Access to Over-the-Road Buses for Persons

With Disabilities

May 1993

OTA-SET-547

NTIS order #PB93-192912

GPO stock #052-003-01320-7
Recommended Citation:

U.S. Congress, Office of Technology Assessment, Access to Over-the-Road Buses for

Persons With Disabilities, OTA-SET-547 (Washington, DC: U.S. Government

Printing Office, May 1993).

1 For sale by the U.S. Government Printing Office

Superintendent of Documents Mail Stop: SSOP. Washington, DC 20402-9328

ISBN 0-16 -041734-1
Foreword

A

s part of the Americans with Disabilities Act, Congress instructed the Office of

Technology Assessment (OTA) to analyze the complex issues of access for all

persons to over-the-road buses (OTRBs)-buses with a high passenger deck

that are commonly used in fixed-route intercity service, as well as for charter

and tour trips.

OTRB transportation is an important element of the U.S. transportation system.

Companies offering regularly scheduled service with these vehicles serve a portion of the

population—rural residents and people with low incomes-with few other travel choices.

At present, very little of this service is accessible for persons with disabilities.

The issue of ensuring access to OTRBs by persons with disabilities while

maintaining adequate service is complicated, in large part because of the generally difficult

financial circumstances facing much of the OTRB industry. OTA finds, however, that there

are encouraging reasons to believe that accessibility can be achieved with little degradation

of service.

First, technologies to assist passengers with mobility impairments onto OTRBs

are available, and OTA anticipates that improved, lower cost technology will enter the

market. In addition, allowing a phased implementation over the replacement cycles of

vehicles will enable thoughtful, company-specific decisions on technology choices. The

phased implementation will also permit members of the disability community to become

familiar with the new equipment and practices, and to develop trust that this service will

be provided.

This report is part of a process leading to regulations to be issued by the U.S.

Department of Transportation. This process has included a review of a draft of this study

by the Architectural and Transportation Barriers Compliance Board (ATBCB). OTA thanks

ATBCB for its prompt response, and thanks the members of the Advisory Panel as well as

those who participated in study workshops, reviewed various drafts, or otherwise

contributed. These groups provided valuable comments, suggestions, and information.

However, their participation does not necessarily represent an endorsement of the contents

of the report, for which OTA bears full responsibility.

(7+’- -

Roger Herdman, Acting Director

.,.

Ill
Advisory Panel

Charles B. Wheeler, Jr., Chair

President

Wheeler Medical Laboratories, Inc.

Kansas City, MO

Robert C. Brown

Senior Vice President

Lehman Brothers

New York, NY

Richard V. Burkhauser

Senior Fellow

Gerontology Center

Syracuse University

Syracuse, NY

Kenneth M. Campbell

Executive Director

Ohio Developmental Disabilities

Planning Council

Columbus, OH

Joseph M. Dabrowski

Vice President for Engineering

Transportation Manufacturing Corp.

Roswell, NM

Joseph S. Dusenbury

Commissioner

South Carolina Vocational

Rehabilitation Department

West Columbia, SC

Marlene Eide

Commissioner

Williams County

Williston, ND

Lex Frieden

Senior Vice President

Texas Institute for

Rehabilitation Resources

Houston, TX

Frank M. Henry

President

Frank Martz Coach Co.

Wilkes-Barre, PA

Ralf Hotchkiss

Director

Wheeled Mobility Center

San Francisco State University

San Francisco, CA

Fred E. Kaiser

President

Kerrville Bus Co., Inc.

Kerrville, TX

Theodore Knappen

Principal

Government Affairs

Management Associates

Washington, DC

Jack Michaels

Technology Access Consultant

Seattle, WA

Ronald R. Moore

President

Burlington Trailways

West Burlington, IA

Walter A. Spencer

Senior Vice President

Cole-Layer-Trumble Co.

Vandalia, OH

Patricia Weaver

Assistant Research Scientist

University of Kansas

Transportation Center

Lawrence, KS

James A. Williams

Chairman

United Transportation Union

Local 1564

Irwindale, CA

Ex-Officio Members

Robert Ashby

Deputy Assistant General Counsel

Office of the Secretary

U.S. Department of Transportation

Washington, DC

Donald Trilling

Director, Office of Transportation

Regulatory Affairs

Office of the Secretary

U.S. Department of Transportation

Washington, DC

Lawrence Roffee

Executive Director

Architectural and Transportation

Barriers Compliance Board

Michael H. Sharff Washington, DC

Assistant Secretary of Transportation

Massachusetts Executive Office of

Transportation and Construction

Boston. MA

NOTE: OTA appreciates and is grateful for the valuable assistance and thoughtful critiques provided by the advisory panel

members. The panel does not, however, necessarily approve, disapprove, or endorse this report. OTA assumes full responsibility

for the report and the accuracy of its contents.

iv
John Andelin

Assistant Director

Science, Information, and Natural

Resources Division

Nancy Carson

Program Manager, Science,

Education, and Transportation

ADMINISTRATIVE STAFF

Marsha Fenn

Technical Editor

Gay Jackson

PC Specialist

Tamara C. Wand

Administrative Secretary

ELIZABETH ROBINSON

Project Directorl

Stephen Garcia

Research Analyst

Daniel Broun

Research Assistant

Edith B. Page

Originating Project Director2

Preject Staff

Elizabeth Sheley

In-House Contractor

Robert Gordon

In-House Contractor

Jonathan Atkin

Analyst

CONTRACTORS

Econometrics, Inc.

Bethesda, MD

Jeffrey Jakubiak

Intern

Cleveland Thornton

Bromley, Greene & Walsh

Washington, DC

Kathi Hanna

Churchton, MD

1 After May 11, 1992.

2 Through May 11, 1992<

v
1

2

3

Executive Summary 1

How Might Accessible Service be Implemented?

What Might the Impacts Be? 3

What Can Congress Do? 4

Summary and Conclusions 5

Over-the-Road Bus Service in the United States

The Demand for Accessible Service 13

Technologies for Accessible OTRBS

and OTRB Service 20

Standards, Implementation, and Costs 25

Impact of Accessibility Requirements 35

Public Financial Assistance for OTRB Owners

Over-the-Road-Bus Industry and

Accessible Service 41

Findings 41

Characteristics of the Industry 42

Fixed-Route Scheduled Service 45

Charter and Tour Service 54

Service to Rural Areas 59

OTRB Accessibility Prior to the Americans with

Disabilities Act 68

Present DOT Regulations 70

Demand for Accessible Over-the-Road

Bus Service 73

Findings 73

Background 7 4

Persons With Disabilities in the United States

Experience With Accessible Service 82

The Difficulties of Projecting Demand 92

(Continued on next page)

2

8

36

74

contents

vii
4 Accessibility Technologies for Over-theRoad Bus Service 97

Findings 97

Technologies To Assist Persons With

Mobility Impairments 98

Technologies To Assist Persons With

Sensory and Cognitive Disabilities 108

Training To Facilitate Accessible Service 111

Appendix 4A—Requirements for Vehicle-Based

Lifts, Ramps, and Securement Systems 113

APPENDIXES

A

B

c

D

E

F

Reasonable Cost Estimates for

Implementing Accessible Over-theRoad Bus Service 115

Federal and State Oversight of

Over-the-Road Bus Service 132

List of Boxes, Figures,

and Tables 138

List of Acronyms 140

Contractor Reports Prepared for

This Assessment 141

Workshop Participants and

Reviewers and Contributors 142

Index 747

. . . Vlll
Executive

Summary

A

milestone for American society, the 1990 Americans

with Disabilities Act (ADA) responds to the needs of

those with disabilities, and makes clear that inconvenience or uncertainty of demand for accessibility cannot

obstruct rights of employment, commerce, and transportation.

Although the act carries with it considerable costs of implementation, it reflects a national consensus that the benefits are worth

the costs.

In congressional debate over the ADA, particular difficulty

developed around the issue of access for individuals with

disabilities to transportation on buses with a high passenger deck,

otherwise known as over-the-road buses (OTRBs). OTRBs are

most often used in scheduled service that takes passengers from

city to city, or on local and regional tours and charter trips.

Uncertain about the feasibility and cost of OTRB accessibility

technologies, Congress was concerned that the burden of

implementing the ADA might cripple an already struggling

industry, and thus cause the loss of intercity, charter, and tour bus

service for many citizens. To ensure that regulations issued by

the U.S. Department of Transportation (DOT) would be based on

accurate, objective information, and fully reflect the needs of

both the bus industry and the disability community, Congress

directed the Office of Technology Assessment (OTA) to study

this issue, with emphasis on the demand for accessible OTRB

service, current and potential technologies, costs of implementation, and impacts on the industry.

There are no simple answers to the issue of access to OTRBs.

OTA identified a number of positive factors, however, that could

lead to workable solutions. A variety of technologies are now

available and more are under development. Even more important

are the desire by the industry to provide accessible service, the
2 0ver-the-Road Bus Access

willingness by disability communities to be part

of a good-faith process that may take years to

reach full accessibility, and the growing understanding by all participants that implementation

of the ADA will mean devising specific strategies

over time to meet specific needs,

HOW MIGHT ACCESSIBLE SERVICE BE

IMPLEMENTED?

Within 1 year of the release of this study, DOT

must issue regulations to inform OTRB operators

of their compliance obligations under the ADA.

These regulations take effect for large operators

in July 1996 and for small operators in July 1997,

although the President may delay implementation

for up to 1 year. The conclusions of this OTA

study, provided to Congress and DOT, can inform

and support DOT in this regulatory process.

What Is an Accessible OTRB?

OTA defines an accessible OTRB as one that

allows persons with disabilities to board and, where

applicable, remain with their wheelchair or other

mobility aid while riding, with only minimal assistance from bus company personnel. Accessible OTRBs

have:

●

●

●

●

●

●

●

Access to level-change devices, including lifts

or ramps. An OTRB without an onboard

level-change device is accessible only if it

operates primarily at stops equipped with

level-change devices.

A sufficiently wide door to accommodate

persons with mobility impairments.

Two wheelchair tie-downs to secure wheelchairs and their users.

Movable arm rests on some aisle seats.

A means to communicate with persons who

have sensory and cognitive impairments, both

on and off the bus.

An accessible restroom or operational provisions for use of accessible restroom facilities.

Personnel trained in both equipment use and

people skills (already a requirement under

DOT regulations).

The ADA specifies that accessibility is phased

in as OTRBs are purchased or leased by private

transportation providers; no retrofitting of vehicles is required. Since the lifetime of an OTRB

can exceed 20 years, operators may take that long

or longer to turn over their fleets and complete the

phase in of accessible OTRBs. Several variables

will

●

•

●

●

●

affect the process:

OTRB service providers may choose between vehicle-based and station-based levelchange devices as best suits their service

patterns. However, more complicated regulatory strategies will be required for the

station-based lift approach, because a bus

without a level-change device onboard is

only accessible when it is at a station with a

level-change device.

