Region XII COG, James J. Burns
June 11, 2007  [via Email]


Comments submitted by: James J. Burns, Transit Director, Region XII COG, 1009 E. Anthony St., Box 768, Carroll, Iowa 51401
 
We operate a six county rural system in western Iowa.  We use primarily the cut-a-way body on chassia vehicles and some vans.
 
The new rules would serve cut our seating capacity.  The wider aisle requirement would eliminate a column of seats on each side of our current aisle reducing our ambulatory seating from 12 to 6 in a 22 foot minibus.  The proposed change in the wheelchair securement area would further reduce our capacity.
 
For a rural operator to transport the same number of people, we would have to either enlarge our buses or purchase more vehicles.  The body on chassis vehicles are already having problems staying under the manufacturer's GVWR and we all have a problem coming up with more funding to purchase more revenue vehicles.
 
The above changes to the ADA transit vehicle requirements would serve only to reduce the service we are offering to our citizens.  We would eventually see some services forced out of business