RE: Comments on Draft Revision.
Comment 1, Subpart B – Buses, Vans and Similar Vehicles
1192.23 Mobility aid accessibility.
(b) Vehicle lift.
(1) Design Load.
Approximately half of the commercial buses ElDorado National produces are handicap accessible. These buses are designed with Level change mechanisms for loading and unloading persons with disabilities. Last year, Federal Motor Vehicle Safety Standard 403 promulgated regulations which specify standards for vehicle lifts. A great deal of time and effort went into the development of this particular standard, and the design load for these lifts was set at 600 lbs. We believe that although the 600 lb. design load may not be ideal, all Federal Standards should maintain continuity and recommend that the lift design load be revised to be in line with the Federal Motor Vehicle Safety Standard (FMVSS) of 600 lbs. which already covers the safety aspect of this important accessibility equipment for vehicle lifts. Most providers have already tested to this FMVSS requirement, and we believe additional testing would put an undue burden on the lift manufacturers and installers and increase the cost to the end user.
Comment 2, Subpart B – Buses, Vans and Similar Vehicles
1192.23 Mobility aid accessibility.
(c) Vehicle Ramps and Bridgeplates.
(2) Design Load.
All of the Mini-vans ElDorado National produces are accessible. These vehicles are designed with ramps for loading and unloading persons with disabilities. Last year, Federal Motor Vehicle Safety Standard 403 promulgated regulations which specify standards for vehicle lifts. A great deal of time and effort went into the development of this particular standard, and the design load for these lifts was set at 600 lbs. We believe that although the 600 lb. design load may not be ideal, all Federal Standards should maintain continuity and recommend that the ramp design load be revised to be in line with the Federal Motor Vehicle Safety Standard (FMVSS) of 600 lbs. for vehicle lifts. Most providers have already tested to the 600 lb. requirement, and we believe additional testing would put an undue burden on the ramp and vehicle manufacturers.
Comment 3, Subpart B – Buses, Vans and Similar Vehicles
1192.23 Mobility aid accessibility.
(c) Vehicle Ramps and Bridgeplates.
(5) Slope.
ElDorado National, (Kansas), manufactures accessible commercial buses and mini-van conversions. The mini-van conversions include a ramp for loading and unloading passengers in wheelchairs and other mobility aids. We provide the ramp in a powered and a manual version. These are folding type ramps that mount in the doorway of the sliding door, and fold out to the side of the vehicle. This vehicle provides important access for persons with disabilities for both personal, and commercial vehicles. The conversion includes lowering the floor so we can meet the door height requirement for ADA and provide for the lowest floor possible for ease of loading and unloading non-ambulatory passengers. Appropriate clearance, under the vehicle, and ramp slope are the main factors that determine ramp length. With the present slope of 1:4, our ramp is at or near the maximum length in regards to handicap accessible parking spaces. Additional ramp length could force passengers to deboard in unsafe areas, or limit the flexibility of use for which the vehicles were intended. Additional ramp length in the stowed position will block part of the windows, and limit visibility for the passenger(s) in the vehicle. It will also obsolete ramps that swing out of the way in the stowed position for the convenience of loading and unloading ambulatory passengers. With the revised ramp angle, the longer ramp when deployed at a curbed sidewalk would extend so far onto the sidewalk as to create more of a trip hazard for foot traffic on the sidewalk. It would also require the ramp to be of a heavier construction. This weight plus the added weight of the longer ramp will limit the load carrying capacity of the vehicle. These concerns are especially true for vehicles sold into taxi service, transit service, and retirement homes. While ElDorado National understands the advantages of the longer slope on the ramp, we would like to petition the Access Board to consider a less restrictive slope of 1:5. This will improve the present requirement while not making it extremely restrictive.
Comment 4, Subpart B – Buses, Vans and Similar Vehicles
1192.23 Mobility aid accessibility.
(d) Vehicle Ramps and Bridgeplates.
(2) Location & Size.
Increasing the size of wheelchair securement areas to 60 inches and removing the 6 inch “toe space” for parallel approaches will mean that fewer passengers will be able to be transported with the same number of vehicles. At a time when our country is trying to decrease its dependence on foreign oil, this seems counter-productive and not in the best interests of our Nation.
Not all users require the larger size securement, so ElDorado National recommends that the longer wheelchair securement be made an alternative for users who require the additional maneuvering room. Another option would be to allow the “toe space” with the 60 inch space, or cut the securement size back to 54 inches for the parallel approach.
Comment 5, Subpart B – Buses, Vans and Similar Vehicles
1192.23 Mobility aid accessibility.
(d) Vehicle Ramps and Bridgeplates.
(3) Mobility Aids Accommodated
Mobility aids could include everything from a cane to the most sophisticated powered wheelchair. This definition is too broad and needs clarification.
Comment 6, Subpart B – Buses, Vans and Similar Vehicles
1192.35 Public Information System.
(a) While larger transit agencies can, and do, request these type systems presently, it becomes cost prohibitive for smaller agencies and rural agencies who struggle to purchase the basic equipment they need to service large sparsely populated areas. Adding an expensive automated voice system could mean that some of those areas that need services would not receive them. ElDorado National believes that a simple P.A. System would be a more prudent choice for many smaller transit situations.
(b) The comment for (b) is the same as for (a) above.
Respectfully submitted,
Ken Huser,
ElDorado National (Kansas), Inc.
1655 Wall Street
Salina, Kansas 67401
http://www.enconline.com