Available technologies can provide reliable

access. Over time, design and production

will lead to technological improvements and

reduced costs. New designs are under development.

The area in which technology is least able to

offer help at present is that of accessible

onboard restrooms. However, access to

restrooms is an important aspect of accessible service, and OTRB operators who

choose not to equip vehicles with accessible

restrooms must respond to this need in some

way, presumably with suitably frequent

stops at accessible facilities.

The ADA imposes different standards on

“freed-route” and ‘‘demand-responsive’

transportation services. OTRBs in fixedroute service follow set schedules; demandresponsive charter and tour services do not.

All OTRBs purchased or leased for fixedroute service must be accessible, but demandresponsive OTRB systems can meet ADA

standards by providing enough accessible

OTRBs to accommodate the demand.

Reservation systems can hasten the implementation of accessible service before OTRB

systems are fully accessible, by allowing
Executive Summary 3

●

passengers to notify companies of special

needs and by providing advance notice to

make accessible equipment available. However, the ADA forbids the use of reservation

systems primarily for persons with disabilities; reservation systems must serve all

riders.

Companies without a reservation system can

begin compliance by publishing schedules

with designations of routes and times that are

served by accessible vehicles, and, for the

routes and times that are not accessible, the

company can specify that persons call, for

example, 24 hours in advance if, and only if,

they need boarding assistance.

WHAT MIGHT THE IMPACTS BE?

The impacts of the ADA cannot be predicted

with any certainty. OTA estimates the most likely

impacts as follows:

OTRB operators providing fixed-route service will face capital and operating costs in

implementing the ADA. Since many OTRB

operators are experiencing financial difficulties,

already they are concerned about these costs.

Some fixed-route providers have said that they

may reduce service, and it is conceivable that

some companies already in financial trouble

could choose to end service. Charter and tour

operators of OTRBs have somewhat simpler

requirements than fixed-route providers under the

ADA, and, as their general financial situation is

often stronger than that of fixed-route OTRB

operators, the cost impact should be less.

Rural communities could experience reduction in service, but it is not possible to predict

whether this will actually happen. Given the

proprietary nature of company data and the

decline of rural service over the decades before

the passage of the ADA, it may be impossible to

isolate the effect of ADA compliance on rural

service-even after the fact—but OTA expects

the effect to be marginal.

Persons with disabilities and other passengers face a phase in of full accessibility that could

last as long as 20 years, Thus, for a number of

years, carrying of riders with mobility impairments will still be used as a method of boarding

assistance, creating problems for both the riders

and OTRB personnel. Accessibility costs that are

passed on through increased fares could marginally reduce ridership by those now using OTRBs.

However, the demand for OTRB service by

persons with disabilities will most likely increase

as systems become truly accessible and the

population ages.

How Much Will It Cost?

. OTA calculates that the additional cost for one new

OTRB to be outfitted with accessibility technologies and operated over its entire lifetime (of roughly

20 years) ranges from $18,000 to $40,000, or

approximately 1 percent of the total lifetime capital

and operating costs. These estimates follow critical

financial assumptions made by OTA and, as with all

estimates of future cost, there is a high degree of

uncertainty.

. Most operators will not purchase accessible vehicles until sometime after the ADA regulations go

into effect in 1996-97, so they will not begin to incur

these costs for some time. As operators turn over

their fleet, the cost of implementing accessible

service will rise and approach approximately 1

percent of the total operating costs only when the

fleet becomes fully accessible.

● Choice in purchasing station-based or onboard

level-change devices is an important factor in

minimizing costs. For example, operators in urbanized areas with many express buses are likely to

benefit from station-based technologies, whereas

operators in rural areas with many stops will most

likely prefer OTRBs with onboard level-change

devices.
4 0ver-the-Road Bus Access

WHAT CAN CONGRESS DO?

The language of the ADA does not open the

door for additional financial assistance for implementation of the law, and implementation will

proceed regardless of government financial assistance. OTA notes, however, that in the case of

OTRB transportation operators, Congress may

wish to consider four arguments for government

assistance:

. First, the fixed-route bus industry has been

operating under tough financial conditions

for some time due to competition from other

modes of transportation. Consequently, fixedroute service now covers a much smaller

passenger base (shrinking from 130 million

passengers in 1971 to 37 million in 1990)

and decreasing numbers of points served

(from 17,000 in 1968 to 5,700 in 1991).

Thus, Congress may wish to subsidize this

industry, not due to accessibility requirements imposed by the ADA, but from the

larger perspective that OTRB transportation

is an essential service for some segments of

the U.S. population, especially those with

low incomes and those living in rural areas.

. Second, carefully crafted financial incentives could encourage transportation providers to purchase accessible OTRBs earlier

rather than later, thus hastening accessibility.

. Third, OTA estimates the implementation

costs of the ADA for freed-route operators to

be less than $10 million dollars annually.

. Finally, engineering and product development funding could make more costeffective accessibility devices available at a

much earlier date.

Presently, the Federal Government assists

OTRB operators with limited funding under the

Federal Transit Act FTA) and with several small

tax breaks. Options for the support of accessibility technologies include augmenting FTA funding, authorizing a new financial assistance program specifically targeted to accessibility equipment, and supporting the development of new

accessibility technologies.
Summary

and

Conclusions 1

T

he 1990 Americans with Disabilities Act (ADA) seeks to

. . . provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities. ” 1 Describing persons with

disabilities as having been isolated and segregated in many ways,

the law sets a national goal of assuring persons with disabilities

. . . equality of opportunity, full participation, independent

living, and economic self-sufficiency, ’ The ADA specifically

addresses discrimination in public accommodations and services, such as transportation, operated by private entities,

including those that provide over-the-road bus (OTRB) service:

No individual shall be discriminated against on the basis of disability

in the full and equal enjoyment of specified public transportation

services provided by a private entity that is primarily engaged in the

business of transporting people and whose operations affect

commerce.

3

However, while the ADA defines accessible service for other

private providers of public transportation (railroads, for example)

and instructs the U.S. Department of Transportation (DOT) to

develop immediately regulations for these providers, it leaves

open the definition of an accessible OTRB and accessible OTRB

service.4 (For further discussion of the Americans with Disabilities Act, see box l-A.)

1

42 USC 12101 (b).

2

42 USC 12101(a)(3) & (8).

3 Sec. 304 of the Americans with Disabilities Act; 42 USC 12184 (a).

4 Public Law 101-336, Sec. 305(a). The ADA defines an OTRB as a ‘‘. . . bus

characterized by an elevated passenger deck located over a baggage compartment. ’ Sec.

301(5).

5
.

6 0ver-the-Road Bus Access

Box l-A—Accessibility for OTRBS: The Americans With Disabilities Act

The Americans with Disabilities Act (ADA) of 1990 seeks to ensure that persons with disabilities have full

access to employment, public transportation, communications, facilities, and so forth. The ADA specifically

addresses public accommodations and services operated by private entities, including those offering over-the-road

bus (OTRB) service. The act states that failure to make reasonable modifications necessary to provide public

transportation services to persons with disabilities is discrumination, unless making such modifications would

fundamentally alter the nature of the specified public transportation services. Discrimination includes failure to

provide the auxiliary aids and services necessary to ensure that no person with disabilities is denied transportation

services, excluded, segregated, screened out, or otherwise treated differently. The ADA specifically prohibits

discrimination in OTRB service.

Section 304(b)(3) of the ADA defines discrimination by a private entity providing specified public

transportation, excluding OTRBs, as:

. . . the purchase or lease by such entity of a new vehicle (other than an automobile, a van with a seating

capacity of less than 8 passengers, including the driver, or an over-the-road bus) which is to be used

to provide specified public transportation. . . that is not readily accessible to and usable by individuals

with disabilities . . .; except that the new vehicle need not be readily accessible to and usable by such

individuals if the new vehicle is to be used solely in a demand-responsive system and if the entity can

demonstrate that such a system, when viewed in its entirety, provides a level of service to such

individuals equivalent to the level of service provided to the general public. . .

However, Section 304(b)(4)(A) states that discrimination includes:

. . . the purchase or lease by such an entity of an over-the-road bus which does not comply with the

regulations issued under section 306(a)(2).

Section 304(b)(4)(A) clarifies that the exclusion of OTRBs from 304(b)(3) is with respect to the compliance

date and specific standards, not from the requirement for accessibility.

Under the ADA, the U.S. Department of Transportation (DOT), in conjunction with the Architectural and

Transportation Barriers Compliance Board (ATBCB), must issue interim regulations and, after review of this

OTA study, issue final rules in 1994 (which take effect in 1996 for large carriers and 1997 for small ones) to

provide accessible OTRB service to individuals with disabilities. DOT does not have the power to allow any

OTRB company to operate an inaccessible system. In Americans Disabled for Accessible Public Transportation

(ADAPT) v. Skinner,l which predates the ADA, the district court held that DOT could take costs into account but

could not, because of cost considerations, abrogate the rights granted by the statutes. In addition, while the ADA

applies the concept of ‘undue burden” to existing buildings and infrastructure, new structures and transportation

services must meet accessibility standards regardless of cost considerations.

OTA could find no language in the ADA stating or implying that OTRBs can be held to a lesser standard

than other modes of transportation, nor does the ADA give guidance on promulgating such a lesser standard. The

requirement of Section 305 of the ADA that OTA conduct a study is not an exemption or retreat from the policies

and goals of the ADA. Section 305 is a practical attempt to resolve a hotly contested issue that arose during

hearings on the ADA, The committee report said:

During its hearings on the legislation, the Committee heard conflicting testimony on the cost and

reliability of wheelchair lifts or other boarding assistance devices with regard to their use on

over-the-road buses. Therefore, before mandating these or any other boarding options in this Act, a

1

881 F.2d 1184 (3rd Cir. 1989).
Summary and Conclusions 7

thorough study of the access needs of individuals with disabilities to these buses and the

cost-effectiveness of different methods of providing such access is required by the Act.2

Section 306 further states that DOT’s regulations must apply specified previous sections of the ADA to

OTRBs and must require OTRB operators to provide accessible service. Finally, Section 308 affirms that in civil

actions, the court shall consider whether the transportation provider could have reasonably anticipated the need

for an accessibility aid, and whether a good faith effort was made to provide such an aid.

The ADA clearly states that full access for persons with disabilities, which is, in all respects, comparable

to that for persons without disabilities, should eventually be the norm for private providers of other public

transportation. Thus, OTA anticipates that the standards of accessibility applied to other privately owned public

transportation providers apply to OTRB service, in keeping with the language and intent of the ADA.

