United Spinal Association, Terry Moakley
June 11, 2007  [via Email]

Dennis,

We offer the following brief comments. In general, United Spinal agrees with the substantive changes that are proposed.

  1. Section 1192.3 Definitions – Bridgeplate – in our experience, a bridgeplate can bridge both a horizontal and vertical gap. So, would the language “horizontal and/or vertical” be more reflective of bridgeplate use conditions?
  2. On removing the definition of common wheelchair, bravo! We agree that the common wheelchair definition has been misused to keep disabled people off vehicles in some situations.
  3. Section 1192.21 General – your “unobstructed volume” language is about as clear as can be. The only other ways of expressing this space that we can think of (such as “unobstructed and continuous horizontal and vertical space”) seem more complex than your terminology.
  4. Section 1192.23 – Mobility aid accessibility, (b) Vehicle lift – again, we agree with raising the design load of lifts to 660 pounds. Hopefully, operating experience over the next number of years with newer buses and vans will be instructive as to whether or not this increase is enough.
  5. Section 1192.23 – Mobility aid accessibility, (c) Vehicle ramps and bridgeplates – our comment is that a 1:8 slope will be difficult to achieve, especially when a ramp is deployed to the surface and not a curb. I’ve had to ask strangers to hold back my wheelchair in situations like this when disembarking from buses and vans.
  6. Section 1192.35 – Public information system – we fully support the change to automated public information systems; here in New York, compliance by bus drivers is sporadic at best.
  7. In general, we are aware of the development of the accessible Standard Taxi. We have been in regular contact with them since January of 2006, because this is one city where they would like to sell a lot of their new cabs. Our question is, would not this be the right time to consider specifications for a vehicle like theirs? It’s not a van, that’s for sure. Just raising this as a possibility for the Access Board to consider.

Thanks for this opportunity to comment.

Terry Moakley
Project Manager
Taxis For All-North America
United Spinal Association
75-20 Astoria Blvd.
Jackson Heights, NY  11370
www.taxisforallNA.org
(718) 803-3782, Ext. 277
tmoakley@unitedspinal.org