US ACCESS BOARD

PUBLIC INFORMATION MEETING

BUS RAMPS

UPDATES TO THE ADA VEHICLE GUIDELINES

October 2, 2012

2:15 – 5:30 p.m.

Washington State Convention Center

Seattle, WA

CART Services Provided by

Alderson Court Reporting
US Access Board Public Information Meeting Unofficial Transcripts

October 2, 2012 Seattle, WA Page 2

US ACCESS BOARD

PUBLIC INFORMATION MEETING

BUS RAMPS

UPDATES TO THE ADA VEHICLE GUIDELINES

Access Board Members Present: 

Christopher Hart, Public Member

Melissa Anderson, Transportation Engineer

Karen Braitmayer

MS. ANDERSON: I think it's about time we got started. For everybody hiding in the 

back, if you want to step forward and sit up closer, you're welcome to do that. Sometimes I 

whisper and make people move forward but I won't do that today. 

So my name is Melissa Anderson, and I'm a member of the staff for the US Access 

Board in Washington, D.C., and we're having this public information meeting to gather more 

information about a couple important issues that have come up regarding our transportation 

vehicle rule. With me today are some of our board members. We have Chris Hart, who's a 

public member of our Access Board, and Karen Braitmayer, also a member from the public. 

And I don't know if everybody's familiar with the makeup of the Access Board, but it's an 

independent federal agency, and we were charged by Congress in 1970 -- we were established 

by Congress in the 1970 to set up guidelines and the rules for accessibility to help people meet 

the requirements of the accessibility regulations that were available at that time. 

We work on a lot of different standard. The transportation vehicles, which affects 

buses is what we're here to talk about but we also do public rights of way, vessels, outdoor 

recreation, the ADAG, the buildings, those types of rules. So we write guidelines and then 

other agencies with enforcement authority adopt them and they become standards. So once 

we finalize our vehicle rule, then they will be adopted by the U.S.DOT and the Department of 

Justice, and they'll become standards that are enforceable. 
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October 2, 2012 Seattle, WA Page 3

So I'm going to give you just kind of a brief introduction of where we are right now and 

what we're here to talk about. 

In 1950s, people were trying to make transit accessible we've come a long way but we 

still aren't there for perfect accessibility yet. Low floor buses is have been a big improvement 

of the some of the recent improvement even since the last transportation rule came out that's 

enforceable now by the DOT. 

The current rule has a requirement for the steepest slope that's allowed is a 1:4 ramp 

slope if a bus deploys a person or picks up a person on a flat surface without a curb. 

Now, this is a very, very steep slope. It means you go up 1 foot for every 4-foot you 

move forward. So that's a 25 percent ramp slope, and that's pretty steep. Your typical curb 

ramp is about 8 percent. So you can think about it being four times what your curb ramps are, 

and that's difficult to maneuver. 

In the past, the ramps have always started at the door edge, so the 1:4 extended 

outside of the vehicle. And that left a lot of floor space inside the bus for people to maneuver 

around. So if a person were to come up the ramp in a mobility device, they had a lot of floor 

space to make that turn or to stop and comfortably pay their fares when they were entering 

the bus before they turned and made their way to the securement area. 

Now, I have a couple videos that I'm going to show that illustrate some of the issues 

that are a problem currently. So bear with me as I switch over here. 

These are the old 1:4 ramps, and you can see that they create quite a challenge for 

people. 
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October 2, 2012 Seattle, WA Page 4

Yeah. So that's one of the problems we're trying to deal with here. And that's from 

the old standards. 

So the new proposed rule has a maximum ramp slope of 1:6 when the ramp is 

deployed from the bus to the ground. People have tried to implement that because I think 

everybody recognizes that a 1:6 slope is much better than a 1:4 slope as far as 

maneuverability, but in doing that people have come up with different ways to do it, and one 

of those ways is to have a fixed slope inside the bus and that then the ramp outside the bus

has a variable slope. So you end up with a grade break as you're entering or leaving the bus. 

And when you do that, you come up with a vertical drop at the corner the way it's 

been implemented so far that we've gotten -- we've received these comments from users and 

operators. So the vertical drop is a problem because you have an abrupt drop. It also makes 

people unstable because you can see that the smaller front wheel in this picture is level on the 

ground but the other wheel on the outside of the picture is in the air. So that's an unstable 

situation for someone. 

And it has lessened the maneuvering space at the front of the bus. So when people try 

to get up there to turn they are kind of pinned in the level area and can't make the turn to

safely maneuver down the ramp. 

I have another video. 

(Video played.) 

And this is an implementation of the 1:6 ramp slope. 

And you can see when it's deployed to the ground you get a pretty good even grade --

or even ramp there, but there's still not a lot of maneuvering space. 
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Now, these videos were -- this was sent to us by the bus company, and it looks like 

they're trying to illustrate their point by people who are not frequent wheelchair users. So 

their maneuvers are more clumsy than someone who is in a chair every day, and that's 

apparent as you watch the video, but they're trying to illustrate their point. 

This is the problem, this area in front, and then trying to get turned around where the 

vertical drop-off is. 

And this is a pretty good spot where you can see one of the major issues. 

I think we see some of the problems. So what the Access Board has done is sent out a 

request for public information, and we want to collect more comment about the issues that 

have been brought to our attention by bus companies and manufacturers and advocates and 

people familiar with the area. In the federal registrar notice that went out, there are four 

questions that we're asking that will help provide us with the information we need to make 

good decisions to develop the guide lines. So I'm going to read through those and then we're 

going to take presentations from our audience, and after that then we'll have an open 

discussion period, so that we can hear, everybody learns a lot just from hearing what 

everybody else has to say. 

So this is the first question that we have to ask. Can a bus ramp with a slope of 1:6 be

provided without a grade break and without compromising the available level space within the 

bus at the top of the ramp? How might bus kneeling affect these designs? 

Second question is if the ramp slope were required to be uniform for the length of the 

ramp with no grade brake, how would such a requirement affect the bus and ramp designs, 

manufacturers, transit operators, and transit users, including those with disabilities? 
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October 2, 2012 Seattle, WA Page 6

The third question is how much level space measured when the bus is sitting on a level 

surface can be provided at the top of the ramp? How can the space be configured to permit 

individuals who use wheeled mobility devices to access fare collection devices and to turn into 

the main aisle? How does the slope of the ramp, the location of the fare collection device, and 

the configuration of the handrail affect the availability of this space? 

And if level space were required at the top of the ramp to permit access to the fare 

collection devices and to facilitate turning into the main aisles, how would such a requirement 

affect bus designs, manufacturers, transit operators, and transit users, including those with 

disabilities? 

So if anybody has -- I've got a list of people who asked to speak, and then if we want --

if other people would like to speak after that, they're more than welcome to do so, and then 

we'll have a little bit of discussion. Everybody can speak up. Now, I'm going to ask -- this is 

obviously being transcribed by our CART reporter and our transcription over here will act as 

our public record of this meeting. So we need you to let us know your name and the 

organization that you represent, or if you're an individual, just let us know you're speaking as 

an individual so that we can get it on record so that we can share it with the public. 

Did you want to say something. 

MR. HART: Yeah. Just to provide you today. There will be on regulation dot gov. So 

you don't want to share it aloud, don't give it to us. 

MS. ANDERSON: And that's a good point. That came up in our meeting in Washington, 

D.C. We had manufacturers that were willing to give us some proprietary information but if 

they give it to us, then it becomes public information and everybody in the industry knows you 

don't necessarily want everybody to know your secret ingredients. So that's a good point, 

Chris. Thank you. 
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Okay. First person on our list is Michael Collins. 

SPEAKER: Can you hear me? Is this turned on? It says it's on. 

MS. ANDERSON: Yes. 

SPEAKER: Can you hear me okay. 

MS. ANDERSON: Yes. 