Comparison of Accessibility Standards for Air Carriers With Those for OTRBs

The ADA puts forward accessibility requirements for all modes of public transportation, except for aircraft,

which are governed by the Air Carrier Access Act (ACM) of 1988. At first glance, the OTRB industry and the

commuter air industry may seem to have a number of characteristics in common, as both transport paying

passengers from one community to another. However, the mere physics of flight and the complex safety

requirements that result are sufficient to require for air carriers a separate set of regulations such as those

promulgated under the ACAA. For example, Federal air safety rules dictate that aircraft seats be capable of

withstanding a forward force of at least 16 gs in a simulated dynamic crash,3 while there are no comparable

requirements for bus seats. This and various other aircraft requirements appear to preclude even the most earnest

effort to allow persons to remain in their wheeled mobility aids onboard, while technology allowing wheelchairs

and scooters on buses already exists.

In addition, air carriers provide onboard flight attendants to assist passengers on craft with 10 or more seats.

On most OTRBs, drivers are the only company employees onboard, and the driver’s primary responsibility is to

drive the coach. Without attendants, many of the accessibility technologies used by airlines, including aisle chairs

and other equipment, cannot be used, Thus, OTA concludes that the example of accessible airline service is not

a suitable model for accessible OTRB service.4

z US. congas, HOUW COMRW on Education and Labor, Legislative History of Public Luw 101-336, The Arnerkans

Wirh Disabilities Act, Serial No. 102-A, Committee FrinL December 1990, p. 249.

3 ~@ s~e~ Foundation, Intermtioml Aircr@ Occupant Safety Conference and workshop proceedings (~lkton,

VA: Oct. 31-Nov. 3, 1988).

4 one o~er UUCkit &fference between the ACAA and the ADA exists for smaller aircrafl which have 30 or fewer seaw

and are commonly used for regional transportation and commuter runs. Regulations for these aircraft stipulate that once DOT

has determined that level-change devices are commonly available and on the marke~ they must be implemented in carrier

service that is not otherwise accessible-requiring retrofitting of the vehicles if necessary. The ADA requires no carrier to

retrofit vehicles, except in the case of trains, where the lifetime of a railcar is quite long.

During the ADA debate, Congress was uncer- OTRB service is essential for all persons with

tain about the feasibility of accessibility technolo- disabilities, and the act reflects this decision.

gies for OTRBs and concerned about inflicting Because of these concerns, the Office of Technolsignificant costs for ADA compliance on OTRB ogy Assessment (OTA) was directed to examine

freed-rate transportation providers, an industry this complex question, so that final regulations

that has been in decline for several decades. could be as constructive and farsighted as posNevertheless, Congress recognized that access to sible.
.—.

8 0ver-the-Road Bus Access

Section 305 of the ADA instructs OTA to:

. . . undertake a study to determine —

(1)

(2)

the access needs of individuals with disabilities to

over-the-road buses and over-the-road bus service;

and

the most cost-effective methods for providing access

to over-the-road buses and over-the-road bus service

to individuals with disabilities, particularly individuals who use wheelchair, through all forms of

boarding options.5

In addition, OTA was directed to:

. . . include, at a minimum, an analysis of the following:

(1)

(2)

(3)

(4)

(5)

(6)

The anticipated demand by individuals with disabilities for accessible over-the-road buses and over-theroad bus service.

The degree to which such buses and service . . . are

readily accessible to and usable by individuals with

disabilities.

The effectiveness of various methods of providing

accessibility to such buses and service to individuals

with disabilities,

The cost of providing accessible over-the-road buses

and bus service to individuals with disabilities,

including consideration of recent technological and

cost saving developments in equipment and devices.

Possible design changes in over-the-road buses that

could enhance accessibility, including the installation

of accessible restrooms that do not result in the loss

of seating capacity.

The impact of accessibility requirements on the

continuation of over-the-road bus service, with particular consideration of the impact of such requirements

on such service to rural communities.6

Within 1 year of the release of this study, the

ADA requires DOT, in conjunction with the

Architectural and Transportation Barriers Compliance Board, to issue regulations informing

public transportation operators using OTRBs of

their compliance obligations under the ADA:

. . . taking into account the purposes of the IOTA]

study , . . and any recommendations resulting from

such study, each private entity which uses art

over-the-road bus to provide transportation to

individuals to provide accessibility to such bus to

individuals with disabilities, including individuals who use wheelchairs.7

These regulations take effect for large operators

in July 1996, and for small operators in July

1997. 8 The President can delay the implementation of these regulations by 1 year if he determines

that they create an undue burden for OTRB

transportation providers.

This chapter summarizes the results of the

OTA assessment and highlights findings that can

inform and support the DOT process. A number

of references are made to later chapters, which

explore aspects of the analysis in more detail.

OVER-THE-ROAD BUS SERVICE

IN THE UNITED STATES

Approximately 23,000 to 27,000 OTRBs currently operate in the United States. About 450

companies offering freed-route, regularly sched5 OTA considers the term “wheelchairs’ in this context to include all wheelchairs, scooters, and similar devices, For the purposes of this

report OTA uses the term ‘‘wheeled mobility aids’ to encompass all wheelchairs, scooters, and similar devices.

6 Public Law 101-336, Sec. 305(b).

7 Sec. 306(a) (2)(B)(ii) of the ADA. The Architectural and Transportation Barriers Compliance Board (ATBCB), established by Section 502

of the Rehabilitation Act of 1973, establishes minimum guidelines for accessibility standards pursuant to the Architectural Barriers Act of 1968

and Americans with Disabilities Act of 1990, ATBCB guidelines address only technical issues and specifications, and DOT must develop rules

for any remaining operational issues.

8 In the interim, before the final regulations wilt take effect, DOT has issued the following rule: “Private entities operating over-the-road

buses. . . shall provide accessible service. . . shall provide assistance, as needed, to individuals with disabilities in boarding and disembarking

. . . [and] shall ensure that personnel are trained to provide this assistance safely and appropriately. The entity may require up to 48 hours’

advance notice only for providing boarding assistance . . .’ 56 Federal Register 45641 (Sept. 6, 1991). The determination of which companies

are large or small is to be made by the Secretary of Transportation. Sec. 306(a)(2) (B)(iii).
Summary and Conclusions 9

uled service use 10,000 to 11,000 OTRBs on

intercity routes or on local routes for airport,

sightseeing, and other services.9 Greyhound Lines,

Inc., is by far the largest of these providers with

roughly 2,300 OTRBs in 1992.10 Another 3,000

companies use over 12,000 OTRBs for demandresponsive charter and tour operations. 11 In addition, a small number of OTRBs are owned by

nonprofit organizations such as churches or

community centers. 12 In 1992, a new, nonaccessible OTRB (with few optional features) typically

cost $225,000 to $250,000. Optional features

include restrooms, video equipment, audio systems, fold-out steps to reduce the first step height

of the boarding stairs, and movable arm rests.

 Fixed-Route Service

Many OTRB transportation providers, especially fixed-route operators, face formidable financial circumstances. Since the 1950s, the numbers of passengers and stops served by fixed-route

bus service have declined steadily (see figure

l-l). The number of passengers riding on Class I

intercity carriers fell from nearly 130 million in

1971 to 37 million in 1990.13 The primary cause

for this decline was direct competition with other

transportation modes, especially the automobile,

but also trains and airlines.

Typical intercity bus passengers differ in several ways from passengers on other intercity

OTRB scheduled, intercity service linked

roughly 6,000 communities in 1992, down from

17,000 in 1968.

public transportation systems. They are more

likely to be under the age of 18 or over the age of

65, to have family incomes of less than $10,000

(1977 dollars, $22,500 in 1991 dollars), and to

live in either large metropolitan areas or rural

areas than riders of other forms of public transportation.

14 

Slightly fewer than one-half of the

passengers on intercity coaches do not own an

automobile capable of a 500-mile trip.15 According to one survey, 33 percent of all bus passengers

take 1 to 3 trips per year, 36 percent take 4 to 10

trips per year, and approximately 20 percent take

9 Current estimates are that less than 5,000 OTRBS are used in fixed-route zntercify service. Frederic Fravel, Eeosometrics Inc., personal

communication, Sept. 29, 1992.

10 G~ble Rudd, Customer Relations, Greyhound Lines, Inc,, persoml comrnunicatiou Feb. 11, 1993.

1 I ~c ADA defines a tixcd-route systcm m “. . . a system of transportation of individuals (other than by aircraft) on which a vehicle is

operated along a prescribed route according to a fixed schedule. ’ Sec. 301(4). Regular-route intercity OTRB service is considered fixed-route

service, and OTA uscs the term fixed-route throughout this report. A demand-responsive system is defined as any public transportation systcm

that is not a fixed-route system. Sec. 301(3). OTA concludes that charter and tour services are demand-responsive.

‘~ Ecosomctrics, Inc., ‘‘Potential Dcmand for Accessible Over-the-Road Buses,” OTA contractor report, August 1992.

13 Inters~[c comerce comls~lon (r(_’_’) mea~mement of tic activi~ of Class I c~ers hs varied considerably over the years. The ICC

definition of Class I carriers since 1938 has been based on adjusted annual gross operating revenue in excess of a certain threshold. This

threshold, initially established at $100,000, was raised to $200,000 in 1950, to $1 million in 1969, to $3 million in 1977, and to the cumnt

level of $5 mdlion in 1988.

14 While ficse &@ &te back t. 1977, hey we he most ~omprehe~ive data collect~ to date. More rcccnt surveys, conducted by Greyhound

in 1989 and 1991, show similar results.

15 Greyho~d Lines, In C., “Greyhound On Board Passenger Profile Survey, ” unpublished document, 1989.
10 0ver-the-Road Bus Access

Figure 1-1—lntercity Bus

160 ] Amtrak

subsidies begin Energy

140 ‘

1=

L’ ‘

120

, crisis begins

bRidership: Class 1 Carriers, Regular Route Service, 1971-91

7< Greyhound

L

disinvestment

strategy

,+–—+ ,

Airline Energy crlsls 2

deregulation begins

begins Bus Regulatory

Reform Act

; 80 ~ GLIH purchase of

ol Greyhound and

c

; 60

2

4 0

20/

0 t 1 1 1 1 1 1 1 1 ! I 1 1 1 1 I I 1

1971 1973 1975 1977 1979 1981 1983 1985 1987 1989 1991

SOURCE: Interstate Commerce Commission, Office of Economics, “Transport Statistics in the United States: Second and Final Release, Passenger

Carriers,” unpublished reports, issued annually for the years 1970-91.

