Docket 2007-1
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:
I am writing on behalf of the Jacksonville Transportation Authority (JTA), the transit system serving Jacksonville, Florida (Duval County), and Northeast Florida, to express our concerns about the proposed revisions to the ADA Accessibility Guidelines for Buses and Vans.
We have four primary issues:
1. 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). While we recognize that the current definition may need to be revised, we fear that leaving the matter open-ended would mean that transit systems like the JTA will need to make a case-by-case determination of every wheelchair user and each vehicle we operate.
2. 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. It will be very difficult to deploy such a long ramp at many of our stops.
3. 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. This requirement would make nearly every current full sized bus and all mini-vans non-compliant. We also have concerns about the proposed requirement stating that securement devices cannot protrude above the vehicle floor.
4. In addition to the above, we believe that much more attention needs to be given to the phase-in period for any and all of the proposed changes. Our Authority keeps buses in service for as long as 18 years, so there will be an extended period during which transit systems like the JTA will be operating 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.
Sincerely,
Thomas Jury
President
Jacksonville Transit Management
100 North Myrtle Avenue
Jacksonville, Florida 32203