SPEAKER: How you doing? 

I'm Mike Collins, and I'm here as an individual today, but I had I had bring extensive 

experience as a transit user, as an advocate, and also as a former public servant involved with 

accessibility for people in all aspects of life, including transmission. 

I just would like to open this with a little bit of a concept for people to put in their 

minds. Despite those videos, most of us in power chairs and scooters need to back up the 

ramps rather than roll forward up the ramps because there is not a sufficient turning radians --

turning radius inside the vehicles to allow us to swing around and back into the wheelchair 

securement spaces. So. 

So you can imagine makes those maneuvers up the ramp, around the corners, avoiding 

obstacles in a wheelchair or a scooter that doesn't have a rearview mirror or a backup camera 

on it. So we face that every day. We face that in our personal vehicles, unless they've been 

configured so we can pull forward into the vehicle, but in para transit vehicles and in fixed 

route buses. I've also ridden on the big blue buss in Culver City that were in this video and 

found them to be fairly accessible in comparison to any lift equip bus that I've ever been on. 
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About 50 percent of the rides I've tried to take on a fixed route transit bus including in the 

Puget Sound region end in some type of a breakdown, or don't begin because of a breakdown, 

and I might have -- I might miss my trip or have to reschedule it for a later time. 

The other concepts to think about are the use of the fare boxes. The video you 

showed doesn't really show the fare box itself, but in many cases, those extend all the way to 

the floor, and often a bus that might -- the vehicle itself that might have come out of the 

factory accessible is made inaccessible by emergency kits, fire extinguishers, and the very 

installation of the transit fare box so that we can't make that corner without a lot of difficulty. 

Now, my wheelchair is a minimum of 48 inches in length. It's also the maximum that's 

allowed on a lot of para transit wheelchair lifts, but that length needs to be turned and the 

turning radius is never a 4-foot turning radius like you would see in any type of an accessible 

dwelling or any type of accessible space. So you need to -- the manufacturers of the ramps 

need to be designing those to give us the full flexibility of making those turns in that confined 

space. So those are the concepts that everybody should keep in mind. 

I've often wondered why the bus manufacturers or the -- some innovative lift 

manufacturer couldn't make an extended lift that hinges at the bottom and simply fold up 

before the doors close and let all the passengers simply walk up that ramp and those of us 

who use wheelchairs we could roll up or down it. The ramp would then be maybe 6 feet, 

maybe 8 feet in length, and would be in use by everybody. So it would be operable everybody 

day or else the bus wouldn't be operating. Just a little thought for some innovative designer 

out there and I'll take my cut when they get their share. 

And if you have any questions, I'm willing to answer them now or later. 

Thank you. 
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MS. ANDERSON: Thank you, Michael. 

MR. HART: Mike, you down played your national involvement for folks who don't 

Mike, Mike was worked some time at the national council which issued numerous federal 

reports to Congress as in his entire, including working at ADA and 504, 508 compliance in 

transit environments, and Mike was one of the folks who helped make that happen. 

Keep our feet to the fire. 

Mike, are you suggesting there then needs to be more innovative design process 

between bus manufacturers and the ramp manufacturers to get a better front entryway? Is 

that what you're suggesting? 

SPEAKER: Yeah, and I should clarify two things, Chris, since you brought up that I 

worked at the national level. I am now retired at the national level, and I live in Redmond, 

Washington. I also neglected to say that when I got started, and I do still write, but I'm not 

going to an office every day except in my own house. 

Yes, I do think that the fact that most of the vehicles themselves are manufactured 

looking nowadays at the reliability, the economics of the vehicle, the ecological imprint it has, 

whether it's because of the fuel or some other factor, maybe even the materials, they 

sometimes forget that there are those of us who need that accessible -- the accessibility of 

that vehicle to be front and foremost, but in my past experience, I've seen that many of the lift 

manufacturers are not related to the vehicle manufacturers. So they have to try to craft a 

solution to a vehicle that's already in existence, and they probably have two or three designs 

available for every vehicle, but they may not all be as accessible. If there was a way to 

mandate that everybody, whoever purchased a wheelchair ramp or a vehicle, a bus, would 

have to be in a power wheelchair for the 24 hours prior to and after they chose that ramp, I 
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think we might have better results, but it's basically a pretty tough fix when you're dealing 

with multiple facets of the accessible features coming from different sources. 

And thanks for the compliment, Chris. 

MS. ANDERSON: Thank you, Michael. 

SPEAKER: All right. 

MS. ANDERSON: Andy VOBARA. 

SPEAKER: Thank you, and my comments, Andy Vabora, director of customer services 

and planning at transit district Eugene Oregon and my comments are going to I think mirror 

your presentation pretty closely but in 2011, 2012, LTD received 24 new vehicles with a ramp 

designed to achieve this 1:6, and in order to accomplish this some of the flat area on the inner 

portion of the platform was sacrificed in some situations in standard operation the deployed 

ramped created what we call double dip just inside the front door this location is where 

people must turn or prepare to exit the vehicle and pay their fare for a variety of mobility 

devices the issues created by the double dip caused customers to become high centered, 

tipping over, scraping their foot rest, and/or experiencing other issues. Some very serious. 

LTD has experienced some success through operational adjustments and driver training, by 

installing a bumper in the vehicle to guide the mobility devices so they don't turn too sharply, 

fall off the cliff that you mentioned. The manufacturer of this ramp has been very proactive in 

beta testing the new design of a 1:6 ramp. We really appreciate their efforts there. While 

further testing and experience is needed, feedback from individuals and operators about the 

new beta design has resulted in favorable experiences at curbed locations so far, and we're 

going to continue to test that over the coming months and in some of our driver training, the 

drivers while we've installed this on one of our buses, the drivers have asked that that bus be 
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rescheduled to other schedules so multiple drivers can experience it in their situation serving 

their customers. 

An issue really needing to be addressed is how equipment such as ramps are tested 

prior to being installed and put into service and the process to get attention when compliance 

or safety concerns are identified, and that's what was a little bit I think disappointing to us in 

finding out that there were issues with these particular ramps earlier in the development. 

The industry must have assurance that equipment on the market is adequately tested 

and meets ADA standards. Equipment should be tested to make sure people with a variety of 

different configurations of mobility devices can successfully and safely use the equipment, 

such as ramps when installed on a bus and used in service. 

Thank you. 

MS. ANDERSON: Thank you Andy. 

Does anybody have any questions. 

MR. HART: 

Yeah, Andy, can you elaborate, when you choose a product such as a ramp or 

(indiscernible), do you call out for that product to be tested previously or you then said the 

industry needs that. I'm wondering, on a contractual basis, do you have any language that 

would help that. 

SPEAKER: I don't know specifically, but I think that's one of the lessons learned, 

certainly, for us as I think one of the very first transit districts fully accessible for people with 

disabilities in the country, we've always had a long history and been very proud of the services 
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that we've provided and the -- I think, again, lesson learned for us is that we had a long history 

of working with particular manufacturers who we felt very comfortable with and in citing the 

specifications and the results of this new 1:6 slope that we felt was going to be very beneficial 

to our customers, and I think for us it really opened our eyes to the fact that we need to do a 

little bit more research, especially in a first generation type ramp like this 1:6 that came out. 

Again, it was something that I can tell you from personal experience because I happen to be 

the acting general manager the day that these buses went into service, and we experienced 

our first accidents. It was really scary and disheartening to know that we put people in that 

kind of situation. So for us, certainly in the future we're going to do a little more due diligence 

on our part, but I think that as both manufacturers of the vehicles and the lifts and working 

together, it would be great if we could have that confidence that, you know, the customer 

safety is first and foremost and that these ramps have been tested adequately before they're 

sold. 

MR. HART: When you buy a bus, are you individually choosing components such as the 

ramp and the fare box, or is that all one package. 