11 to 30 trips per year. Less than 10 percent take

more than 30 trips per year.l6

Until 1982, OTRB fixed-route service was

regulated at both the Federal and State levels. The

Bus Regulatory Reform Act (BRRA) of 1982

repealed many Federal Government restrictions

on intercity bus service and preempted State

regulation of service abandonment and fares. This

allowed freed-route bus companies greater freedom to restructure their services and routes to

maximize profits, Consequently, although intercity bus carriers had already dropped many rural

points of service before the BRRA, the trend

continued in the years after its enactment. In

1968, regularly scheduled intercity bus service

covered approximately 17,000 points, but by

1991 the General Accounting Office estimated

fewer than 6,000 points of service remained.17

The impact of service abandonment on rural

communities is difficult to determine. Residents

of many communities were able to substitute

other transportation modes (primarily automobiles) and package express services (e.g., Federal

Express or United Parcel Service) for intercity

service and, consequently, do not report significant detrimental effects due to the loss of service.

However, some individuals without access to

other forms of transportation undoubtedly suffer

from diminished bus service.18

Although operators of OTRBs have restructured their service for greater profitability, companies offering fixed-route service still face

16 Greyhomd Lines, hlC., “Greyhound On Board Passenger Profile Survey, ” unpublished documen~ 1991.

17 U.S. Gener~ Accounting OffIce, Availability cflrrfercity Bus Service Continues to Decline (Washington ~:Jme 1992), P. 2. we not

all of the points dropped were rural, OTRB operators indicate that most were. Remarks at Office of lkchnology Assessment Workshop,

“Building an Accessible Intercity BUS System, ” July 15, 1992.

ls Ecosome~cs, hlC., ‘‘Background Paper on Accessibility for the Disabled and the Intercity Bus Industry, ’ OTA contractor report, Mar.

31, 1991.
Summary and Conclusions 11

of the ADA will jeopardize their ability to

continue service (see box l-B).

 Demand-Responsive Service

By reducing restrictions on charter and tour

operators, considered demand-responsive operaFigure 1-2—lntercity Bus Industry:

Class I Carriers, Operating Ratios, 1971-91

1990 and 1991

data reflects

Greyhound strike 1

and bankruptcy v

110% “ Al

A Iv tors under the ADA, passage of the BRRA in 1982 1 f100%/n I

cleared the way for more companies to enter the

market. The number of firms operating exclusively charter and tour services grew from fewer

than 1,000 in 1982 to over 3,000 in 1990. Many

fixed-route carriers also offer charter and tour

services.

800/0

70%

6 0 %

Key

Operating ratio=

operating costs

operating revenues Charters and tours are generally arranged far in

advance of the date of travel. Charter transporta- 50’% 1 1 1 ,

1971 1975 1979 1983 1987 1991 tion provides group travel where the schedule,

SOURCE: Interstate Commerce Commission, Office of Economics,

‘Transport Statistics in the United States: Second Release, Passenger

Carriers,” issued annually for the years 1971-91.

financial hardships. Figure 1-2 presents the operating ratios (i.e., the operating costs divided by

operating revenues) for the Class I carriers. In

1971, their collective operating ratio was 88

percent, but it rose to a high of nearly 109 percent

in 1990 and then down to a ratio of 98.7 percent

in 1991. In practical terms, this means that a

company with an operating ratio of 98.7 percent

and revenues of $5 million would have $65,000,

after deducting operating expenses.19

These aggregate figures obscure the fact that

many individual fixed-route companies operate

with deficits for extended periods. Indeed, some

of these companies find it difficult to finance the

purchase of even one new coach. OTA has

confined its analysis to the impacts of the ADA on

the future of OTRB companies, as an analysis of

the overall future of the bus industry is beyond the

scope of this report. It is clear that many OTRB

operators are concerned that the implementation

origin, and destination are set by the members of

the group. A charter tour includes additional

services, such as meals, lodging, or attractions,

again at the group’s request. A retail tour includes

the same services as a charter tour but is sold

directly to the public on an individual basis by the

tour operator.

OTRBs in charter and tour service visit a variety of

destinations, from tourist sites to baseball games.

19 -l-he~c ~pemfig ratio dab afc from rcpofls rna~c [O the Interstate Commerce Commission by the ctiers tith operating rc~’enues Wcater

than $5 million (SCC ch. 2).
. 

12 0ver-the-Road Bus Access

Box l-B—An OTRB Operator Views the Future of Intercity Bus Service

In 1981, Ray Brownl purchased several midwestern routes from the National Trailways Bus System; the new

company was called Pomona Trailways. Ray had grown up in the bus industry, working in various positions in

his father’s bus business before becoming president of his own.

In the past few years, Pomona Trailways has been a break-even operation, struggling to compete against

airfare wars, the subsidization of Amtrak, the Greyhound reorganization and strike, and the recession. Pomona

Trailways owns 11 buses, dating in age from 16 years to one brand new coach. The service runs 1,900 miles per

day in regular freed-route service and also offers charter and package express services. None of the buses are

accessible, although the newer coaches have an extra step for easier boarding.

Pomona serves approximately 45,000 passengers a year. Ray says in the 11 years he has been fully

operational he has only had six requests for special access from individuals who use wheeled mobility aids. In

two of those cases the individual had to be carried on and off the bus; the others were able to walk on and off and

had their mobility aids stowed below. In addition, Pomona personnel routinely assist individuals with hearing and

visual impairments in boarding and disembarking. Like other over-the-road bus operators, Pomona offers a

“Helping Hand” program that allows attendants to ride at no extra charge. In one case, Ray paid his son to

accompany a person with a disability for 16 hours, serving as an attendant.

Some operators believe that bus service is the last resort for travelers, whether they have disabilities or not.

‘‘People travel by bus when there is no other way,’ Ray says. “Either they don’t like to fly and there is no train,

they don’t have a car or a license, or they can’t afford any other alternative. The bus is the cheapest way to go

and still people will make it their last choice. ” For this reason, some operators do not believe that outfitting every

bus for accessibility makes sense, because in most cases, persons with disabilities will choose the bus as a last

resort. These operators doubt that making all buses accessible would ever generate enough demand to justify the

cost.2 Ray claims there is demand for accessible service within the communities in his area, but mostly in the form

of vans or small buses to assist individuals in getting to work, stores, or medical appointments.

Although some operators oppose subsidies to the industry, some believe that if small operators like Pomona

Trailways are forced to comply with all provisions of the Americans with Disabilities Act, the Federal

Government should assist in the purchase of one or more accessible buses per operator. 3 If ridership increases as

a result, and the route or service becomes profitable because of the accessibility, the subsidy could be repaid. Ray

sympathizes with the need for accessible service but believes that full accessibility requirements, layered on top

of already tough economic conditions, would force businesses like his under, ultimately resulting in a loss of

service for everyone.

1 “Ray Brown” and “Pomona Trailways” are fictitious names; the person and the company am real.

2 Re~~ at WI= of ‘I&hnology Assessment Workshop, “Building an Accessible Intercity BUS system” J~Y M

1992.

s Ibid.

Little nonproprietary information about charter socialize, attend sporting and cultural events, or

and tour passengers is available. A 1986 market go sightseeing. They have a household income of

research effort by one firm shows that bus retail over $34,000 (1985 dollars, over $43,000 in 1991

tour patrons have a mean age of 60 and take an dollars) and an average auto ownership of 1.8

average of five l-day trips, 4.1 overnight trips, autos per household.20 This limited statistical

and 2.3 extended trips annually, primarily to information indicate that the median income of

m Lawrence F. Cunningharn, “Profii Tour Patrons and Non-Patrons in Intereity Bus Passenger Markets,” paper presented at thehnual

Meeting of the Transportation Research Board, Washington DC, January 1986.
Summary and Conclusions 13

tour patrons is much higher than that of fixedroute passengers. Both tour and fixed-route passengers are more likely to be over 65 years of age

than travelers on other transportation modes.

No comprehensive data exists on the financial

condition of the charter and tour industry. Anecdotal data from charter and tour companies

indicate that the service is, in general, more

profitable than freed-route service, but this conclusion cannot be quantified,

 Current Accessible Service

The Urban Mass Transportation Assistance

Act of 1970 states that persons who are elderly or

who have disabilities have the same rights as

others to use mass transportation services. Despite this legislation, many publicly funded transit authorities did not purchase buses that were

accessible for persons with mobility impairments.21 In 1973, Section 504 of the Rehabilitation Act declared that:

[N]o otherwise qualified individual with handicaps in the United States . . . shall, solely by

reason of his or her handicap, be excluded from

the participation in, be denied the benefits of, or

be subjected to discrimination under any program

or activity receiving Federal financial assistance.22

Under this act and Section 16 of the Urban

Mass Transportation Act, the Urban Mass Transportation Administration adopted regulations in

1976 requiring federally funded transit agencies

to make special accommodations for persons with

disabilities. Many public transit authorities subsequently purchased new buses with lifts and

other assistive technologies. As of early 1993,

roughly 350 OTRBs equipped with vehicle-based

lifts were operated by or under contract to

publicly funded transportation systems. Government funds helped to purchase the accessibility

technologies in most of these cases, Until the

passage of the ADA, however, public transportation services using privately owned and operated

OTRBs were not required to be accessible. (For

an account of an incident that would be prohibited

now under the ADA, in which OTRB service was

denied to a person with a disability, see box 1-C.)

Few operators run charters and tours for

individuals with disabilities. As of January 1993,

Evergreen Travel Service, Inc. (Lynnwood, Washington) and Sunrise Plaza, Inc. (Los Angeles, California) were the only charter and tour operators to

have purchased OTRBs with accessibility equipment for persons with mobility impairments

without government funding. Evergreen, using an

OTRB capable of securing 12 wheeled mobility

aids and with room for attendants, runs tours all

over the United States, Sunrise Plaza recently

bought an OTRB with a lift, two tie-downs, and

an accessible restroom. This OTRB was financed

in part by a Japanese tour operator who was

previously unable to include persons with disabilities in Japanese groups touring the United States.

In addition, several OTRB operators provide

charter and tour service with accessible vans.

Some tour operators also specialize in arranging accessible tours. For example, for the past 20

years or more, Flying Wheels Travel Service in

Minnesota has acted as a travel agent and tour

operator for accessible tours, mostly overseas

because of the difficulty in locating accessible

buses in the United States. Maryanke Tours, a

tour operator in Central Michigan, began offering

tours for persons with hearing impairments in

1991. These companies have identified a new

market niche, responding to existing demand.

