COMMENTS TO PROPOSED ADA RULES
PINELLAS SUNCOAST TRANSIT AUTHORITY
3201 SCHERER DRIVE
ST. PETERSBURG, FL 33716
June 4, 2007
1. The apparent reason for changing the ADA access rule appears to be that there is a problem with the current set of rules. It is the position of the Pinellas Suncoast Transit Authority (PSTA) that there is no problem and the current rules are adequate. It has been our experience that in the twenty months between December of 2004 and July of 2006 we had a total of thirty incidents related to the use of a bus ramp by a person in a mobility device, and only four resulted in a complaint by a passenger. Our records indicate that virtually all of the incidents were the result of the operation of the mobility device by the passenger and that the ramp and ramp angle were not the cause of the problems. During the period within in which we conducted this study, PSTA transported in excess of 80,000 individuals in mobility devices.
RECOMMENDATION – Do not change the current regulations.
2. The proposal to change the ramp angle from the current 1:4 to 1:8 is not viable in the environment of our county and is unnecessary. Most of our bus stops are at curbs and with a curb present, the ramp as deployed to a 5” or 6” curb, is at an angle that is very easily negotiated by individuals in mobility devices. An 8 ft. ramp when used at a curb would require more ROW than we currently have at any bus stop in our county. In areas where there is no curb (commonly called “rural cross sections”) there is not adequate space to deploy a ramp at an 1:8 slope as the ramp would have to be almost 8 ft. long. In most rural cross sections in our county there is no sidewalk and only a narrow area from the edge of pavement to the drainage ditches. To use an 8 ft. ramp on a rural cross section would require that the bus stop several feet into the next traffic lane just to keep the ramp out of the ditches. The PSTA currently has over 6,000 bus stops and to attempt to make everyone suitable for an 8 ft. ramp would be impossible, as at the same time the stops would have to be suitable for the current 4 ft. ramps.
The ramp angle at rural cross sections is essentially a roadway design problem, and not a bus design problem. Presently our agency is in the process of working with our “roadway” partners and there is a “curb retrofit” design for the rural cross sections that greatly reduces the ramp angle. This retrofit is essentially a short section of curb with a 5’ x 8’ landing pad, curb ramps, and a connection to the adjacent sidewalk. In our county we have installed approximately a dozen of the new curb retrofits and have found it to be very effective in enhancing access to our buses.
RECOMMENDATION - Do not change the ramp angle to 1:8. Introduce curb retrofit design for bus stop enhancements. Require these retrofits with rural cross section roadway projects and bridge swales for connectivity to adjacent sidewalks.
3. The proposal to eliminate the definition of a “common wheelchair” and require for wider access would cause every transit operator to have two classes of vehicles; new vehicles with wider doors and aisles and old vehicles with less room. This situation would cause situations where an individual may travel one way on a newer and wider bus and then not be able to get back because an older and narrower bus is on the route. Our position is that there is a problem with mobility devices and it is a lack of standards for defining what a “transit accessible” mobility device is. Bus manufacturers should not be forced to accommodate every possible size and design of mobility device that comes onto the market. The American transit system has billion of dollars invested in meeting the current 30” x 48” access standard and as with the ramp angle issue; it is our position that there is not a problem. We board more than 4,000 mobility devices every month and we have not had complaints about our ramps or our bus doors and aisles not being wide enough.
RECOMMENDATION – Maintain the current size requirements and establish “common wheelchair” standards for mobility device manufacturers, so that all of these devices are “transit accessible”