Kansas City Transportation Group, Terry O’Toole
June 11, 2007  [via Email]

1300 Lydia  Kansas City, Missouri  64106   (816) 471-2015  FAX (816) 512-5524

Dennis Cannon
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 Mr. Cannon:

Kansas City Transportation Group (KCTG) would like to provide comments on the Access Board’s Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans.  Thanks in advance for taking the time to review our concerns.

Vehicle Specifications (Section 1192.21(a))

KCTG believes the ADA vehicle specifications applicable to minivans, full-size vans and minibuses have served the disability community since 1991 and do not need to be changed. The draft specification states: Sufficient clearance to permit a wheelchair or other mobility aid user to reach securement locations. At least one route to each securement location shall have a clear width of 36 inches minimum measured from floor level to a height of 40 inches and a clear 30 inches above a height of 40 inches. If the draft specification is adopted as written, it will in essence render Minivans unusable in the paratransit community. 

IF major changes are made to vehicle specifications, we ask the Access Board to grandfather in existing accessible vehicles for the life of the vehicles.  Failure to grandfather in existing accessible vehicles would create an undue financial burden on private and public transportation providers and could result in less service available to persons with disabilities.  This issue will only be worsened by the fact very few current models in production come close to meeting the proposed requirements.  Even if you discount the financial issues to the company – the product itself is not readily available. 

Platform Entrance Ramp (Section 1192.23 (b)(8))
The draft guideline states the new slope shall not exceed a slope of 1:8.  This new slope would require ramps so large and cumbersome in the rear of the vehicle, they in themselves would pose a danger.  In addition, all paratransit providers assist the people into the vehicles, so the lesser slope is not required.  The existing 1:5 ratio is more than adequate for the designed purpose.

Wheelchair Standards

It should be clearly called out in the legislation the goal of accommodating wheelchairs fitting in the 30” by 48” envelope.  Currently, wheelchair manufacturers are producing wheelchairs with dimensions that cause problems for wheelchair occupants to be accommodated in both transportation vehicles and public buildings.

KCTG believes in the end, if the proposed revisions are accepted “as is” it will reduce the options of vehicles available to the taxicab, Para transit and other non-emergency accessible transportation services.  This most certainly is not the intent of the legislation, but it is the reality.  Thank you for interest in this very important legislation.  I can be contacted at (816) 512-5514 or totoole@kctg.com if you would like to discuss this issue further.

Sincerely,

Terry O’Toole
General Manager