Good morning, Dennis.
I hope you can accept the two comments to follow regarding the proposed revisions to subparts A and B of 36 CFR part 1192 – even though they were due yesterday. I have two really good excuses for being late. One, I tried to access your site last night, but I couldn’t get through. Two, I actually am on vacation and writing from home, so I hope you’ll give me a few extra hours out of pity!
My name is Susan Millbank and I am the Accessibility Officer for Spokane Transit Authority, Spokane Washington.
I have reviewed the proposed changes to subparts A and B of 36 CFR part 1192 with STA’s maintenance manager. We have one comment and one concern. The comment is the hope that these proposed guidelines have been reviewed with the companies that manufacture buses and paratransit vans. Spokane Transit will operate any vehicle that meets the guidelines. We hope you will specifically ask for comments regarding the ability to produce vehicles that fit these proposed guidelines.
The concern is that with these guidelines, we may need to use a folding ramp. A folding ramp has the potential to be a step backward in the effort to make buses accessible. Any property who deals with snow, ice, mud, dirt, sand, or any other ground cover that can be tracked into the bus will have an added maintenance issue with folded ramps. The fold mechanism will become full of stuff and break down issues will occur. This would be very disappointing and take away the delight our passengers feel when they see their bus is a ramp bus. We all anticipate the day when none of our buses will have lifts. Folded ramps will be better than lifts – but maybe not by much.
As the Accessibility Officer, I have another concern regarding the removal of the definition of a common wheelchair. I understand and sympathize with your reasons for wanting to remove the definition. I am extremely concerned that the consequences of this removal will mean less access to buses for those people who truly need it. My concern is with the use of the term “mobility devices.” Of course, I suspect that you want to open the doors to Segway-type vehicles – or whatever will come down the line next. I think the price paid will be less access for people who have no option other than a wheelchair.
I work from the prejudice that a person uses a wheelchair or a scooter because that device is necessary for the person to be mobile. Every day on the buses, we deny access to the wheelchair securement areas to people who have other kinds of “mobility devices.” We say the securement areas are for people and their “common wheelchairs.”
Keeping in mind that we cannot establish as fact that a person is disabled, here are some examples of “mobility devices” we have encountered on our buses. Passengers want to store their device in the wheelchair securement area – which would, of course, mean that space would not be available to a person in a wheelchair.
A walker that is loaded with grocery bags of stuff (not groceries) – we don’t know if this person is disabled.
A stroller with a baby in it – the mom is disabled and under the new guidelines, she will use the securement area by claiming the stroller is her “walker.”
A passenger who might be disabled and who boards with a huge “service dog.” She will definitely claim the dog is her “mobility device” and claim her right to have the dog occupy the securement area. Believe me, she will not give up the space for a person in a wheelchair.
I could probably come up with other examples – but I am on vacation! The point is people who use a “common wheelchair” really need those two securement areas. They can’t stand when the bus is full, and they don’t need to compete for the two “seats” available on the bus.
Thanks for listening, Dennis. Please let me know if you have any questions.
Susan Millbank
Accessibility Officer
Spokane Transit
1230 W Boone Ave
Spokane, WA 99201
509 325 6094
smillbank@spokanetransit.com