July 6, 2007
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
Madam Chair and Members of the Board:
I am writing on behalf of the Interurban Transit Partnership also known as The Rapid to provide comment on the Architectural and Transportation Barriers Compliance Board’s Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans, published April 11, 2007.
About The Rapid
The Rapid offers a variety of services to meet the mobility needs of our community. We have 21 fixed routes, and paratransit service for those not able to use the fixed routes. We provide parking lot shuttles under contract to the City of Grand Rapids, manage our own vanpool program, and offer demand/response service to ensure everyone within the service area has access to public transit. We also have a county-wide program to support employment transportation. Last year we introduced the Air Porter to provide service from the airport to the downtown hotels and convention center, directly supporting the convention and tourism industries. We serve six cities in the greater Grand Rapids Area and are a regional authority supported by property tax millages, state funding, fares and other revenues. Las year we transported more than 7.4 million trips on all our services.
Application of Guidelines
First, we appreciate the need to address the guidelines that relate to bridge plates and BRT vehicles. We appreciate the Access Board’s consideration of new technology and support the development of guidelines that facilitate the implementation of mew accessible and customer friendly technology. However, we have great concerns with many of the other proposed changes to the vehicle guidelines. We don not understand the need for the changes and are concerned that they may not be based upon operational reality. We run extensive paratransit services and do not observe a problem that needs to be addressed that any system on a responsive basis cannot address. The Access Board has not provided information that allows me to judge whether the proposed changes actually solve a problem. We observe that the proposed changes in dimensions of lifts are not required. WE have been able to transport all our clients in a mix of vehicle types with different lifts and have not had one instance of trip denial because of the lift dimensions.
Proposed Changes Should Only Affect Future Procurement
As proposed, section 1192.21(a) would render virtually every existing transit bus and van inaccessible. Words like ‘new, used, or remanufactured’ to describe the buses and vans to which the new rule will apply imply a range of vehicles that may affect all agencies with severe hardship. We recommend that this phrasing apply to all new vehicles as of a reasonable date pursuant to the issuance of new guidelines; and most certainly not to existing equipment in service, on order in a procurement phase.
Automated Stop Announcement Requirement Issues
Proposed section 1192.35 introduces a new requirement for automated stop announcements. The Rapid is about to embark on an ITS project that includes automated annunciation of stops. Many systems do not have the resources to move in this direction. This would be an undue burden and hardship on many small systems that are operating on a shoestring.
Furthermore many vehicles over 22 feet are in different types of services that may not require automated annunciation. Why mandate such an obligation.
Lastly, the proposal is to call for annunciation in visual form. How is this to be effected? This is another proposal that may be very difficult to apply. What are the standards being used that will not cause hardship universally.
Problems with changes to the definition of “Common Wheelchairs”
On what basis is The Access Board redefining a “common wheelchair”? We have spent many years and improvements to carry common wheelchairs. Rule changes must continue to be defined on the basis of accommodating a common wheelchair. Nothing in the proposed changes has been demonstrated to be necessary for the accommodation of common wheelchairs.
The proposed standards would require costly redesigns of nearly every commonly available vehicle and may cause a financial hardship at a time when many basic service needs are not met.
Definitional Issues
The proposed section 1192.3 is problematic in many respects. Vehicles we are scheduled to obtain including vans, “similar vehicles”, bus rapid transit vehicles, are not defined in a contextual manner. For example, what is the Access Board’s definition of BRT?
Please look at these comments carefully and consider the impact it would have on a service that is moving people with disabilities and access issues in a significant and positive manner.
Respectfully,
Peter J. Varga
CEO
Interurban Transit Partnership
300 Ellsworth Ave. SW
Grand Rapids, MI 49503-4005
(616) 456-7514