SPEAKER: No, those are individually specified. 

MR. HART: That's my understanding that that was the case in smaller procurings. 

MS. ANDERSON: Thank you, Andy. 

Jonathan Porter. 

SPEAKER: I ask could you lower this a little bit? 

MS. ANDERSON: Yes. 
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SPEAKER: That's fine. That's perfect. 

Yes, my name is Jonathan Porter. I'm here as an individual but I'm on the Seattle 

commission for peoples with disabilities. We actually had a housing forum at the same time 

today so I'm the only one that was able to represent them. I was just really -- a lot of my 

points that I was going to point out were kind of hit on the head already, but as a long time --

I'm a Seattle native and bus user seeing when the lifts went from you know the electronic lifts 

that they actually deploy and come out to the ramp systems where it's the 1:6 to now the 

newer buses that have the one -- all the ones and 1:4, the newer ones are 1:6. It's funny how I 

was excited about the newer buses, but with the new 1:6, the whole double dip thing, one 

caught me off guard but it was definitely the vertical drop and that turn, I myself and I've had 

a lot of wheelchairs. This chair that I have currently has probably been the shortest vertically 

as far as from front to end, but even in this chair, kind of that radius turn I've had difficulty on, 

and as was already stated, you know, for the most part most wheelchairs that get on buses we 

all kind of back in and go out frontwards, and with that vertical drop and having the harder 

turn radius it's a lot harder because, one, chairs have less power I find going backwards. So 

you're not able to get over vertical drops. You're just not able to. So a lot of times I'm forced 

to go in frontwards, and then that brings even more headaches as far as people already 

signature, having to maneuver and turn back around to sit, but then also getting out, you 

know, I'm either scraping my foot rest on the front or I'm having to, like, almost ask them if I 

can go out backwards because it is such a small space where I've gone off the vertical drop 

and I'm just like lucky I'm okay, everything's fine, and I just find it interesting like how all these 

buses are installed and then I'm just kind of thinking how does the testing process happen? 

Are they using more than one wheelchair test on these buses because we all are different. 

But like I said, everything was kind of already pointed out in the video, and that's all I was 

going to say and you guys showed it. So I'm just excited and hopefully they're able to look at 

that and say, you know, this is totally a problem and if all the buses moving forward are going 

to be like that, you know, in a lot of ways I was -- had less evils with the older buses than the 

newer ones. So that's my only comment. 
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MS. ANDERSON: Okay. 

Thank you, Jonathan. 

Okay, Doug Cross. 

SPEAKER: Hi, I'm Doug Cross. I'm an independent consultant specializing in transit 

accessibility based in Oakland, and my client is the Santa Clara valley transportation authority, 

which is the bus system, among other transit functions for the San Jose urban area. 

And I began working for VTA in February of 2011. They had received the new buses 

with the 1:6 ramps a couple of months before that, and they started to experience the 

problems, which they contacted me about, and I couldn't understand it at first. I can kind of 

shortcut by saying there's quite a bit of this information in my comments to the docket, which 

has been posted by the Access Board along with other ones that -- from big blue and Santa 

Clara VTA own comments in parallel with mine. 

My comments are based on my project for them, though, not my own personal 

interests. So there's a relationship there. 

And in doing those comments in the project for VTA, I talked to quite a few other 

transit agencies and kind of -- we wanted to verify that this experience was happening other 

places, which we did. 

Part of the background is a little -- it's a little fuzzy. I think I understand it, and I just 

say think I understand it, but there is a lack of centralized research demonstration in testing. 

The USDOT previously did some more applied research than they do now, including especially 

with accessibility things, the original guideline specifications for lifts on buses came out of an 
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UMTA, USDOT project, and they got away from it for whatever reason, and I am involved in 

some other wheelchair accessibility research for transit but it's not housed in the public 

transportation industry; it's in the Department of Education, night, or national institute for 

developmental develop research. There is a project going on right now that is related to DOT, 

which is the transportation research board, transit cooperative research program, on issues 

with -- it started off with oversized wheelchairs and scooters and mobility devices but I think 

it's going to touch on pretty much everything, but this kind of research has been very 

uncoordinated in the past, and so there wasn't any real way to anticipate what would happen 

with a new ramp design like this, and to the manufacturer's defense, it kind of evolved over 

time, and something that I put in my comments was there's a previous version of the one 

manufacturer's of this type of ramp with the inside slope, fixed slope in the bus, and it was 

less of a slope. So when they went to making it a little bit more of a slope to get the overall 

1:6 slope on the whole length, it was a small marginal change, but it turned out to be just go 

over that tipping point where things started happening. So without some kind of vetting and 

ordering formal research and testing, it was easy for this to happen, unfortunately. 

And people have brought up the difference between -- or the relationship between lift 

and ramp manufacturers and the bus manufacturers. Some of them are very close because 

the bus manufacturers build their own lift, ramps especially, and others are not because it's a 

separate company and whenever you have that happen -- I dealt a long time with wheelchair 

securements and seating layouts in buses, and there's always this kind of disconnect, where 

one thinks the other is handling it. So that's another reason something like this could happen. 

But in finishing, I'd like to just say there are a lot of good comments that have already 

been posted and people that have ideas about it should really get comments in by the end of 

October to the Access Board. 

The main thing, though, that I wanted to say that came out of our review of things at 

Santa Clara VTA which was as recently as yesterday, we did more detailed looking at the ramp, 
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and they are, by the way, one of the other locations, besides Lane transit in Eugene, that has 

the prototype of the new version, I call it the, quote, solution, unquote, version. I don't know 

if it is the solution, but it is different and it addresses some of the problems, and that's why it's 

being tested. And it is being tested. So we can't say anything about whether it's the right 

thing or how well it's doing because it's just in the beginning of this evaluation and testing, 

which is a very good thing. 

But meanwhile -- well, I want to say one thing about what we did yesterday. We 

reconfirmed how difficult it is even to get up a 1:6 ramp. I am not a daily wheelchair user, but 

I use manual and power wheelchairs often enough that I'm pretty well-versed, and I cannot

get up a 1:6 ramp by myself in a manual wheelchair. I tip it over backwards. 

So people may have forgotten that the original proposal from the Access Board was for 

one to eight, which would be extremely difficult to put in a bus the way things are today and 

that's why it got dropped back to the 1:6, but the one and eight really is the more usable type 

of a slope than even what we're talking about. So it's kind of a -- it just hits home with how 

difficult this overall situation is we, Santa Clara VTA, myself, and some of the other systems 

I've talked to and the Access Board even, Chris mentioned it earlier recognized the inner 

relationship between the ramp and the bus vestibule and the fare box and the whole 

construction which I think really should be the focus and it's not fair to just put it on one or the 

other of them. 

But the other thing that came out of looking at this was the notice of proposed rule 

making itself and where we've come. It's been a long time just since this 1:6 ramp issue came 

up. Things are changing. We have the new prototype. There are other things going on with 

other bus manufacturers, but it brought up -- there are quite a few other questions in the bus 

and van specs that it's been so long since the proposals originally came out, first the drafts and 

then the noticed proposal rule making itself that it seems like it really would be beneficial if it 

could be reopened and allow comments again, because so much time has gone on that things 
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have changed. I know for my own part, I wasn't interested in the 1:6 ramp issue, and I 

commented heavily on the rear facing wheelchair location specification that, in fact, since 

then, King County Metro here in Seattle has adopted for their bus rapid transit vehicles, and 

it's a very promising technology and approach along with something else that I mentioned in 

my comment to the docket, which is second or rear door ramp boarding, and I think things 

that people brought up here already today point toward looking at that and having some 

more organized review of that kind of topic as a potential solution as well. 

