I am writing on behalf of the St Cloud Metropolitan Transit Commission, located in central Minnesota serving the cities St. Cloud, Sartell, Sauk Rapids, and Waite Park. This letter is in regards to our concerns about the proposed revisions to the ADA Accessibility Guidelines for Buses and Vans.
Primary concerns with proposed changes:
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). The current guideline has been incorporated into our operating policies for both our Fixed Route and Paratransit services. This policy is enforced to ensure the safety of passengers using our lift equipment and for the safety of our drivers that need to push these chairs on our paratransit door thru door service. Leaving the matter open-ended would mean that transit systems like ours would need to make case-by-case determinations of every wheelchair user. This would take extra resources and could be a potential safety issue for drivers and passengers.
2. The requirement that all vehicles longer than 22’ must be equipped with an automated stop identification system that includes both a visual and audio announcements. We are currently in the process of moving towards meeting our goal of stop enunciation on our Fixed Route system. Our paratransit is a door thru door demand response point-to-point system not needing stop enunciation. The majority of our paratransit system is comprised of 26’ low-floor Orion vehicles that under the proposed change would be non-compliant. The proposed change could in the future limit the size of vehicles that could be used on our paratransit system.
3. The proposal would increase the securement locations dimensions to a minimum of 60” long (up from the current 48”) and would prohibit using any space under a seat as part of the location. The dimensions of our securement devices are set at 48” on our current low-floor buses. Going forward we have determined that any new low-floor buses will have a specification of 54”. That length will enable us to transport up to five wheelchairs. Any additional length would reduce the capacity for
wheelchairs and ambulatory customers on our system.
4. The proposal would require that we be capable of securing anything that enters the vehicle and requires that securement devices can not protrude above the floor. St Cloud Metro Bus has policy requirements regarding what can be brought on a Fixed Route or Paratransit vehicle. Leaving this open ended without size or space requirements would result in capacity and safety issues.
Thank you for the opportunity to comment on the proposed Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans.
Sincerely,
David W. Tripp
Executive Director
St. Cloud Metropolitan Transit Commission
665 Franklin Avenue N.E. St. Cloud, Minnesota 56304
David W. Tripp
Executive Director
-----------------------------
St. Cloud MTC
665 Franklin Avenue Northeast
St. Cloud, MN 56304
Phone: (320) 529-4482
Fax : (320) 251-3499
E-mail: dtripp@stcloudmtc.co