will take a minimum of four years to complete.
Metro has a plan and is currently seeking a Letter of No Prejudice from FTA in developing this communication network. The majority of the funding will come from formula funds over a 6-year period. This represent a substantial portion of our capital budget going forward and will require many other worthwhile projects be delayed or eliminated in order to achieve the goal.
Metro is committed to developing the complete infrastructure once adopted. The mobility of people with disabilities across the country will be impacted for many years until all vehicles can meet the proposed standards. Unfortunately less transit options for people with disabilities may ultimately be available due to costs and loss of seating capacity associated with the proposed regulation change.
Sincerely,
Patricia Hall
Director of ADA Services
Raymond Friem
Senior Vice President – Transit Operations