Razorback Transit 131 Administrative Services Building
155 Razorback Road
Fayetteville, Arkansas 72701
(479) 575-7128 FAX
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
June 11, 2007
Re: Comments to Access Board Docket Number 2007-1
Dear Madam Chair and Members of the Board:
Razorback Transit operates fixed route and demand response for the University of Arkansas and the City of Fayetteville. We have the following comments regarding proposed ADA guidelines for transit vehicles:
Common wheelchair definitions with regard to length and width currently provide reasonable criteria for access to transit vehicles. Some reasonable guidelines need to be in place. There are space and weight limits aboard all vehicles, including buses and vans. Previous legislation recognized that having specific rules avoided “legal interpretation” which necessitated endless court cases and individual judge and jury’s anecdotal “opinions” on what will or won’t fit aboard a bus or van. Not having definitions opens the door to basically unworkable “opinions” for transit systems. There is no opinion regarding length, width and weight. They are measurable dynamics of reality. The basic size and weight of a bus, including length, width and weight are also a reflection of the realities of roads, traffic and materials. Please continue to recognize the operational realities of service delivery and provide the specifics of what is deemed reasonable rather than leave it up to utter neophytes to provide their “opinion” in a court of law. Leadership is required here, don’t abandon us in regard to length and width.
Auto visual and audible announcements are a worthy goal. They must be phased in, however, in a reasonable time frame, so that bus manufacturers and transit properties will be able to recognize that all new buses will need this technology within next twelve year replacement cycle. I would say that operator action to trigger these announcements should be part of the equation as well as recognition that “called stops” will require operator action. GPS technology to trigger these devices is often unworkable in urban environments with tall buildings. My experience is that stop announcement goes up by magnitudes simply by having the annunciator automate the message provision with the operator cycling the annunciator. Wording that allows operator triggering of the automatic annunciation of all scheduled stops, rather than recourse to totally automatic systems will make the legislation work just about everywhere and will reduce the cost and complexity of reliance on gps.
Ramp length, again, is a dynamic of an actual working environment. We can theorize that longer, less sloped ramps would be easier to roll a wheel chair up. When we go to extend that ramp in a real world environment or understand the physical dynamics of supporting a longer ramp for a proposed higher weight we bump against the reality of material strength and environmental limitations. Bottom line is the proposal ramp length is unworkable as proposed. Compromise is required here.
The other dynamics of size and weight require vetting by the bus manufacturers and recognition by the general public. Obviously redesigning bus interiors to fit fewer non ADA seats and narrower regular seats so that bigger and bigger scooters can be accommodated robs Peter to pay Paul. ADA’s guidelines promise a better environment for all of the public. Vehicle size restraints (the legal width, length and weight of a transit bus) mean that all will benefit from ADA legislation if everyone brings a level of compromise to the table. The proposed changes mean a radical redesign of current buses to take seated space for the current riding public for the disabled riding public. This was never the intention of the initial ADA bill.
Thank you for the opportunity to comment.
Very Truly Yours,
Michael J. Seither