THE DEMAND FOR ACCESSIBLE SERVICE

OTA was explicitly asked to study “. . . the

anticipated demand by individuals with disabilities for accessible over-the-road buses and accessible over-the-road bus service. ’ The law directs

21 Paul S. Dempsey, “The Civil Rights of the Handicapped in Transportation: The Americans With Disabilities Act and Related

I+gislation,” Transportation Law Journal, vol. 19, No. 2, 1991, pp. 309-333.

22 public hiw 93-112, 29 USC 794(a) (1973).
14 0ver-the-Road Bus Access

Box l-C-Raymond Smith and Janet Smith v. Greyhound Lines, Inc., 1982

Raymond and Janet Smith both have cerebral palsy. Raymond Smith uses a wheelchair; his wife Janet,

although physically limited, does not. In November 1982, Raymond Smith purchased a ticket from Greyhound

Lines, Inc. for bus transportation from Pittsburgh to Philadelphia, a trip of over 300 miles. Greyhound policy

allows riders with disabilities to be accompanied by an attendant at no extra cost. The Smiths had previously

traveled together on Greyhound under this arrangement between Pittsburgh and State College, Pennsylvania (a

trip of about 140 miles). Janet Smith is able to help her husband with personal needs, such as purchasing food

at rest stops, but she cannot lift him onto or off the bus without the assistance of others.

In advance of the November 1982 trip to Philadelphia, the Smiths had made arrangements for two additional

people to be present to assist in boarding in Pittsburgh, and for friends to meet them on arrival to assist Raymond

in leaving the bus. On arriving at the bus terminal in Pittsburgh for boarding, however, the bus driver refused to

transport the Smiths and they were unable to depart for Philadelphia. In a later statement, a Greyhound official

defended the driver’s decision, citing the risks of road failure or accident en route that would require alighting

and reboarding another bus. Greyhound reiterated its policy that, because of these possibilities, they require an

attendant, at no extra charge, who can help the individual with disabilities should either of these situations arise.

According to Greyhound, Janet Smith did not qualify as an able attendant.

The Smiths-denied transportation under these conditions on Greyhound buses since the November 1982

incident-filed a complaint in 1986 with the Interstate Commerce Commission (ICC), alleging that Greyhound

had not complied with ICC’s regulations concerning the transportation of persons with disabilities. l Specifically,

the Smiths asked ICC to review Greyhound’s actions in light of the regulations, as well as its policies and practices

with regard to travelers with disabilities. Furthermore, the complaint asked ICC to order Greyhound to revise its

policies with input from groups familiar with the needs of those with disabilities and to compensate the Smiths

for their inconvenience, humiliation, expenses, and legal fees.

ICC ruled that Greyhound’s actions in the Smith case did not violate the regulations because: 1) Greyhound

did not deny transportation to Smith solely because of his disability (he had access with free passage provided

to an attendant); 2) Greyhound policy expressly provides for advanced boarding and seating to accommodate

persons with disabilities; and 3) it was not unreasonable for Greyhound to assume that the attendant should be

capable of providing all necessary assistance to a person with disabilities en route. The decision stated that ICC

rules require that carriers provide assistance “when ever possible.” In addition, ICC noted that brochures provided

by Greyhound clearly state that the bus driver’s only job is to drive the bus and that it is reasonable for the company

to want to avoid the situation where a driver alone would be forced to help a passenger with disabilities board

and disembark en route, particularly in an emergency situation. Finally, the decision stated: “. . despite

complainant’s assurances, Greyhound had no guarantee that Mr. Smith’s friends would be in Philadelphia to help

him disembark. ” The complaint was dismissed by ICC with one dissenting view that the Smiths had presented

sufficient evidence to support a course of action.

1

49 CFR 1063.8.

OTA to estimate how many persons with disabili- According to the 1990 National Health Interties will ride accessible OTRBs; however, OTRB view Survey, of the total 1990 U.S. population of

transportation systems must be made accessible 249 million (figure 1-3):23

under the law, regardless of OTA’s findings about . 1.4 million people use wheelchairs;

demand.

● 1.7 million people use walkers;

23 ~cse ROUPS IIMy overlap, because persons with disabilities may use several types of tids.
Summary and Conclusions I 15

Figure 1 -3—Populations With Disabilities

in the United States

4

3

2

1

0

I

I

J

SOURCE: U.S. Department of Health and Human Services, Centers

for Disease Control/National Center for Health Statistics, “Assistive

Technology Devices and Home Accessibility Features: Prevalence,

Payment, Need and Trends,” Advance Data No. 217, Sept. 16, 1992.

●

●

●

3.0 million people use one or more mobility

technology devices, including wheelchairs,

walkers, crutches, scooters, and other mobility equipment;24

4.0 million people use hearing technology

devices; and

0.3 million people use vision technology

devices.

This survey probably underestimates the number

of persons with mobility and sensory disabilities,

because it excludes persons who have disabilities

but use no devices; moreover, it relies on selfidentification and might exclude persons who use

devices only rarely or who have temporary

disabilities. However, few other databases with

similar statistics exist.25 A 1982 source estimated

that: 26

●

●

●

1.1 million people are legally blind;

5.0 million people have sight impairments

that make travel difficult; and

Up to 14 million people have experienced

significant hearing loss.

No reliable data exist for persons with cognitive

disabilities. 27 Depending on the breadth of the

definition used, estimates of the number of

persons with cognitive disabilities range from 1 to

20 percent of the population.

The U.S. population is aging. The U.S. census

projects that the population of Americans 65 and

over will grow from 12 percent in 1990 to almost

18 percent in 2020, and to nearly 23 percent in

2050 (figure 1-4). Because of a higher prevalence

of disabilities in this age group, an increase in the

population of individuals with disabilities is

likely in the coming years. (For a profile of a

senior citizen who uses public transportation

services, see box l-D.)

Almost all individuals with disabilities are

potential riders of OTRBs, but, of course, many

would choose other transportation modes for the

same reasons persons without disabilities choose

to fly, drive, or take the train. How many persons

with disabilities would ride on an OTRB after the

~ This number does not include persons using leg or foot braces and,lor canes and walking sticks.

‘s Remarks at Office of Technology Assessment Workshop, op. cit., footnote 17.

‘h Wilham H. Henderson et al., Passenger Assistance Techniques: A Training Manual for Vehicle Operators of Systems Transporting the

Elderly and Handicapped (Fort Worth, TX: Transportation Management Associates, 1982), pp. 3-9.

‘7 Persons with cognitive disabilities do not often have trouble boarding or disembarking from an OTRB, but they may find it difficult to

negotiate the terminal, purchase their ticket, and find the appropriate bus.
—

16 10ver-the-Road Bus Access

Figure 1-4-Projected Growth of Older Population

as Percentage of Total Population

250/.

,

20 %

Age 65 and

150!0

10“/0

5%

0%

. .

.. ”- ..-

..-

..-

---

,

,

,

,

, . . . . . . . . . . . . .

,

,

,

,

,

,

,

,.,

::’

,,, s::= -.....””

.-

. . . . . . . . . . . . . . . . .

.-

1 I I 1 I

1990 2000 2010 2020 2030 2040 2050

NOTE: Projections are based on a Lowest, a Highest, and a Middle

Series of assumptions about fertility, mortality, and immigration.

SOURCE: U.S. Department of Commerce, Bureau of the Census,

Projections of the Population of the United States by Age, Sex and

Race: 1988 to 2080, Current Population Reports, P-25, No. 1018

(Washington, DC: U.S. Government Printing Office, 1989).

systems are accessible? OTA has found no data to

provide a reliable quantitative answer to this

question.

The primary reason for the lack of demand data

is the lack of experience with accessible OTRB

service. Only one State-sponsored program in

Massachusetts, two demonstration projects in

Canada, and limited service operated by the

Denver and Golden Gate transit authorities have

offered accessible intercity buses on freed routes.

(For a profile of the accessible OTRB service

offered by the Denver transit authority, see box

l-E.) Each of these services had, or has, relatively

low ridership by persons with mobility disabilities. However, questions of lift reliability (especially with early generation lifts), insufficient

marketing, and limited route coverage might have

contributed to low ridership.

Box l-D-Transportation Needs of a

Senior Citizen

Alice Beringerl is an 84-year-old resident of a

retirement home in Alexandria, VA. Several years ago

she suffered a stroke and lost the use of her right arm

and leg. She has learned to use her right leg with the

use of a leg brace, but finds walking more than 50 feet

tiring. She is unable to climb stairs.

Alice uses an electric cart to maneuver around her

apartment and through the hallways of her building.

When she wants to go somewhere else, however,

Alice encounters difficulty because she must give up

her cart and use a wheelchair that requires the

assistance of another person. Alice wishes that she

could find away to transport her electrical cart so that

she could travel more freely without assistance. “If I

could take it along,” she says, “I could get off the bus

and go. Now I have to have someone with me to push

the chair and that is not always possible.”

The retirement facility operates an accessible

minibus. The minibus has a ramp that Alice says is so

steep that it takes great effort to push her wheelchair

onto it. Once inside the minibus, there are no

tie-downs for Alice’s chair, so she must move to

another seat and stow her wheelchair in the back of the

bus. She is not able to carry her electric cart with her

on these trips, which usually take her to a doctor’s

appointment or to a store. In addition, Alice must have

a companion travel with her, something that is not

always feasible. Because of the discomfort and

inconvenience of this process, Alice frequently relies

on her son to provide transportation in his car, with her

wheelchair stowed in the trunk. She says she travels

well by car and prefers it over the minibus, which she

uses only as a last resort.

Since losing full mobility, Alice has not attempted

long distance bus travel, but flies when traveling long

distance. She feels that the airlines “take very good

care of you.” However, several years ago, Alice had

an uncomfortable experience in a Wisconsin airport

where she had to be carried up stairs to board a plane.

She says the experience was “disconcerting.” Following the passage of the Americans with Disabilities

Act, Alice called a major bus service to inquire about

travel to Richmond, Virginia, about a 2-hour trip. The

operator told her that, as there were no accessible

buses, the driver would have to carry her, and she

would have to travel with an attendant. Alice did go to

Richmond, but by car.

1 Alice Beringer” is a fictitious name; the person is

real.
Summary and Conclusions 17

Box l-E—Accessible OTRB Service in One Transit Setting

Denver Regional Transit District (RTD) is a public transit system serving the Denver region, including a

number of routes to outlying cities on which OTRBS are used. * RTD was one of the first transit agencies in the

United States to provide service specifically for persons with disabilities, in response to 1986 Federal

requirements under the Surface Transportation Assistance Act. RTD offers discounted fares to individuals with

disabilities and free rides to attendants. Two types of wheelchair-accessible service are available: accessible

service on regular fixed-route systems, and HandiRide, a separate transit system for riders with more severe

impairments.