But please, if possible, if the Access Board can look at either doing another NPRM, a 

reiteration to allow people to make comments, I think it would be very helpful. The rear facing 

situation since my comments went in November 2010, the ISO standard had been adopted, 

which is quite divergent from the ADA proposal. And I don't know which one's right. I can't 

say. I think more research is needed. I hate to be a broken record on that, but that's kind of 

where things stand, and I appreciate the opportunity to speak to you. 

MS. ANDERSON: Thank you, Doug. 

MR. HART: And, Doug, this is going to be because we really want this to not just be 

fake testimony, because we need to hear discussion from everyone in the room. 

We are here today to really deal with the front entry, fare box design layout issue. 

People are always free to comment on things that we don't ask about in what we put on APTA 

dot gov. We can't stop folks from commenting on questions that we ask but we really want to 

focus today primarily on on that boarding and fare box issue for questions that which Melissa 

can reiterate again, because in DC two weeks ago we had a very forward discussion, albeit 

with a much smaller group of folks, we had several manufacturers present in the room, 

including one who indicated that he had design process and he got into one and seven. Now, 

that was interesting to hear. Not everybody has gotten there yet, but having folks in the room 

begin to have that type of discussion of what it took to get to not just 1:6, to one and seven 
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October 2, 2012 Seattle, WA Page 18

was informative for all of us here on the board or for staff, and I would just say to you, to 

everyone in the room, the more you guys can help discuss what needs to occur, the better the 

rule will be. 

SPEAKER: Right. 

MS. ANDERSON: Thanks, Chris. 

I've added a link to our Web site up here on the board in case anyone needs it. Sorry I 

didn't have that up there. 

Comments are due by October 31st, and I think sometimes it's intimidating to step up 

to the mic. So we'd like to have more information from members of the audience, and if 

we've got a microphone we can pass around if somebody else would like to speak. I'd like to 

hear from some of the operators, if you've had similar experiences, and some of the bus 

manufacturers. What kind of challenges have you seen, and if you've started to implement 

these designs, what kind of feedback have you had from your customers and clients? 

And I kind of tried to stir up some of the fare box manufacturers because your real 

estate was in jeopardy in our meeting in Washington, D.C. So I don't know if there's any 

attempt at coming up with new fare box designs and freeing up some of the floor space, but, 

I'd like to hear some conversation on that too. 

So anybody else who would like to speak, raise your hand and we'll get a microphone 

to you. 

I think we've got somebody in the back. 

Paul. 
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SPEAKER: I can go to the podium if you prefer. 

MS. ANDERSON: Paul, why don't you get the microphone so we can start passing that 

around if we get more discussion. 

MR. HART: 

NOTE: not able to hear 

SPEAKER: I'm an individual. I don't represent anybody. I had spoken a little bit ago 

about the issue -- speak. 

My name is Tom. I'm not with an organization. 

MR. HART: Can you state your last name. 

SPEAKER: Reid. 

MS. ANDERSON: Thank you, Tom. 

SPEAKER: Sure. 

It relates to an issue that's ongoing for me for better than three years now, which I've 

received a response from the FTA regarding Sound Transit, particular bus organization that's 

recently come into the Puget Sound and offered extensive service and express service. They 

have a coach style bus made by MCI manufacturing that they use and it is a mid-way loading 

ramp deployed from underneath, which would escalate to the top of the bus and load you at 

center. There is a design problem with that bus. The ramp is not structured at the center of 
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October 2, 2012 Seattle, WA Page 20

the entryway; it's actually offset to the forward area of the entry. The front seats, all the 

seats, three go forward, three go aft, and you load at the center. 

The problem is, because of the orientation of the ramp and because of the seating in 

front, the lockdown position of the very backseat as the three forward seats are slid forward, 

directly encroaches on the doorway by at least three to 6 inches. You add further to that 

when the seat is reclined because they do as in aircraft seating, they do recline, and right in 

the back of the seat, each seat has a hand grab bar, which further encroaches on that same 

space. So there is no physical way to enter that access area with a right hand drive 

wheelchair. Mine is somewhat top-heavy but there's just no way because the hand and 

everything encroach right in the space for me to drive in. And I've actually got myself in 

serious dangerous situation, half hanging off that ramp and almost running people over in the 

bus because of my particular configuration. It just jambs and starts throwing things all over 

the place. I've been with drivers. I've called the organization and told them that I would be 

riding from a certain stop on a certain day. I've dealt with supervisors, and I get the response 

and it all has to do with haphazard training. I've been at the corporate headquarters and done 

safety issues with their staffing, had pictures taken, talked to their corporate executives, and 

the FTA board ruled that there's nothing wrong with these buses, and I haven't finished yet I 

intend to take it further but I have limited legal representation. 

So the problem exists. It can be visibly seen by somebody who would sit there and I 

could show them as it has been done in the past, but it's a really serious problem and I don't 

know that anybody's addressed it or is aware of it and I wanted to get it on the record. 

MS. ANDERSON: Thank you. 

Thank you. We appreciate your input. 

Anybody else? Michael. 
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October 2, 2012 Seattle, WA Page 21

SPEAKER: Once again, my name is Michael Collins. I'm from Redmond Washington. 

And I want to just follow up to what Doug Cross said about the mid-loading or rear 

loading ramps. I've used several of those. Those are what's used at a lot of airports. They use 

the smaller buses and they have the rear ramps, but they also, unlike -- well, like a lot of other 

manufacturers, have to find a place to put their luggage racks. So usually they put them just 

opposite the top of the ramp. So where you would have a really accessible vehicle and ramp 

configuration, you end up having to maybe turn out of the ramp pathway within 18 inches or 2 

feet of the top of the ramp, and it causes a lot of problems. 

The other successful, I think, rear lifts that I've been -- rear ramps I've been done on 

were the circulator buses in Washington, D.C., and. 

[APPLAUSE]. 

And those were something I was advocating for all systems to adopt because the rear 

ramps don't have the same problems they do with the front running gear on a regular bus. It 

seems that the floor in the rear can be dropped a little bit lower and if they deploy the ramp 

on to a sidewalk, the ramp is not too steep even though they were using shorter ramps. 

One other thing, even though I advocated for an 8-foot tall or long ramp that folds --

hinges at the bottom and folds out of the front door of the vehicle, the problem with that is 

many of the areas where people are being unloaded on to sidewalks in this community and 

elsewhere are finding minimal space to turn off the end of a lift or a ramp because of the 

width of the sidewalk not being sufficient for a normal unloading area. So all of those factor 

need to be taken into consideration. I don't think there is one solid solution that everybody 

can buy into. So we’re going to end up working around the edges for quite a while to come, 

and hopefully we do come up with a better solution than exists today. 
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October 2, 2012 Seattle, WA Page 22

And thanks for coming out to Seattle. I hope the board will hold every hearing that you 

hold in Washington, D.C., in this opposite end of the country. We like to be here. 

MS. ANDERSON: Well, we thank APTA for helping to host us. 

In fact, a big thank you to APTA, who has given us this space at no cost and supplied 

the AV equipment and wonderful AV staff. 

So I should have said that up front too. 

Is there anybody else that has something to say? 

Yes, ma'am. 

SPEAKER: Hi. I'm Annette Williams from the San Francisco municipal transit agency in

San Francisco. 

And just the up with thing I wanted to mention is we've, you know, obviously had 

accessibility for a long time, and we were reluctant to go with low floor buses for many, many 

years, and part of the reason was the 1:4 ramp. And we have a lot of situations in San 

Francisco where the ramp does go down into the street. We have places where the bus isn't 

able to make it to the curb. We also, you know, it's a very urban area have people that park in

bus zones, things happen. 

