Madam Chair and Members of the Board:
Pierce Transit is submitting these comments in response to Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans published April 11, 2007, comments requested by June 11, 2007. Pierce Transit is a public transportation agency providing fixed route and paratransit services to the City of Tacoma, Washington and a number of outlying incorporated cities and towns as well as parts of unincorporated Pierce County. The agency serves an area of 414 square miles and a population of approximately 773,500. We appreciate the opportunity to comment on the proposed revisions to the U.S. Access Board’s ADA Accessibility Guidelines for Buses and Vans.
1. You requested comments on the feasibility of the proposed requirement that there be a route from the bus or van entrance to the securement locations with a minimum of 36 inch width. Pierce Transit currently operates satisfactorily with a 32 inch minimum width. We are concerned that a 36 inch width is not achievable with current bus designs, specifically noting that the wheel well in the low floor bus design limits the available aisle width.
2. You requested comments on raising the required weight for lift and ramp specifications from 600 lbs to 660 lbs. We support this increase but note that increases in weight carry with them the likelihood of more on the job injuries.
3. You requested comment on establishing the maximum slope of ramps at 1:8 in all cases, including when deployed to the roadway. We do not believe that the mandated slope ratio is feasible in situations where there are no curbs/sidewalks or a raised boarding area. Much of our service area does not have curb/sidewalks. Under ideal circumstances a ramp measuring 8 ft. long would be required to meet these criteria. Several practical issues arise as a result. Often, there is not 8 ft of depth to work with from the face of the curb or edge of the roadway to deploy a ramp of that length. The structural challenges of constructing and stowing such a ramp also capable of a design load of 660 pounds is likely not cost effective. This leads in a direction of retuning to a lift type mechanism, which, in our view, is a step backwards for accessibility and reliability. A third alternative, at significant agency expense, requires building raised boarding platforms at stops without curbs/sidewalks. It should be noted that all such boarding platforms would have to be constructed in other jurisdictions’ rights of way as all locations controlled directly by Pierce Transit are already constructed with raised platforms. The option of adding boarding platforms places a very large financial burden on this agency and implies many issues of jurisdictional coordination and engineering.
4. You requested comment on whether the Society of Automotive Engineer (SAE) standard would be better than the current stand which requires that a vehicle must have securement devices, seat belts and shoulder harnesses to be considered accessible. We do not recommend that the SAE standards be adopted as the SAE standards specifically apply to fixed seating applications and may not be appropriate for a secured mobility device application. Either the performance standards of 49 CFR 571 or a standard specifically written for the security mobility device application would be more appropriate.
5. We would also like to comment on section (d) Securement devices, subsection (2) (i). This section stipulates that bays should be 36 inches minimum width where the depth exceeds 24 inches. This is currently not achievable because this amount of protrusion into the isle (current low floor bus fleet) would create a hazard for boarding other passengers. In addition, currently available securement devices were not designed nor have they been tested for the sideways transport of passengers as depicted in Figure 1. It is not feasible or advisable to transport passengers in this orientation.
6. We are concerned about the abandonment of the definition of a common wheelchair. The definition provides a reliable measure for transit operators. Without the definition, we are open to liability as a result of uncertainty over the definition and what is acceptable. We support the APTA position that the Board should clearly state its goal of accommodating wheelchairs that fit in the 30" by 48" minimum envelope.
7. We are very concerned about the prospect of operating for a number of years with a “mixed fleet”, i.e. buses that meet the old standards and buses in compliance with the new standards. This will result in a situation where a person in a wheel chair may not have confidence that a full round trip will be accessible. Standards should not be changed unless we are clear of the long term benefits as the phase-in period, which can be up to 12-14 years, will create hardships for passengers and public transportation operators alike.
Thank you for this opportunity to comment on the draft revisions.
Lynne Griffith, CEO
P.O. Box 99070
Lakewood, WA 98499-0070