As of late 1992, the system operated 102 intercity coaches, of which 39 are wheelchair accessible. The large

number of intercity coaches and the length of the routes are unusual for a public urban transit system. Overall,

37 percent of the intercity service operates with lift-equipped coaches, with weekend routes generally 100 percent

accessible. On weekday services, the percentage of accessible trips ranges from O to 55 percent, depending on the

route.

OTRB lifts were first installed in 1987, when RTD asked Stewart& Stevenson Power, Inc. to design a lift

for retrofitting an MC-8 coach. The lift was subsequently redesigned not only for retrofitting MC-8s but also as

a factory installation on the Neoplan Metroliners and the latest purchase of MCI coaches. These MCI MC102A3

coaches ($235,400 in 1991) are all lift-equipped, seating 47 with one wheelchair tie-down available at all times,

and with a second tie-down available by folding and sliding two seats on the left side of the coach. The Stewart

& Stevenson Powerlift by itself cost $12,350 in 1990. The lift and tie-down locations permanently reduce seating

capacity by four seats. The baggage compartment is reduced by two cubic feet for the lift pump and controls, and

in some models the rear baggage compartment is no longer accessible from the right side.

Early ridership on the accessible RTD intercity routes was quite low, at one or two wheelchair-trips per

month, but that level has increased over time, as more of the fleet has become accessible. Ridership is heavier

on the routes RTD designates as “intercity,” as compared to the ‘regional’ routes that use the same equipment,

possibly as a result of fewer accessible buses assigned to the regional routes. The bulk of the lift usage is on the

route linking Boulder, downtown Denver, and the Denver Airport, for which 57 percent of total bus trips are

scheduled to use the accessible OTRBs. The daily rate of lift usage amounts to nearly 8 lift users out of

approximately 2,800 total passengers.

RTD prints an Accessible Service Brochure describing its services. The Marketing Department of RTD

coordinates the Handicapped Advisory Committee, comprised of RTD staff and representatives from the

disability community who regularly review services and the brochure describing them. The committee has

assisted in the development of sensitivity training sessions using in-class discussions, role playing, lectures, and

videotapes depicting realistic situations bus operators might encounter. RTD also periodically holds open forums

to solicit additional questions and input from the disability community and offers a “training bus” to groups

working with persons with disabilities. A RTD Telephone Information Center provides information about

intersections and bus stops that may pose difficulties for travelers and suggests alternative routes.

1 Much of me following information is horn Econometrics, he., ‘‘Evaluation of Methods to Provide Accessibility to

Over-tbe-Road Buses and Services,” OTA contractor repo~ August 1992.

The experience of public transit systems since Minneapolis, and New York, have seen ridership

buses became accessible provides an interesting by individuals with mobility disabilities increase

counterpoint. Several cities, among them Seattle, dramatically as the transit systems became more
18 0ver-the-Road Bus Access

accessible, although ridership by persons with

mobility disabilities remains a small percentage

of the total (see ch, 3).

 Estimating Potential OTRB Ridership

Given the limited experience with demonstration projects, OTA has attempted to extrapolate

potential OTRB ridership for persons with disabilities from trip frequencies for the total population. First, “trip rates” are calculated for both

freed-route and charter and tour services. A trip

rate is the average number of freed-route or

charter and tour trips taken by a person in the

United States.

OTA estimated the fixed-route intercity per

capita trip rate by taking the best estimate of U.S.

fixed-route intercity ridership and dividing it by

the total U.S. population. In 1990, the Interstate

Commerce Commission estimated fixed-route

ridership on the largest intercity carriers at

approximately 28 million passengers. Increasing

this number by 10 percent to account for ridership

on the smaller carriers results in a figure of 31

million. 28 This figure was divided by the total

1990 U.S. population of 249 million to obtain a

national fried-route trip rate of 0.125 trips per

person annually .29 Similarly, three separate estimation methodologies resulted in a figure of

roughly 290 million trips in 1990 for charter and

tour service, and an average per capita trip rate of

1.17 trips.30

These trip rates are averages over the total U.S.

population. Considerable debate exists about

estimating OTRB trip rates for the subset of

persons with disabilities, assuming all OTRB

services were accessible. On the one hand, some

analysts suggest that trip rates for persons with

A travel group arranged this camping trip for persons

with disabilities.

disabilities would be lower than those for the

general population due to the subpopulation of

persons with disabilities who have overall lower

mobility, or due to the generally lower economic

status of the population of persons with disabilities (i.e., they could not afford the trip). On the

other hand, some researchers suggest that trip

rates could be higher due to both the lower

economic status of persons with disabilities

(because OTRB public transportation operators

are a low-cost provider) and low levels of

automobile ownership. In fact, the profile of

OTRB ridership resembles in many key ways

28 These figures represent only intcrcity fried-route ridership. Ridership on other freed-route OTRB services, such as scheduled airpo~

sightseeing, and other services, was not estimated.

29 One impo~t note Concern tie possibility of developing different per capita trip rates for different age groups ~d for Wbm v. m~

populations. While such a breakdown of the national trip rate might be desirable, it is not feasible with available data.

so The m= estimation methodologies used, respectively are: 1) the statistical summary, Transportation in Arnen’ca; L) Amefim Bus

Association (ABA) Annual Reports; and 3) two sumeys commissioned by ABA. Econometrics, Inc., ‘ ‘Potential Demand for Over-the-Road

Bus Service by Persons With Disabilities, ” OTA contractor report, July 15, 1992.
Summary and Conclusions 19

(including income, gender, and age characteristics) the profile of the population of persons with

disabilities (see ch. 3). In addition, charter and

tour trip rates for persons with disabilities could

be higher than for the overall population if all

OTRB services were accessible due to the convenience of having a tour operator ‘scout ahead’

to determine the accessibility of the tour route.31

Given these differences in opinion, OTA did

not adjust the trip rates for differences in travel

patterns between persons with disabilities and

those without. Therefore, using the trip rates and

the demographic figures developed above for

fixed-route intercity service, if all OTRBs were

accessible today, total trips made annually by

persons with sensory and/or mobility impairments might include the following:32

● 180,000 trips by persons using wheelchairs,

. 210,000 trips by persons using walkers,

. 380,000 trips by persons using any mobility

devices,33

. 33,000 trips by persons using vision technology devices,

. 140,000 trips by persons who are legally

blind,

. 630,000 trips by persons who have sight

impairments that make travel difficult,

. 500,000 trips by persons using hearing

technology devices, and

. Up to 1.8 million trips by persons who have

experienced significant hearing loss.

Similarly, for charter and tour services, total trips

made annually by persons with sensory and/or

mobility impairments might include the following:34

. 1.7 million trips by persons using wheelchairs,

● 2.0 million trips by persons using walkers,

. 3.6 million trips by persons using any

mobility devices,35

. 0.3 million trips by persons using vision

technology devices,

. 1.3 million trips by persons who are legally

blind,

. 5.9 million trips by persons who have sight

impairments that make travel difficult,

. 4.7 million trips by persons using hearing

technology devices, and

. Up to 16 million trips by persons who have

experienced significant hearing loss.

It should be stressed that these numbers are

projections based on a simple model and are

highly uncertain. Estimating travel demand for

services not yet introduced is notoriously difficult. Travel preferences are often unique to the

individual, and only data from an operational

transportation system can give credible projections of future travel on that system.36

In addition to whatever new ridership occurs

from passengers with disabilities, there could be

other direct changes in demand as a result of

making OTRBs accessible. For example, if the

J] Remarks at office of Technology Assessment Workshop, Op. CiL, footnote 17.

32 ~e= flW~ do not ~lude ~rsons using @ bra~s or p~sons using canes or w~g SU&S, who might dso require assistance,

especially in the form of a lower fwst step, in boarding OTRBS. OTA estimates the number of fixed-route trips made annually by persons using

leg braces as 110,000, and the number of fixed-route trips made by pmoms using canes or walking sticks at 550,000.

33 ‘1”~5 ~U&r ~cludes ~r50n5 us~g crutches, wakers, WheelC&s, scooters, ~d other mobility equipment, but nOt persons USbg kg

braces or canes and waking sticks.

34 ~e5e fiwre~ do ~ ~clude persons us~ leg bra~s or persons Ushg canes or walking sticks, who might dSO r~tlk i@SWIICe,

especially in the form of a lower first step, in boarding OTRBS. OTA estimates the number of charter and tour trips made annually by persons

using leg braces as 1 rdlion and the number of fixed-route trips by persons using canes or walking sticks at 5.1 million.

35 ~5 nm~r include5 ~r50n5 u5hg cmtc~e5, w~er5, whee]c~s, scooters, ~d oher mobility equipment, but not persons UShlg leg

braces and/or canes and walking sticks.

36 Dem~d forecut~ rely heavily on Previous usage data. us congress, office of Wc~ology Assessment, AirPort s~~srem Development,

OTA-STI-231 (wi3ShiI@Oflj DC: August 1984), pp. 159-185.
20 0ver-the-Road Bus Access

A quarter million people rely primarily on sign

language to communicate, but many more are

fluent in it.

provision of accessible service requires bus companies to raise rates, certain passengers who are

price-sensitive may choose to ride other forms of

public transportation, go by automobile, or not

travel at all. On the other hand, passengers

without disabilities might accompany family and

friends with disabilities on OTRB trips, increasing the number of trips taken as a result of OTRB

accessibility. Combined with the actual ridership

of passengers with disabilities, these changes in

ridership might result in either a net increase or

decrease. (For further discussion, see app. A.)

Indeed, since OTRB ridership fluctuates for other

reasons (due to changes in the general economy

and points of service), the causes of specific

ridership changes will probably always be impossible to ascertain with confidence, even retrospectively. 37

TECHNOLOGIES FOR ACCESSIBLE OTRBS

AND OTRB SERVICE

What will constitute accessible OTRBs and

OTRB service? This section reviews technologies

appropriate for providing accessible service, training for industry personnel, and restroom accessibility.

Technologies that help persons with disabilities ride OTRBs fall into two categories: 1) those

that assist persons with mobility impairments,

and 2) those that assist persons with sensory and

cognitive impairments. Although the second category addresses a very wide range of disabilities,

many people in this category are assisted by the

same technologies.

 Accessibility for Persons With

Mobility Impairments

Persons with mobility impairments include

individuals who use wheeled mobility aids and

those who do not. While there is much diversity

within these two groups, some generalizations

can be made about the technologies that can assist

them.