So I want to stress that the 1:4 ramp, at least in our community, doesn't work well at 

all, and we waited until we could get a ramp that was -- I don't know that exactly 1:6, but 

closer to 1:6, and we started with a bifold ramp and I'm not saying it's the great solution, but 

we really feel that we need to have a solution that isn't a 1:4 ramp that has -- and I think 
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October 2, 2012 Seattle, WA Page 23

Doug's right when he said that, you know, ideally it would be one and eight or -- you know, 

but I don't think that the ideal, unfortunately, is really physically geometrically possible in 

terms of the environment that we're working in with the space inside the bus and the 

sidewalks that we're putting ramps out to, but I just -- I want to stress that I think the 1:4 ramp 

that many of us, you know, evaluated over the years really is not a solution that will work, at 

least in our particular environment. 

I think there are some transit properties in the country where it is, you know, more on 

the 98 percent or the 95 percent of the time that they are able to get to a curb and deploy at a 

curb. I don't know. I just know that's not the case in San Francisco and that we really need a 

ramp that provides a lesser slope that makes it possible. 

And we tested 1:4 ramps many different types of configurations, and we always had 

problems with people, you know, chairs coming up and -- from a street, you know, if you were 

going from the street into the vehicle. So we were very happy to see manufacturers actually, 

you know, addressing the issue and looking at other ways to try to reduce that slope, and, you 

know, we don't want to lose that kind of momentum in that sense, at least from our particular

unique circumstances in San Francisco. 

MS. ANDERSON: Thank you. 

And that's very helpful because if we don't move forward and we just stay with what 

we have now, that's the result we'll have, is maintaining that 1:4, and the other current 

standard. So we want to try to move forward but we want to do it wisely with the best input 

we have from everyone. 

Any other comments? 

Doug? 
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October 2, 2012 Seattle, WA Page 24

SPEAKER: If nobody else does. 

MS. ANDERSON: No, that's fine. 

You guys aren't near as active as -- in D.C. it was a really interesting meeting. 

MR. HART: In fact, we ended up delaying lunch for our hour because people were so 

talkative. 

So, I don't know, folks didn't have coffee or what. 

MS. ANDERSON: I don't know. We could tell them that we're going to put a 60-inch 

radius turning requirement at the top of the ramp. You think that would stir them up? 

MR. HART: I don't think it would fit. 

MS. ANDERSON: Well, I don't know they're not telling us it won't. 

Okay, Doug, you want to -- did you have something else you wanted to say? 

SPEAKER: Yes, I actually have some responses to the four questions. 

MS. ANDERSON: Okay. 

SPEAKER: That are from both me and things that I talked with Santa Claire VTA about. 

First of all, the question about be provided without a grade break whatsoever, I'm 

wondering if it couldn't be broadened to mean a minimal. What is the maximum grade break 
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October 2, 2012 Seattle, WA Page 25

that is feasible to not have problems instead of an absolute just flat, straight slope? Because

there is -- there's a lot of variations. If you -- I think one of the important things to do in the 

engineering and analysis of this is, like the little hand drawn pictures in my comments, that put 

the different scenarios in front of you and with different, I think, engineering type drawings of 

different kind of wheelchairs, with their wheel base and size of wheels and length and so 

forth, because there's a comp -- again, there's a complicated set of inner relationships and the 

length of the slope section with the angle of the slope section together with how it interfaces

with the flat floor is very complicated. You basically cannot do what you're asking for without 

some kind of compromise somewhere. Unless you have a completely different looking kind of 

bus. I'm not sure. 

The kneeling question is -- kneeling lower definitely helps the situation, but how far 

down can you expect buses to kneel? That's another research topic, I think. What's 

reasonable, what's doable? What kind of engineering research would need to be done? 

Again, on a centralized basis, for the whole industry, instead of expecting each manufacturer 

to do it on their own, obviously the ones that have done it on their own and got farther ahead 

have really great products, but that's not, as you've heard, that's not the way buses are 

bought. You can't just say I'm going to pick the one that I like the kneeling on. It is a bigger 

picture than that. 

The issue about the fare box I think is maybe the most important, and a couple of the 

constraints that I've heard about are the vault of the fare box. There's still enough cash being 

paid on boxes to require a good sized vault, and that's a study I think that could be done

somewhere. What kind of diminishing of cash payment of fares can we expect with the new 

electronic media and programs that are out there, and also what kind of different design of 

the fare box, and that, again, kind of comes together with the fare box manufacturers being 

separate from the bus manufacturers, and really it's a joint problem of where it's going to fit. 

Because you can't -- there have been a lot of comments, and my initial reaction is just move it, 
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October 2, 2012 Seattle, WA Page 26

you know. Well, it's not that simple, and it has to be reachable by the bus operator and by the 

passengers that are using it. So it's a pretty involved set of measurements there. 

The same goes for the pedestal that it's on when it's also serving as a foot step for the 

driver to get into the driver's seat area. I think some work could be done along those lines, 

and the one picture we have of the new flier with the semi cantilevered box and the cut down 

foot step area I think is a good example to kind of try to see if it can be taken further. 

So I don't know what kind of clout Access Board has with DOT and other federal level 

research agencies, specifically RETA research administration, but I think there's a lot of work 

that needs to be done before you can answer all these questions because everybody -- they're 

so broad. You've got the different constituencies here that conflicting goals, and I think that's 

going to be your big challenge. 

MS. ANDERSON: Thank you, Doug. 

MR. HART: Doug, is there a fare box manufacturer that you know of that is offering a 

smaller footprint for let's say larger systems, not a smaller Lane county, but larger. 

SPEAKER: Right. 

Not that I know of. I know what you're speaking of because I've used them in systems 

that I've worked for is the small fare box that's, you know, two or 3 feet tall and it can be 

bottled to a stanchion. That would be beautiful, but right now it's not working. And the other 

thing I forgot to mention is the standardization of fare box pretty important. I'm not directly 

knowledgeable about it but what I've been told is that having different kinds of fare boxes

with different vaults, different kinds of vaults in one transit systems is problematic. 

MR. HART: Any time you have different variations, whether it's a fare box or a fan belt. 
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October 2, 2012 Seattle, WA Page 27

SPEAKER: Right. It's a cost. 

MR. HART: The more stuff you're going to have to keep up and maintain. 

SPEAKER: Right. 

Right. 

MR. HART: One of the comments, and I want to open this up to anyone, that we had in 

DC was if there was a slight angle on the ramp or the front entry door, so it wasn't a complete

90-degree turn, let's say it was an 87-degree turn, may help that turn maneuver, but we need 

to here more about that. 

Have you seen here in the states or overseas that offer that slight angle. 

SPEAKER: Yes. 

That's a great point, and I know of one particular North American -- should I say which 

country they're from -- bus manufacturer that has a wider door and wider door area, and it 

allows that different angle. It's not a constrained -- as constrained a 99-degree turn. It's got

that angle. 

There is also a low floored body on chassis manufacturer which would be the cut away 

van chassis type that has deliberately engineered the door and the ramp area to be offset at 

an angle just for that purpose, and I think they gave testimony and had their information. 

MR. HART: Yes, they did. 
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October 2, 2012 Seattle, WA Page 28

They were also offering a one and seven slope depending on curb height. 

SPEAKER: Right. 

And that brings up another issue. Say if that bus is what a transit system thought was 

best, can they just say we’re going to buy that bus, or do they need to follow federal 

procurement guidelines and have more than one vendor available to do it. So that starts to 

get to be a sticky wicket. 

MR. HART: That's outside of our scope. 

MS. ANDERSON: That is outside our scope, but like I tell people when I do right away 

training, he who has the gold makes the rules, and FTA and Federal Government have a lot of 

transit money that's going out there. So it's their rules you have to follow. 

Does anybody want to offer up any information about maybe upcoming technology in 

fare boxes and -- we've had some internal discussions about, well, so many things are 

electronic and Wifi and all that type of thing. Is there a movement towards making the fares 

more electronic and maybe eliminating fare boxes over time or mounting them differently so 

that the floor space is freed up? 

We've not been talking about a 60-inch diameter circle, by the way. 

