San Joaquin Regional Transit District, Jean Folleta and Marla Livengood
San Joaquin RTD /
P.O. Box 201010 / Stockton, California / 95201
209.948.8516 [fax] / www.sanjoaquinRTD.com
Board of Directors / Chair, D. David Smith / Vice Chair, Joni Bauer / Duane Isetti, Floyd H. Weaver, Anthony H. Stevens
General Manager / CEO / Donna Kelsay
June 11, 2007
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board 1331 F Street NW, Suite 1000
Washington, DC 20004-1111
Re: Comments to Access Board Docket Number 2007-1
Dear Madam Chair and Members of the Board:
We are writing on behalf of the San Joaquin Regional Transit District (RTD), which serves San Joaquin County, California, to express our concerns about the proposed revisions to the ADA Accessibility Guidelines for Buses and Vans.
Our concerns include:
- We encourage you to reconsider the abandonment of the current definition of a common wheelchair (30" x 48" and not exceeding 600 lbs including the passenger). Leaving the matter open-ended would mean that transit systems like RTD would need to make a case-by-case determination of every wheelchair user and each vehicle we operate. This would not be practical and would be costly; not to mention the considerable impact to overall operations. Additionally consumers would have no standard in which to reference.
- The requirement that all vehicles longer than 22' must be equipped with an automated stop identification system that includes both visual and audio announcements will mean that even the smallest transit system will need to equip their vehicles with GPS in order to make the automated systems work. This provision, particularly for rural providers with flag stops, will be very problematic.
- The proposal to change the definitions for compliant boarding ramps from a maximum slope of 1:4 to a slope that does not exceed 1:8 means that ramps will have to be twice as long as they currently are and the devices will need to have a bi-fold or other more complex mechanism. These modifications will make it very difficult to deploy the ramp at many stops.
- The proposal requires that all vehicles have doorways and a clear pathway to the securement location that is at least 36" wide, and also ramps and lifts 36" inches wide. Not only would this requirement make nearly every current full sized bus and all minivans non-compliant, we fear that this dimension would limit the seating capacity of the small buses we use in our neighborhood service to the point that we could no longer run such vehicles.
- We believe that the phase-in period of the proposed changes needs more attention. Systems need to be given the opportunity to operate a mix of “old rule” equipment and newer fully-compliant vehicles.
Thank you for the opportunity to comment on the proposed Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans.
Legislative Affairs Manager