Accessibility for Individuals Who Use Wheeled

Mobility Aids

At present, to board an OTRB, most individuals who use wheelchairs or other wheeled mobility aids must leave the aid and be carried to an

OTRB seat. Carrying is presently allowed in

OTRB service because of the lack of other means

to assist persons with mobility impairments in

boarding. However, the interim DOT regulations

for OTRBs state that “. . . we agree with the

discussion in the Department of Justice’s Title II

preamble, that carrying is a disfavored method of

37 ~u~, h me ~o~t ~~culatiom ~~~~~~t~d later ~ ~is c~pter, potent~ flUCMtiOnS in overall ridership levels due to changes in fare

structures (resulting from the purchase of accessibility technologies) are not included. In addition, ridership changes due to the potential for

increased crowding or delays on OTRBS are not included (see app. A).
Summary and Conclusions 21

providing assistance to an individual with a

disability. ’38 The Department of Justice preamble states: “. . . carrying an individual with a

disability is considered an ineffective and therefore an unacceptable method for achieving accessibility.’ ’39

OTA also notes that carrying persons aboard

OTRBs has severe drawbacks:

●

●

●

Many persons who use wheeled mobility

aids find this method of boarding the bus

frightening, humiliating, and, in many cases,

physically painful.40

Carrying an individual up or down stairs and

transferring a person from a wheeled mobility aid to another chair involves many risks.

Even if those carrying or transferring the

individual are well-trained, the process is

always difficult and may result in injury for

any of the parties involved.41

Separation from the mobility aid may incur

risk for certain persons if the supportive

features of that aid are not available during

the trip (e.g., some persons with spinal

problems require the support of certain

restraints built into their mobility aids to

minimize the risk of injury) .42

OTA recognizes that, in the absence of a better

alternative, some persons with disabilities may

find carrying an acceptable interim boarding

method. However, (OTA concludes that carrying as a method of boarding assistance does not

meet the ADA requirement for full accessibility.

Some bus companies have suggested using

special chairs, called ‘‘boarding chairs, ” to aid

persons with disabilities in gaining access to

OTRBs. In order to use a boarding chair, a person

with a wheeled mobility aid must first transfer

from the aid to the boarding chair. BUS company

personnel must then get the person in the boarding

chair to the seating area of the bus by either

carrying the person and chair together up the bus

steps or wheeling the boarding chair up a ramp.

Once on the bus, a second transfer is necessary for

the passenger, this time from the boarding chair to

a standard bus seat. The passenger’s wheeled

mobility aid is stowed in the baggage compartment. At rest stops and the end of the trip, the

transfer must be repeated in reverse.

For most persons with ambulatory disabilities,

there is little or no appreciable difference between

carrying and using boarding chairs. Only for the

most agile persons using wheeled mobility aids—

those who may be able to walk a few steps

unaided--does transfer to a boarding chair involve less risk or less discomfort. Most people

fmd this method of boarding assistance trying; all

participants are put at increased risk of injury; and

separation from the supportive features of some

assistive technologies can be harmful for some

persons with disabilities. In addition, DOT regulations for all other forms of public transportation

(except air travel, see box l-A) specifically forbid

transportation entities from requiring wheeled

mobility aid users to transfer to a vehicle seat. The

entity may provide information on the risks of not

doing so and make a recommendation, but the

38 ~c intcfim regulations go on to state that: “[H]owever, since accessible private OTRBS cannot be required by this rule, there maybe

times when carrying is the only available means of providing access to an OTRB, if the entity does not exercise its discretion to provide an

alternative means. It is required by the rule that any employee who provides boarding assistance-above all, who may carry or otherwise directly

physically assist a passenger-must be trained to provide this assistance appropriately and safely. ” 56 Federal Register 45756 (Sept.

6, 1991).

YJ U.S. Department of Justice, ‘‘Nondiscrimination on the Basis of Disability in State and Local Government Services, ’ 56 FederaZRegister

35709 (July 26, 1991).

40 Remks at Office of Technology Assessment Workshop, “OTRB Accessibility Technologies for Persons With Disabilities, ” Mar. 17,

1992.

Al John v. BmmJ1~ ad R. ~c Kirby (eds.), ~edica/ Rehabi/itatio~ (Ba]tfiorc, m: Williams and Wikens, 1984), p. 247.

42 Rem~ at office of Tcc~ology Assessment Workshop, op. cit.t foo~ote ‘“
22 0ver-the-Road Bus Access

final decision on such a transfer is up to the

passenger.

OTA concludes that, to meet the requirements of the ADA, accessible boarding assistance devices must allow persons to remain in

their wheeled mobility aids. Such devices

include level-change devices that travel with

the OTRB or remain at a station, and ramps

that meet the appropriate slope requirements

(i.e., with a slope of 1 to 12)43

At present, OTRB operators may choose from

several safe and reliable level-change devices.

Some are housed aboard an OTRB, while others

are kept at stations. Most of these devices have

been operationally tested in transit systems or

demonstration projects. Manufacturers have developed several reliable products to meet the

growing demand, but the manufacture of accessibility technologies for OTRBs is essentially a

young industry. Better technologies at more

affordable prices will eventually become available. In fact, several new prototype technologies

are currently in development. (For more details,

see ch. 4.)

In addition to vehicle- or station-based

level-change devices, OTA finds that, in order

to meet the requirements of the ADA, accessible OTRBs must be equipped with at least one

door wide enough to accommodate a wheeled

mobility aid, and with at least two accessible

tie-down placements.44 DOT presently specifies

A man in a wheelchair uses one of several available

OTRB vehicle-based lifts.

that public transportation vehicles over 22 feet in

length (excluding OTRBs) must be equipped with

two tie-down locations.45 Although OTA recognizes that, in some cases, more than two passengers who use wheeled mobility aids may want to

ride a specific OTRB, it is questionable whether

OTRB service is sufficiently different from other

forms of public transportation to warrant a change

in this policy.

The technologies used to secure passengers in

their wheeled mobility aids aboard OTRBs are

still evolving. Several of these tie-down technologies are used aboard transit buses, but few have

43A related concern is the need to plan for evacuation of persons in the event of an emergency en route. Although on-tie-road Om

breakdowns are not a regular occurrence, they are not uncommon. One possible solution might be a regulation specifying that OTRBS not

equipped with their own lift or ramp (i.e., those equipped for use with station-based level-change devices) carry a collapsible ramp and boarding

chair in order to take persons with mobility impairments off the OTRB or to transfer them to a replacement OTRB. This ramp would not

necessarily have to meet ADA requirements for ramps used as routine level-change devices, but must be safe, reliable, and easy to use.

44 ~ tie Preb ~~t for the ~te~ Federal re~ations for both publicly and privately owned 0’rRBs promulgated on S@. 6) 1991?

the Architectural and Transportation Barriers Compliance Board (ATBCB) suggested a minimum clear width for the door of 32 inches to allow

for the passage of persons using wheelchairs or crutches. The American Bus Association (ABA) responded to the draft regulations stating that

,,

. . . the 32 inch clear width requirement for [front] doors could not be met without major structural changes to the vehicle forward sectioq

suspension and running gear components, and recommended a clear width of 30 inches if a width of 27 inches is allowed when structural

members preclude the wider door. ’ ATBCB agreed to the ABA recornmendatio% since the ADA prohibits the interim requirements fium

imposing structural changes on OTRBS. ATBCB has not yet made any decisions regarding OTRB technical speci.tlcations. 56 Federal Regisrer

45557 (Sept. 6, 1991). A second door maybe required to meet a width standard of 32 inches.

45 vehicle5 ~der 22 feet ~ len@ (excludfig automobiles ~d v~ with a ~ting ~pacity of less ~ eight) must have one tie-down

location.
Summary and Conclusions 23

been fully tested for OTRB use. OTA finds that

further testing and evaluation for safety and

effectiveness are needed for tie-down technologies. Movement restriction standards for wheelchairs and scooters in tie-downs and the safety

of these aids in tie-downs during crash situations must also be reviewed for OTRB intercity, charter, and tour use (see ch. 4).

Accessibility for Persons Who Do Not

Use Wheeled Mobility Aids

Many level-change devices and bus modifications are designed specifically for persons using

wheeled mobility aids, but may not accommodate

persons who use walkers, crutches, or other

devices. In particular, some bus doorways are not

tall enough to accommodate persons walking off

a level-change device. OTA concludes that

accessible level-change devices must be equipped

for persons with all types of mobility impairments (i.e., they must allow individuals to use

the level-change device without crouching or

experiencing other undue discomfort).%

In addition, while many persons with mobility

impairments are sufficiently ambulatory to negotiate OTRB stairs, seats, and aisles, certain OTRB

features provide greater risk and inconvenience to

these passengers. To address some of these

problems, DOT already requires new OTRBs to

include slip-resistant flooring, handrails, stanchions, and a minimum clear width for doorways.

However, DOT is awaiting the findings of this

OTA report to determine whether to require a

reduction of the initial step height into an OTRB

(currently 16 to 17 inches). OTA has found that

such a reduction would be useful and would allow

persons with many types of mobility impairments

to board more easily and quickly; for example,

people with crutches and canes and the frail

elderly would benefit immediately .47 Therefore,

OTA recommends that accessible OTRBs have

means to reduce the height of the first step. Three

currently available options (a retractable front

step, a kneeling feature, and a step box) all reduce

the first step height to 8 to 12 inches.

In addition, movable arm rests on OTRB seats

make it easier for persons with mobility impairments to be seated. OTA concludes that some

seats (preferably all aisle seating) on accessible

OTRBs must be equipped with movable arm

rests. Unless all arm rests on an OTRB are

movable, signage must indicate priority seating for persons with disabilities. (Movable arm

rests are currently a common optional feature on

most new OTRBs.)

 Accessibility for Persons With Sensory

and Cognitive Disabilities

Persons with sensory and cognitive disabilities

do not often have trouble boarding or disembarking from an OTRB, but they may find it difficult

to negotiate the terminal, purchase tickets, and

find the appropriate bus. While the specific

problems faced by persons with sight, hearing,

and cognitive disabilities are very different, the

problems have the same root cause, which is

difficulty in communicating and receiving information. These difficulties are relevant to all

modes of transportation, Because they are not

unique to OTRBs, they are not explained in depth

in this report.

DOT has addressed concerns for persons with

sensory impairments in its present regulations,

which require privately operated OTRBs to provide additional lighting in doorways and

stepwells and contrasting step edges.48 Over and

above these issues, however, persons with sensory and cognitive disabilities often have difficulty communicating with bus company employees and receiving important information. OTA

finds that OTRB operators will need to pro46 such a pquircmcrl[ is often lntcrpre{cd to mean the use of a door into the OTRB that is at lcml 68 tiches high.

17 Re~ks at Office of Tcchnolo~ Assessment Workshop, Op. cit., footnolc ~.

4fI DOT has a]so issued rcguhtions for station and terminal acccssibili(y under the ADA.
24 0ver-the-Road Bus Access

.