(Laughter) 

SPEAKER: Oh I thought that was already a rule. 

MS. ANDERSON: No. I'm just trying to wake you guys up. 
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October 2, 2012 Seattle, WA Page 29

SPEAKER: Well, you woke me up. 

There is one research project that has the fare payment technology as one of its 

focuses, and that's the rehabilitation engineering research center for accessible public 

transportation at the university's of -- it's the university at Buffalo Suni and Carnegie Mellon, 

and they have a lot of emphasis on the modern technology kind of things. And they're also 

mocking up bus interiors for movement mobility space, mobility device maneuvering, and I

have included them on some of my out reach on the 1:6 topic, but I haven't heard anything 

back from them. Interestingly enough, they're in Buffalo which is one of the places that has 

the 1:6 ramp buses that have the problem. So I -- you can't make them do something along 

the lines specifically tailored for what you're talking about but you could sure encourage them 

to. I think if they heard from more people

that -- how big of an issue this ramp thing is and not just the overall slope, I think everybody 

acknowledging what Annette Williams from San Francisco muni said and I did about the 

overall slope, everybody kind of knows what that scenario is, what works and what doesn't, 

and what our goal is, but how you accomplish it and how it fits in the bus is the big thing. And 

it gets into a lot of heavy-duty engineering and construction stuff that's over my head. 

MS. ANDERSON: Does anybody else have a comment? I think we've got one at the 

back here. 

SPEAKER: So I'm Kendra from King County here Metro here in Seattle and I'm coming 

mostly from the bust stop planning environment. Got accessible services folks from our 

agency flanking me here too so they're a wealth of knowledge. Feel free to correct me. 

Just to quickly point out there is an APTA session tomorrow approximate nonfare box 

revenue. So I think it's what time? A, you can find it. But I just wanted not to stray too far 

from the topics being posed here, but from the bus stop environment, I think I can probably 
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October 2, 2012 Seattle, WA Page 30

echo the thoughts of San Francisco in terms of the slope. We're kind of in the midst of a new 

trolley procurement, and I think what's peaked our interest is the idea of these ramps on our

very steep hills here in Seattle. I think about a third of our ramp deployments -- or lift 

deployment rather occur on our trolley system as about a third of our rider ship is on our 

trolley system. So we're kind of facing this front of we don't know exactly how these ramps 

are going to be for users on our very steep hills. I think we have some that are in the realm of 

17 percent grade. So when you're talking about a 1:4 or even a 1:6 slope deployed to the

ground on these very steep hills, the resultant force is a pretty steep one in the diagonal 

direction. So part of that discussion has been for us, you know, handrails or things of that. 

Nature. That's come up as a topic. So just something to be aware of and thinking about as 

we're kind of getting into that procurement process. 

So I guess that probably would apply to San Francisco too as they're quite hilly. 

SPEAKER: And Oakland. 

And Oakland yes. 

SPEAKER: Pittsburgh, Cincinnati. 

So just a discussion on how these ramps play with the street environment is of interest 

to us in particular as we're facing this procurement. 

The other thing I just wanted to bring up, I came from a State Department of 

Transportation background, and more in the realm of roadway design so I was pretty surprised 

when I came here to Metro to see the huge discrepancies between roadway design and, you 

know, these vehicles, and it was quite shocking to see, you know, a 1:4 slope where I was used 

to designing one to twelve for, you know, the ramps, the curb ramps. So I guess along those 

same lines, I was used to very frequently laying out auto turn plots for trucks as they're 
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October 2, 2012 Seattle, WA Page 31

moving through a turn from a left turn lane to a receiving lane, and I guess I'm wondering if 

that can't be something that we work into a procurement process or into some contract 

language where we'd want to see the particular ramp and the particular bus, the earn 

environment laid out with a sort of auto turn plot showing maybe the maximum design 

vehicle or wheelchair if you will making that turn through the front of the vehicle. It makes a 

lot of sense to me and we require it for a roadway design. It would make sense to try to work 

in that direction here too. 

MS. ANDERSON: Thank you very much. 

SPEAKER: Do you guys want to add anything? 

No. 

SPEAKER: Okay. I'm good. 

MR. HART: Kendra, you're actually gave us a great segue. The board staff has been 

developing some new technical assistance guidelines, technical assistance material, not 

guidelines, and one of the elements that the board staff is working hard on is actually 

borrowing how the basic building blocks. Let's say opening a door so folks who look at the 

code and go what does this mean. 

SPEAKER: Sure. 

MR. HART: Could actually be -- basically see what that means, and I think for a lot of 

folks who are not necessarily engineers, the visible can be immensely helpful. We're nowhere 

near to getting tomorrow vehicles, but it's something -- there's no reason why the industry or 

APTA or FTA in conjunction with APTA could not pursue something like that. 
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SPEAKER: Sure. 

MR. HART: It would probably be helpful for all of us. 

I am curious, when you are deploying a ramp on a -- I don't know, we'll pick on fourth 

Street area, whatever block you want. I've gone up so many hills, I don't remember, but. 

(Laughter) 

Do you find premature wear on one of the hinges because of the hill deployments, or is 

that not as -- 

SPEAKER: Yeah so if we're talking about kind of a differential between one end of the 

ramp, absolutely that's an issue. 

So part of this is that our trolley system right now is, it still has the old lift. So we 

haven't really gone full blown into ramps on our hills yet. I mean, certainly there's hills 

throughout our can the, but some of the biggest ones are here in downtown Seattle. So we -- 

MR. HART: I noticed. 

(Laughter) 

SPEAKER: So we haven't quite noticed what that's going to be experienced street do 

you mean trackless trolleys. 

I'm sorry, we call them the overhead wire. 

SPEAKER: Trolley buses. 
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October 2, 2012 Seattle, WA Page 33

Sorry, I throw people off a lot with that language. 

MR. HART: I figured you meant trolley buses. 

SPEAKER: So there's multiple issues going on one being we just don't have a lot of 

experience with it yet but that is certainly -- when we've gone out and done field tests with 

these ramps on these hills that is one of the issues that there's a 3, 3-inch gap between where 

it's hitting the sidewalk or the street space and where it's not. So that is a definite concern for 

us. 

MR. HART: Part of why I ask is the guidelines do not require nearly as who use the 

ramps were supposed to mandate nearly all the time but we need and Doug, [indiscernible], 

when you have a bus that's on a hill, things tend to be the 15, and then you kneel the bus

further, you're compounding the tweak on the indent of that ramp and it may actually be 

more detrimental to kneel the bus. 

SPEAKER: Yeah, I guess that is a good point. 

MR. HART: But we don't have any real data. 

SPEAKER: Yeah, and I guess in my experience so far, the hills that we've tested it on, it 

seemed that the kneeling helped that differential but maybe that's because we were downhill 

instead of uphill or whatever, but, that is something to take into consideration. 

I think most of all of our procurements now are for kneeling buses. That is something 

we specify as an agency and it's something we probably need to be looking at specifically for 

these trolleys. 
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MR. HART: And it may vary where there is a piano hinge style versus a different hinge. 

SPEAKER: Yeah, definitely. 

MR. HART: But when folks have some bracing, it would be good for the board to have 

that. 

SPEAKER: Yeah, that's something I can check with our vehicle maintenance 

department with. 

MS. ANDERSON: Do we have any other comments? 

SPEAKER: I'll just step back really quickly. 

MS. ANDERSON: Can you restate your name. 

