Central Contra Costa Transit Authority
2477 Arnold Industrial Way
Concord, CA 94520
Office of Technical and Informational Services Architectural and Transportation Barriers Compliance Board
1331 F Street, N.W., Suite 1000
Washington, DC 20004-1111
RE: Comments to Access Board Docket Number 2007-1
Dear Chair and Members of the Board:
The Central Contra Costa Transit Authority (County Connection) hereby submits comments on the Architectural and Transportation Barriers Compliance Board?s
(Board) proposed revisions to the Americans with Disabilities Act (ADA) Accessibility Guidelines for Buses and Vans published in the Federal Register on November 19, 2008.
About County Connection
County Connection provides fixed route and paratransit service to approximately five million riders annually in central Contra Costa County of the San Francisco Bay Area. County Connection uses a combined fixed route and paratransit full accessible fleet of 181 vehicles on an annual operating budget of about $34 million to provide services.
County Connection was the first public transit system in the country to have a fully and completely accessible fleet. This was accomplished well before the enactment of the ADA. And, County Connection was the first transit system in the country to allow standees to use wheelchair lifts to board high floor buses. As a leader in the transit industry on issues of accessibility, County Connection has a unique and well qualified point of view in terms of commenting on these proposed standards.
In addition to endorsing the comments submitted by the American Public Transportation Association (APTA), County Connection offers five additional comments on the proposed standards.
The proposed standards should be the subject of further study and are premature.
County Connection is gratified to see that the Board has made some changes to the proposed standards since publication of the last draft in response to comments submitted. However, County Connection encourages the Board to take some additional time to study what problems actually exist for transit users with limited mobility, determine what options exist to solve the problems, and research ? with the help of transit providers and vendors ? the feasibility of the options that best address the problems.
For example, is there any evidence that requiring a wider path of travel in a vehicle would benefit transit users with limited mobility and, if so, that any width is more or less desirable than another? Next, has the Board considered the potential operational impacts of the proposed standard, such as whether it would require use of rear-door lifts, which could force vehicles to pull into intersections to allow passengers using wheelchairs to board or disembark?
As another example, is there any research indicating that increasing wheelchair lift weight capacity to 660 pounds will be helpful? Would twenty pounds in either direction make an appreciable difference in terms of access and/or feasibility?
Doing such study now, before adopting new standards, could both increase access and save regulated entities from being forced to comply with costly, incremental increases over time.
Any new standards should be prospective only.
When standards are approved, it is important to ensure that they are prospective only. At a time when operating costs are increasing and revenues are decreasing, public transit nationwide faces economic hardships resulting in a combination of fare increases and service cuts. Already, orders for new buses on standard replacement schedules are becoming harder to fund, and adding costs of upgrading buses not scheduled for rehabilitation or replacement would completely disrupt this process, making it increasingly difficult, if not impossible, to maintain a modern, accessible vehicle fleet. Furthermore, a reasonable applicability threshold must be clear in the standards so that vehicles being designed and manufactured now, and in the remaining time before the standards are finalized, are not in danger of being out of compliance before they even enter service.
It would inappropriately hamstring transit agencies if buses built according to standards in place at the time later had to be retrofitted at their mid-life point.
Transit providers regularly extend vehicles? use by rehabilitating them at the mid- point of their expected service lives. Typically, this rehabilitation consists of new brakes, a new engine, and other mechanical upgrades. Rarely, if ever, does rehabilitation allow for structural changes, such as widening of a wheel well.
Requiring any rehabilitation process to bring vehicles up to standards not in place at the time the vehicle was designed, purchased and built could make it impossible for transit operators to use vehicles for their entire anticipated and budgeted service life, and could eliminate or restrict access to federal funds otherwise available for this purpose.
Standards should be consistent across types of facilities.
While some of the standards proposed for revision do not have counterparts in other types of facilities (e.g., the automated stop announcement provisions), there are other standards, most notably the passenger egress standard (the public rights-of-way, or PROW, counterpart), that mirror standards adopted for buildings.
In the latter cases, standards should be consistent across facility types so that standards for buses and vans do not differ from those in place for buildings.
Inconsistency of this type creates problems for our riders, who reasonably expect compliance with existing standards and based on that expectation, may take a bus to a certain destination, but then not be able to enter the building when they arrive. Adjusting standards for some facilities, such as buses, but not others, does not promote access in the larger world.
The standards should continue to include a definition of a ?common wheelchair.?
Finally, like APTA and so many transit operators, County Connection encourages the Board to leave intact, and possibly augment, its definition of a ?common wheelchair.? Transit providers, manufacturers, and customers rely on the use of a single definition to ensure that we all have a common understanding of what type and size of mobility aid can be accommodated on vehicles and in facilities across the country. Losing this definition would create a gap leading not to increased access, but to inconsistent access with no certainty for any of the regulated parties or those intended to benefit from our service.
Thank you for the opportunity to comment on Access Board Docket No. 2007-1.
Please contact me if I can be of further assistance or if you have any questions of me.
Central Contra Costa Transit Authority