I believe the following "Sec. T203.3.1 Large Vehicles. On vehicles more than 6.7 m (22 feet) in length, at least two wheelchair spaces shall be provided." should be amended and this measurement of length should be changed from the overall vehicle to the actual body length of the bus on cutaway and chassis cab mounted bodies. The chassis Bumper to Back of Cab dimension seems to continually grow, placing more units in this classification.
I believe that a forward control chassis should use the overall dimension, but that bodies built on cutaway chassis changed to some reasonable body length more in line with an interior dimension comparable to that of a "flat nose" or forward control chassis where th driver is placed at the very front of the unit, thus allowing more passenger area.
If left unamended, this requirement places bodies that are little more than 12 feet long over the 22 feet threshold. I believe this places undue financial burden on purchasing agencies at a time when all governmental budgets are severely limited. The verbiage calls these "large buses" and the logic of the additional wheel chair position in a "large bus" is certainly sound. It is simply my belief that as worded this unintentionally places quite small buses in the large bus category, thereby requiring agencies to increase their fleet size to deal with passenger loads that are increasing due to economic and fuel price factors.
Coupled with the new guidelines for circulation paths and maneuvering room, passenger capacity will be reduced, regardless of attempts to show foldaway or flip seats as options.
I would suggest an outside body dimension of greater than 170" before requiring the second position, or increasing the overall bumper to bumper reference from 22 feet to 23 feet 6 inches.