SPEAKER: Andy Vabora. The question about changing to a cashless system. We've 

had that discussion a number of times. For small agencies like ours or just even going to 

automated fare boxes where we have just really standard basic fare boxes is a huge financial 

investment for us to change over our fleet. So our new general manager is very passionate 

about going to automated fares and wants to get it there now with new map 21 language and 

no discretionary grant program and a lot of pressure on our 5307 funds it's going to be a little 

more difficult to achieve some of those changes but it's something at least on the automated 

fare side we want to move toward but I guess one of the questions I would have would be 

some of the Title six complications of going cashless and what that would do to some of those 

populations so it's a very complex issue for organizations to deal with. 
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October 2, 2012 Seattle, WA Page 35

This is Doug Cross again. I was thinking with the change in the environment not 

necessarily requiring cashless but with all of the encouragements for new types of electronic 

and smart media as well as passes and multiple

ride tickets and so forth, being less of a need for the cash and coin hold capacity, which seems 

like a really good topic for TCRP or somebody to study specifically, and 23 they had the 

motivation of this accessibility need, getting just the ability to get a foot and a half or a little 

bit more up off the ground, the foot rest area of mobility device users would be awesome. It 

would be really beneficial in this problem we're talking about. 

MS. ANDERSON: I'm not going to keep everybody here and torture you -- oh, we've 

got another comment back here. 

MR. HART: Pat. 

SPEAKER: I'm Pat PIRES. I represent only me. And I came in lately so I don't know if 

anybody mentioned the FTA draft chapter of their ADA circular that was issued today 

regarding vehicle acquisition of accessible vehicles. 

MS. ANDERSON: No. I think that's something we'd probably all like to hear. 

SPEAKER: Okay. Well, I did a super quick review on t. but the main thing is that it's 

open for a 60-day comment period, and so people might want to correlate the various 

activities going on as they comment, but the draft chapter, they're going to construct this 

circular on a chapter by chapter basis, and the first chapter is with regard to acquisition of 

accessible vehicles which they think is the simplest topic to address. 

(Laughter) 
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SPEAKER: No comment. But particularly in light of some of Doug's comments about 

the federal procurement rules, people may want to bring forth comments about how the

procurement process itself can help to increase accessibility to the extent that that's desirable 

goal. The draft chapter largely speaks primarily -- it covers all sorts of vehicle, not just buses, 

and it really repeats the regulations in Part 37 with a few references to Part 38 and says, oh, 

by the way, some of these may change. It also includes a sample checklist that apparently is 

used by the current or some sort of -- some of the consultants for FTA who do the vehicle 

reviews which still includes a reference to common wheelchairs, interestingly. So they may 

want to change that when they finalize the document. But given that that's relating 

acquisition, you know, they're -- I would suggest people look at these issues in relationship to 

each other. 

MR. HART: Thank you, Pat. It's good to know. 

SPEAKER: Where do people find it? 

You can find it either -- I didn't -- the notice that came out for people who are 

subscribed says go to the ADA page on the FTA Web site. You can also get it from the circulars 

page where it's listed under proposed circulars. But there's two documents you have to look 

at. There's a federal register notice that describes the process, then there's the draft itself. 

SPEAKER: What effective law does a circular have. 

It is guidance. 

But under SAFETY-LU after notice and comment it can impose a binding obligation on 

recipients. 

MR. HART: It's grant guidance. 
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October 2, 2012 Seattle, WA Page 37

MR. CROSS: Grant guidance. 

MR. HART: Know it at your peril. 

MS. ANDERSON: It's back to the he who has the gold makes the rules. 

SPEAKER: Just real quick sense it was brought up about the fare boxes Tom Reid, 

individual, the fare boxes seem to be a critical issue here. I notice a lot of the buss are going 

to GPS and announcement services for the blind and I thought that it would be a good idea to 

address the same idea with the fare boxes which only have a visual readout. There should 

maybe be something there for the blind something audio that tells them the amount that was

reduced from their card or fare, whatever, especially if we're dealing with a cashless system so 

they're aware. 

MS. ANDERSON: Thank you. 

MR. HART: Tom, are you suggesting -- are you saying that that needs to be addressed? 

SPEAKER: Yes it does if you're looking at fare boxes as an integral part of the vehicle 

and you're redesigning it that's something to incorporate in the redesign as I see them 

upgrade the same buses with new technology for GPS and announcing stops, whereas the 

drivers used to have to do it the fare box should do the same thing for the blind and announce 

the amount that was taken off the card so they're aware of where they stand. If you've got a

low value and you have visual, then you can see it there on the readout and you can hear it 

when it beeps a certain way that you have a low card value. That makes sense. But you only 

right now have a visual but you don't have an audio for somebody to say what value was just 

removed from my card. With a it is a transfer? Am I within the two hour window? Did 75 
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October 2, 2012 Seattle, WA Page 38

cents extra get taken out because I just went on link light rail. I mean these things I would 

guess people of certain disabilities, especially thinking of blind, would need to know, for audio. 

MR. HART: Effective communication. 

SPEAKER: Yes. 

MS. ANDERSON: Thank you. 

Any more comments? 

MR. CROSS: Sorry. 

MS. ANDERSON: That's okay. That's what -- we're here to get information from the 

public. 

MR. CROSS: I just wanted to bring up a side issue about one of the problems we have 

maneuverability of wheelchairs and scooters and this issue of the turn at the front of the bus 

with front door ramp boarding and the more or less 90-degree turn is that there is a parallel, I 

guess, world of wheelchairs and scooters, and they will say what their wheel base is and 

turning radius, but that isn't equated with how tight of a turn in a constrained space you can 

make. So there are a number of especially four wheeled scooters that might have even fit 

within the old common wheelchair envelope that cannot make that turn at the front of the 

bus. 

MR. HART: I know. I used to have one.
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(Laughter) 

MR. CROSS: So it's like -- it's something that it hasn't fallen through the cracks. It 

never even made it that far. And I've worked on it some myself. If anybody's interested I 

could talk about something a client of mine had to do with measuring wheelchairs they were 

buying for a plaintiff in a lawsuit that had to fit on buses. So we did some analysis, but each 

bus is different and the wheelchairs are different. So there's no template. You can just apply

and say, okay, this one's going to make it, this one isn't. Sometimes it depends on the skill, 

experience of the user of the mobility device, and other factors Mike brought up about fire 

extinguishers and other things that get put in the way. So it's an interesting problem, dilemma, 

I guess, that's kind of related to what you're talking about with the ramp, being able to turn at 

the top. 

And having that flat space, I mean, how much -- that's one of your questions I think 

that really begs a lot of looking at, is how much space is needed for different types of mobility 

devices. 

And one of the comments that got posted to your docket already was also I think very

telling where it's a consumer and they suggested that whatever new ramp designs are tried be 

checked out by people with different mobility devices and different capabilities instead of just, 

you know, like we do with these standard -- old standard manual wheelchair, we see some of 

the problems but we probably don't see enough to have a good broad picture. 

MR. HART: We always crack up when we see video of old intake 1970's airport style 

manual chairs because that's not what you'll get today. You would kill yourself trying to wheel 

that today. We have come so far in technology, but a lot of folks don't realize it and that's the 

first thing used as a model. 

MR. CROSS: True. I think they just took a picture of that out of the federal ADA regs. 
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October 2, 2012 Seattle, WA Page 40

MR. HART: Yes, we did. That was a common wheelchair. 

And you're quite right, the four wheeled scooter, I'll pick on one of many distributors, 

(indiscernible) it still does. It's quite popular but the turn radius is gigantic. 

MR. CROSS: Right. And that's the problem that four wheeled scooters are getting 

more popular with senior citizen users and people that don't have a full-time mobility need 

and they don't know when they buy, especially if they haven't been regular transit users 

before and then they go out and try to do it, and they can't. It's pretty bad. 

SPEAKER: Once again I'm Jonathan porter. 

