Date: June 11, 2007
Docket 2007-1 [RIN 3014-AA38]
Office of Technical and Informational Services
Architectural and Transportation Barriers and Compliance Board
1331 F Street NW
Suite 1000
Washington, D.C. 20004-1111
Dear Sir/Madam:
Re: Docket 2007-1
Proposed changes to ADA Accessibility Guidelines for Buses and Vans
The Architectural and Transportation Barriers and Compliance Board (“Access Board”) has published draft revisions to the Americans with Disabilities Act (“ADA”). These comments are provided in response to the draft revisions of the ADA accessibility guidelines for buses and vans.
DaimlerChrysler Commercial Buses North America Inc. (DCCBNA) manufactures and
distributes a wide city of bus models in the United States, including city transit buses,
motorcoaches, and shuttle buses. DCCBNA supports the efforts of the Access Board to
improve the functionality of buses to accommodate all passengers. The following
comments are provided with respect to the draft ADA revisions.
DCCBNA suggests that the Access Board issue drawings and technical data that it relied on to develop the suggested ADA revisions. This will assist all parties, including vehicle manufacturers, in the analysis of the feasibility of the proposed changes.
DCCBNA suggests that, where possible, the Access Board issue background
information that describes the technical issue that each proposed revision is attempting
to overcome. This information will assist in allowing the industry to understand the
extent of the problem, and propose alternatives if the revision is not feasible from a
design perspective.
The draft changes would have a significant impact on existing bus design, including a reduction in seating capacity. DCCBNA’s assessment is that these changes cannot be incorporated on current buses because of restrictions in vehicle width and road design. A major redesign of the vehicle structure would be required among others.
As requested these E-mail comments are sent to cannon@access-board.gov with the following full name and address of the sender in the text.
Joe Labonte
Compliance and Safety Officer
DaimlerChrysler Commercial Buses North America
350 Hazelhurst Road
Mississauga, Ontario
L5J 4T8
Joe.Labonte@DCBUSNA.com
In particular, the following issues are noted:
1) 1192.23 A(2) General. Where a turn is required, sufficient maneuvering space shall be provided to allow a wheelchair or mobility aid having a width of 30 inches maximum and a length of 48 inches maximum to turn with a minimum of back-and-forth movement.
If the proposed securment maneuvering space inside the bus is to be 30 inches by 60 inches then there must be equivalent maneuvering to get into the bus.
In the ADA and ABA Accessibility Guidelines for Buildings and Facilities, amended August 5, 2005 section 304.3.2 T-Shaped (Turning) Space was revised to add an additional 12 inch extension arm for making the 90 degree turn from a 36 inch wide aisle to a 36 inch wide aisle. In order to accommodate this the vehicle structure and suspension system would have to be redesigned. The bus would have to be either lengthened or made wider. Significant obstructions are created by the wheelwells, driver’s station, and various farebox sizes.
a. Bus length is restricted by vehicle size regulations, front over hang and approach angles.
b. The bus width is restricted by Federal regulations.
c. Additional maneuverability space would reduce seating space.
d. Bus structure and suspension modifications cost over a hundred thousand dollars to development and add thousands of dollars to the cost of each bus.
2) 1192.23 D(2) Location And Size. Securement location length is increased to 60 inches from 48 inches and removed securement location size floor space under seats and panels.
The impact of this change will be as follows:
a. Eliminate two rows of seats (4 seats).
b. Increase the hazard for those walking to seating location due to addition distance to reach a station handhold or seatback.
c. Provide more free standing space when not occupied by mobility aids but would increase front axel loading beyond current design and allowable axel load road regulations.
3) 1192.3 Definitions. Removal of definition of “Common Wheelchair”
The removal of the definition results in the loss of a maneuverability template that allows for the establishment of design parameters, and demonstration of compliance. The definition and diagrams provided in the ADA have been integral to understanding the accessibility requirement. Rather than eliminating this information, additional detail on the maneuverability requirement should be provided.
4) 1192.23 (B) Vehicle Lift and (C) Vehicle Ramps And Bridgeplates. Ramp and lift weight capacity increased to 660 lbs from the current 600 lb.
a. New lifts and ramps must be designed for the heavier load and meet the required 3 and 6 times safety factor loads.
5) 1192.23 (c) (5) Slope. Set the maximum slope at 1:8 for ramp and lift transitions (remove reference to curb).
a. The bus suspension cannot be lowered. The bus kneeling feature and frame design already create the minimum floor elevation.
b. A longer ramp creates difficulty when deploying due to stop obstructions and causes the bus to stop further from the curb. To reach the 1:8 proposed slope the ramp would need to be nearly 80” long.
c. Currently ramps are simple in design with a 41” ramp plate. A longer ramp must be multi-sectional and would require stronger power units and structure.
d. Multi-section ramps are complex affecting reliability, maintenance, thousands of dollars in costs, durability and strength.
e. Closed multi-layered ramp sections can create a raised tripping edge.
6) 1192.29(c) Eliminate overhead handrail in favor of seat-back handholds.
a. This should be optional.
7) 1192.35(a) and (b), Automated stop announcements in auditory and visual formats.
a. This will increase the base cost of the bus by thousands of dollars.
8) The Board seeks comment on whether seat belts and shoulder harnesses shall meet alternative SAE standards.
a. Federal Motor Vehicle Safety Standards (FMVSS) only allow seatbelts that meet 49 CFR 571.209.
b. Anchorage standards appropriate for a bus “G” forces must be developed due to the vehicle mass differences between that of a bus and a passenger car. The FMVSS 49 CFR 571 requirements are for passenger vehicles that are under 10,000 lbs. Gross Vehicle Weight Rating (GVWR). Transit buses have a GVWR of 36,000 lbs. to nearly 44,000 lbs.
9) In the preamble it discusses a turning clearance within 42 inch minimum aisle required to turn into a 36-inch wide aisle.
a. Cannot be accommodated in shuttle type buses due to vehicle body design.
b. For Transit buses see 1. above.
c. A specific requirement must be provided to certify compliance.
10) 1192.39 Destination And Route Signs.
a. Destination signs are standard for the front of the bus and optional for the boarding side. Sign suppliers state they currently meet the proposed size and lettering requirements.
b. Making the boarding side destination sign mandatory will increase the base cost of the bus by thousands of dollars.
11) The ADA needs to clearly indicate that any changes are prospective and do not impact vehicles manufactured prior to the implementation date.
a. Changes should be effective relative to the magnitude of the development efforts and after the year 2010.
DCCBNA’s assessment is that the draft changes cannot be incorporated into the current bus, and that significant changes would have to be implemented. Consideration should also be given to the fact that engineering resources throughout the industry are being applied to extensive engine emission regulation changes for 2007, 2010 and 2013. In conclusion, these proposed changes will require significant time, costs and effort to consider if a redesigned bus can meet the requirements.
Yours very truly,
DAIMLERCHRYSLER COMMERCIAL BUSES NORTH AMERICA
Joe Labonte
Compliance and Safety Officer
DaimlerChrysler Commercial Buses North America
350 Hazelhurst Road
Mississauga, Ontario
L5J 4T8