Comments on Draft Revisions to ADAAG for Buses and Vans
The National Center for Accessible Transportation
PREFACE TO COMMENTS
We have reviewed this document as well as comments by some others that people planned to submit in response to this document. It is clear that different people have different ideas about what the ADAAG is supposed to do. Our point of view is that it’s important to stress performance and therefore to avoid prescribing specific solutions as much as possible. We do recognize that we don’t have as much background knowledge on some aspects of this material as do others and therefore may be making comments that are in some respects inappropriate. On the other hand, those comments may be useful in pointing out a need for clarification or explanation in the document.
Also, it is much easier to find fault with documents like this than it is to develop and offer a good alternative. Wherever possible, we try to offer an improvement rather than just point out a problem. However, in some cases we couldn’t come up with anything we consider to be a good alternative. In those cases please consider the pointing out of potential problems to be a flag, not a criticism.
1192.1 Purpose - no comment
1192.2 Equivalent Facilitation - no comment
Designated public transportation - This definition is not clear to us. On first reading it seems to apply to intra-city and excludes inter-city as well as aircraft and commuter rail. It might be clearer to move all of the exclusions (parenthetical phrases) to the end and to perhaps include an explanation that they are excluded because they are covered under different regulations.
1192.4 Miscellaneous Instruction - no comment
1192.21 General - no comment
1192.23 Mobility aid accessibility
(b) Vehicle Lift
(c) Vehicle ramps and bridgeplates
(d) Securement devices
- This is certainly one of the most difficult sections. The variety of chairs, occupant capabilities, and now securement/containment options makes the writing of a guideline to cover all foreseeable circumstances virtually impossible.
- If we understand correctly what is written, this document says that rear facing wheelchairs must still be secured to the same requirements as forward facing but with the additional requirement of having a barrier behind the passenger’s head. This should be stated clearly in the guideline and it should be pointed out that this is very different than the rear facing containment being worked on by several groups and which is currently being used by several transportation providers.
- Because it is already quite well known in the mass transit community, the concept of rear facing containment (for wheelchairs on large vehicles only) should be addressed in this document. If it is deemed inappropriate to provide a guideline at this time, then at least its existence should be acknowledged in this guideline.
- If rear facing containment is to be included then we think it might be useful to re-organize this section into two sub-sections, one for forward facing securement and one for rear facing containment. The intent and specific requirements are different enough that separating them would help keep the requirements clear. A comment might be included somewhere that for a single space to be used for both possibilities, it must meet both sets of requirements.
1192.25 Doors, steps and thresholds –no comment
1192.27 Priority Seating Signs – no comment
1192.29 Interior circulation, handrails and stanchions
(c ) There are no requirements for stanchions to be placed on side facing seats. On large vehicles these are often the most frequently used seats by people with disabilities and also the most hazardous…Some requirement for stanchions for each seat location is needed.
1192.39 Destination and Route Signs
(a) this merely says illuminated but does not suggest a contrast level or basic reading distance say 50 feet.
(b(6)) Contrast it is possible to specify basic Contrast levels…by using the international definition of contrast…