I guess the thing I'm curious and I think the Access Board should look into is I know that 

some of these buses that Seattle has with the 1:6 that are having the vertical drops and the 

double dip as it was called earlier today, those buses are relatively new so I'm curious to see if 

the Access Board or if federal or the City's going to push to when those issues are corrected or 

they're found to be unsafe which it seems like many of us are saying they're unsafe in a lot of 

ways it will then be pushed to be pretty much fixed or removed. I understood the older buss 

are going to get eventually phased out but these ones that are three or four years old in terms 

of a bus lifespan really isn't that old. So it would be interesting to see if those are going to get 

phased out or fixed or corrected as opposed to saying, well, you know, this bus is kind of new 

so we need to keep this but we'll bring in new ones slowly but surely but we still have these 

unsafe ones which are still going to have the same problems especially with the way they've 

tested chairs and everything. 

MS. ANDERSON: Now, the Access Board develops the guidelines and we don't decide 

when and how they are implemented. That will be up to the USDOT, and I can tell you that in 

-- what has happened in the past is there has been kind of a phase-in period. There's a phase 
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October 2, 2012 Seattle, WA Page 41

in time that the changes will take full effect at a certain date, and the guidelines apply to new 

and altered products. So I don't know how the DOT will handle the implementation. 

There is a bus company, either the operating company, management company, and 

the bus manufacturers and the ramp manufacturers, they're all kind of at a liability risk if they 

don't have a safe product. So I think just because we live in America that may sort itself out as 

far as liability and safety. And it's beyond what we do in the way that our guidelines are 

typically implemented. The DOT could come out and do something entirely different and say 

that something, they could do whatever they wanted with their implementation, but typically 

it's -- the guidelines only apply to new and altered products. 

MR. CROSS: Yeah, that's true, and sorting itself out is pretty much what is going to 

happen, but it's already started to happen. I didn't mention it, but one -- or I did mention 

Stockton, San Jaquin regional transit district. They have a different ramp manufacturer than 

Santa Clara VTA and some of the other ones, and they are looking at retrofitting not a new 1:6 

ramp, but an older 1:4 ramp to

eliminate the double dip problem as you call it. But that's a negotiation between them, and 

there's no federal or state law or rule that's controlling that. It's pretty much a procurement 

thing between them. And you've heard mention of the at Lane transit in Eugene and Santa 

Claire VTA in San Jose of the prototype of the lift you new style 1:6 ramp in testing, and that 

one is possible, as far as I know, butt, you can correct me if I'm wrong, it is possible to retrofit 

that one into the previous 1:6, the one with the problems if it turns out that's going to be the 

way to go or something similar to it, but as far as I know the 1:4 can't be retrofitted into it. So 

your issue is there are going to be some buses out there for a while, at least, that have the 1:6. 

But something that hasn't been brought up is there are a number of places where they 

don't -- they either don't have problems with the 1:6 or they haven't had it yet to the extent 

where it's risen to the level of what we're talking about here, and I think that's going to be 
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October 2, 2012 Seattle, WA Page 42

very interesting to see as those -- I think those buses with the 1:6 ramp are still being 

delivered. 

Is that true? 

Yes, they're still being delivered to places around the country. So your question, your 

point is really going to be happening here for the foreseeable future. 

MS. ANDERSON: Okay. 

Any other comments? 

SPEAKER: Andy Vabora. Our following testing on these early tests have been very 

positive is again to retrofit. Again we're a unique situation maybe we're not Seattle. I don't 

know how many buses you guys have but we only have 24 of these buses. So the retrofit is 

pretty easy and painless we're pre appreciative of the work that the manufacturer is doing and 

our intent is to retrofit our buses. 

MR. CROSS: I should add that Stockton is eight buses so it's even a more doable 

situation. 

MS. ANDERSON: And we don't mean to put any particular manufacturers or bus 

companies or operators on the spot. There are some companies that have come up in 

conversation and we know that some of the companies are working hard on different options 

and different designs. So the industry changes pretty frequently. 

Go ahead. 

SPEAKER: This is Mike Collins again. 
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October 2, 2012 Seattle, WA Page 43

I just wanted to give everybody a reminder of what we're working with here. You 

know, the ADA guidelines for a ramp are one and twelve, and preferably one and 20. So we're 

talking about something that as best is twice as steep as the accepted standard for curb ramps 

and for any other ramped surface under the ADA. So if we get to one and six without any 

drop-off to the side and a full turning radius to the top, that's great but we should aspire to 

greater if we ever can. So something for the designers to set your goals to and good luck. And 

thanks again for coming. 

MS. ANDERSON: Okay. If we don't have any more comments, I won't make you guys 

sit here in torture. 

Anybody who wants to stay and have further conversation, you're more than welcome 

to. 

MR. HART: However, if you talk to us after. 

MS. ANDERSON: It will be on public record. 

MR. HART: It won't be on the record and therefore -- 

MS. ANDERSON: It will be on public record. 

MR. HART: Oh, okay. 

MS. ANDERSON: It will remain on public record but I don't want to keep everybody 

beyond what you're really interested in hearing, but I do want to encourage anybody -- here, 

we've got another comment. 
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October 2, 2012 Seattle, WA Page 44

SPEAKER: Point of clarification. If -- sorry, my name is Stanton Saucier and I'm with the 

Ricon corporation. I wanted to -- if we follow up with you after the fact with a comment, 

because a few things have come up here that I'd like to look into and come back to. Is there a 

blog format or someplace where this stuff will be posted or if I simply address yourself after 

the fact, I'd presume that also goes into the public record. 

MS. ANDERSON: I can't tell you that it -- if it's a substantive comment that affects rule 

making decisions. 

SPEAKER: Yeah. 

MS. ANDERSON: Then it would become -- it would have to be part of public record. 

SPEAKER: Very good. 

MS. ANDERSON: But, if you have questions, we're always available for an e-mail a

phone call, but we do have to make sure that the input that we get that affects our rule 

making is -- 

SPEAKER: Is made public. 

MS. ANDERSON: Is made public. 

SPEAKER: Right. 

MR. HART: And that's on regulations dot gov in the docket. 

SPEAKER: Understood. 
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October 2, 2012 Seattle, WA Page 45

Thank you for that. 

And, thank you for the opportunity to come and listen, sincerely. This is really the first

time that the persons on the end of this bit of tech knowledge, the assessable bus have had a 

voice in what is going to happen with it, and I think this is really the way the thing needs to go 

forward. 

MS. ANDERSON: Yeah. 

And well we appreciate everybody attending, and I would encourage everybody, you 

can read the whole rule on regulations dot gov. You can access it from our Web site, and I 

would encourage everybody to submit comments on regulations dot gov before October 31st, 

and if you have any questions or clarifications, you're welcome to contact me. I've got 

business cards up here. We have three different staff members that are working on the rule 

and everyone's always welcome to come to our regular Access Board meetings. Mostly 

they're held in Washington, D.C., which I know isn't always convenient for everyone. We try

to travel around. I don't know where we're going next year. 

MR. HART: However, we will be in the Bay Area next May, dates to be announced. 

MS. ANDERSON: So the Access Board gets out once or twice a year. 

MR. HART: Yeah, once or twice a year we're out of town, but in industry specific rules 

like this one, we do our best to always reach out to business association that represents that 

industry. 

So not having input from folk would not be helpful. 

MS. ANDERSON: And there is a chance that either later this fall or early spring we may 

be doing kind of a road trip to different manufacturers or ramp companies to see what kind of 

products, just an educational opportunity really for those of us working on the rule to become 

better informed and to see what some of the limitations and restrictions are that everybody's 

dealing with and that type of thing. So that might be happening. 
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And if you haven't -- we're trying -- budgetary constraints and several other constraint, 

we're trying to keep a pretty limited area, but if you would like for us to come and visit, you 

know, let me know. We can talk about it. I don't know for sure that we're going to do it, but

it’s a conversation we're having there in the office. 

So with that, I guess I'll let everybody go. Anybody who wants to stay is more than 

welcome. We'd love to hear more technical stuff. Thank you very much. 

[APPLAUSE].