I believe the Access Board should consider the effects of a long ramp on the bus stop accessibility. Since the passage of the ADA, cities have been constructing bus stop pads to the criteria listed in FTA’s ADA guidelines (specifically the 96 inch by 60 inch clear zone.) If a ramp extends further than four feet into this bus pad area, the area for wheelchair maneuvering will be less than the recommended in the ADA/Access Board guidelines. Cities have invested years and millions of dollars in the construction of what was “known” to be accessible. If lifts/ramps are allowed to extend beyond the four feet dimension, much money and even more importantly, much time will be lost in making our fixed route systems accessible. Overnight, an accessible system could become inaccessible. Customer service inventories of bus stop dimensions become useless as the pad space is not something we have had to measure and record. Just in getting a realistic inventory of what bus stops are accessible with the ramp length will require an inordinate amount of time. As soon as the vehicles with longer ramps begin operations, all bets are off in knowing which stops a person in a wheelchair can use.
I am also concerned that once a new “standard” ramp is created, another will be designed and then another. (We have seen this pattern before, haven’t we?) Do the bus stops have to keep being re-built in order to accommodate bus manufacturer’s limitations?
Also, bus stops are provided by cities, not by transit systems. Currently, cities are governed by DOJ regulations and transit system by DOT. Even if these two regulations are brought into complete agreement, transit systems do not have the legal ability to cause cities to re-build bus stops nor can transit systems invest in bus stops without the cooperation of cities.
I understand the desire to make boarding a bus easier and more comfortable to users of mobility devices and to make the vehicles accessible to an ever increasing number of mobility devices. But I am deeply concerned that in make vehicles more accessible, we make bus stops less accessible thus defeating the overall purpose.
Thank you for accepting comments on this critical issue.
Debra Astin, AICP
City of Scottsdale
7447 E. Indian School Road, Suite 205
Scottsdale, AZ 85251