Many transportation systems already use video

display terminals and similar technologies to

help all passengers, including those with sensory

and cognitive impairments.

vide a range of methods of communicating

with persons who have sensory and cognitive

disabilities, both on and off the bus.

There are many ways to improve communication with persons with sensory and cognitive

impairments. At present, most OTRBs are equipped

with public address systems and signage indicating the destination of the bus. These simple

technologies satisfy most communication needs.

However, OTRB operators may wish to train

workers further to interact with persons with

sensory and cognitive impairments. They may

also choose several versatile technologies already

in use in many transportation settings, such as

posters, changeable information displays, video

display terminals for reporting arrival and departure information in terminals, and color-coding

(or symbol-coding) of OTRBs, to allow persons

with sensory and cognitive disabilities to better

identify specific coaches.49 For example, colorcoded OTRBs and tickets can help persons who

cannot read (as well as those who cannot read

English) find the appropriate OTRB.

 Training

Good staff training in both equipment use and

people skills is vital to ensure the safe and

courteous operation of any transportation system,

especially one serving persons with disabilities.

Employees must be aware of and respond to the

needs of those passengers most likely to require

special assistance, and understand the policies

and procedures of the operator with respect to

such passengers. DOT currently mandates that:

[E]ach public or private entity which operates a

fixed-route or demand-responsive system shall

ensure that personnel are trained to proficiency, as

appropriate to their duties, so that they operate

vehicles and equipment safely and properly assist

and treat individuals with disabilities who use the

service in a respectful and courteous way, with

appropriate attention to the difference among

individuals with disabilities.5o

This performance standard allows for improvements in training practices as they develop, and

OTA finds that this rule is adequate to ensure

appropriate training. Several training programs

developed by public transit systems to educate

their personnel could be modified for the OTRB

industry, and at least one company in Massachusetts has a training program specifically tailored

to OTRB service. Bus company personnel must

pay special attention to the needs of persons with

disabilities who are negotiating a station, purchasing tickets, and boarding and disembarking

from OTRBs. For charters and tours, this might

also encompass services at travel destinations.

 Restrooms

Onboard restrooms or sufficiently frequent rest

stops are essential for all OTRB passengers,

including persons with disabilities. Section 306

of the ADA prohibits DOT from requiring an

49 me ADA rquires telecornm~catiom companies to provide relay services for persons with hearing and speech impairments at no

additional charge to the users. These relay services allow for communication that is functionally equivalent to two-way voice communication.

Thus, bus companies witl not need to invest in telecommunications devices for the deaf (TDD) or other such equipment for resemation or

information services by telephone.

so .56 Federal Register 45641 (Sept. 6, 1991).
Summary and Conclusions 25

accessible restroom aboard an OTRB if it results

in the loss of seating capacity. However, the only

restrooms OTA found in production or under

development reduce seating capacity .51 Thus,

with today’s technologies, DOT cannot require an

accessible restroom aboard an OTRB. The only

alternative available to DOT for providing adequate restroom access for persons with disabilities is to require sufficiently frequent rest stops.

This, however, runs directly into a legal, not

technical, issue relating to express service.

Section 302 of the ADA defines as discrimination the failure to make reasonable modifications

unless making such modifications would fundamentally alter the nature of the services. For

OTRB service, this raises the question as to

whether long, nonstop trips (i.e., express service)

would be altered by a requirement for frequent

stops to accommodate persons with disabilities

who could not use an onboard, nonaccessible

restroom. Some express service provides passengers with nonstop service between major destinations, such as large cities, with trip lengths up to

5 to 6 hours. Assuming that rest stops would be

necessary every 1 1/2 to 2 1/2 hours, and that such

stops would take 15 to 30 minutes, it appears that

more frequent rest stops might indeed alter the

nature of this kind of bus service. Thus, at present,

the provision of restroom service on longduration OTRB runs for persons with disabilities

may be legally impossible to require.

OTA cannot resolve these legal questions, but

points out that prolonged lack of access to

restrooms is not compatible with accessibility. It

is unreasonable to force any passenger to endure

the discomfort that comes from a prolonged

period with no access to a restroom. OTA finds

that OTRBs cannot be designated accessible

until OTRB operators provide sufficiently

frequent access to restrooms for persons with

disabilities, either through on-board accessible

restrooms or

stops.52

STANDARDS,

through providing appropriate

IMPLEMENTAION, AND COSTS

This section discusses the standards for accessible service for fixed-route and charter and tour

operators set forth in the ADA, implementation

requirements for OTRBS, and the costs of complying with these accessibility standards. In

addition to the regulations already put forward by

DOT for accessible OTRBS, OTA defines an

accessible OTRB as one with:

●

●

●

●

●

●

access to level-change devices (onboard or at

stops) that allow individuals to stay in their

wheeled mobility aids,

a sufficiently wide door to accommodate

persons with mobility impairments,

two wheeled mobility aid tie-downs,

movable arm rests,

a means to communicate with persons with

sensory and cognitive disabilities, and

provisions for the use of accessible restroom

facilities.

For freed-route transportation systems, with

the exception of publicly owned companies that

operate OTRBs, the ADA requires private operators to install accessibility technologies when

purchasing or leasing a vehicle.53 Eventually, all

scheduled freed-route service will use accessible

SI For Cxmple, iII 1991 the State of Qhfornia purchased 22 Neoplan Metrolirters with accessible restrooms, which pe~- ently displaced

a minimum of three scats on each OTRB. Econometrics, Inc., ‘‘Evaluation of Methods to Provide Accessible Over-the-Road Buses and

Services, ” OTA contractor report, July 31, 1992, p. 141.

52 Mmy tr~sit buses ad some OTRBS me quipped With stop request buttons or cords, which den the fiver to a passenger ‘quest ‘0

disembark. Such a technology might allow persons with disabilities and other passengers to signal the driver for requests ior information or

restroom access.

53 DOT has inte~retcd this st~d~d ~ p~llcl with Other transportation modes covered by the ADA to me~ that OTRJ3S must be amessible

when purchased or le~sed, and accessibility technologies must be installed if the vebiclc is remanufactured to extend its lifetime for 5 years

or more. 56 Federal Regis(er 45631 (Sept. 6, 1991).
26 Over-the-Road Bus Access

OTRB stations differ greatly, so a single accessibility

technology may not be practical in all situations.

vehicles. 54 In the case of privately operated

OTRBs, there is some debate about whether DOT

has the latitude to promulgate regulations under a

different, perhaps lesser, standard of accessibility.

However, OTA expects that the same standard of

accessibility will be applied to all private operators of public transportation within the jurisdiction of the ADA (see box l-A). Therefore, OTA

anticipates that the ADA’s standard of accessible service for fixed-route private operators of

other public transportation systems extends to

fixed-route service using OTRBs. In other

words, to meet the requirements of the ADA,

all OTRBs purchased or leased for use in

fixed-route service must be accessible.

Charter and tour services meet the definition of

demand-responsive systems. For demandresponsive transportation systems (other than

those using OTRBs and automobiles), the ADA

has required each private operator to

. . . operate such system so that, when viewed in

its entirety, such system ensures a level of service

to individuals with disabilities . . . equivalent to

the level of service provided to individuals

without disabilities.

When purchasing a new vehicle, the ADA requires these private operators to purchase an

accessible vehicle, unless the operator can show

that the system, when viewed in its entirety,

provides the same level of service to individuals

with disabilities as to those without. As with

fixed-route service, OTA anticipates that the

ADA’s standard of accessibility for private

operators of other demand-responsive transportation systems applies to demandresponsive services using OTRBs (i.e., charter

and tour operations). In other words, to meet

the requirements of the ADA, private operators of demand-responsive OTRB service must

eventually have access to enough accessible

OTRBs to accommodate the demand.55

 Implementing OTRB Accessibility

The ADA specifies that private, freed-route,

public transportation operators (those that do not

utilize OTRBs, automobiles, or vans with a

seating capacity of less than eight) phase in

accessible service at the time of the purchase or

lease of a vehicle.56 The ADA does not require

retrofitting existing vehicles.57 OTA finds that

this is also the most efficient method of introducing accessible vehicles into an OTRB transportation system, since it allows maximurn flexibility

54 meDA does not wow ~wrators to provide accessible se~ice ~ough the u= of ~t~tive acc~sible vehicles or f.hrou@ RW_VZitkXl

systems used solely for persons with disabilities. For example, a tour operator could not provide accessible service with an accessible van that

transports passengers with disabilities while the rest of the tour patrons ride in an OTRB.

55 when he Compmy n=d5 t. pwc~5e or Ieme ~ o~, it must buy or l~se ~ accessible ve~cle, tiess it has met this stid~d. (NO

retrofitting is required.) The test of how many OTRBS are enough to provide accessible service is loose. Most fundamentally, if persons with

disabilities request accessible service and are turned away a number of times (where the number is yet to be determined by DOT, law, or

precedent), then the company has too few accessible OTRBS available.

56 See Sec. 304@)(4) ad 302(b)(I)(D)@) of the Americans with Disabfities Act of 19~.

5756 Federal Register 45532 (Sept. G, 191).
Summary and Conclusions I 27

Table l-l—Accessible OTRB Terminology

An accessible over-the-road bus (OTRB) has:

● access to level-change devices (onboard or at stops) that allow individuals to remain in their wheeled mobility aids

. a sufficiently wide door to accommodate persons with mobility impairments

. two wheeled mobility aid tie-downs

. movable arm rests

. a means to communicate with persons with sensory and cognitive disabilities

. provisions for the use of accessible restroom facilities

A trave/er-comp/ete OTRB is:

● an accessible OTRB with a vehicle-based level-change device

A trave/er-ready OTRB is:

. an accessible OTRB without a vehicle-based level-change device, which relies on station-based level-change devices to

elevate passengers with mobility impairments to the passenger deck

Accessible service is:

● the part of a transportation system that uses accessible vehicles

SOURCE: Office of Technology Assessment, 1993.

to the operator while preventing the purchase of

nonaccessible equipments (see app. A).

The time period between the issuance of the

DOT regulations and full accessibility of OTRB

transportation systems will most likely stretch

over the lifetime of an OTRB—roughly 20

years.

59 

some owners may turn over their fleets

more quickly, implementing accessibility technologies as they purchase OTRBs, while others

may allow their fleets to age. Much may depend

on the resale market for OTRBs, which is often

unpredictable. During that 20-year period, OTRB

companies will deploy increasing numbers of

accessible buses, but the whole system will not be

accessible until every OTRB is accessible in

fixed-route service and enough vehicles are

accessible in demand-responsive service.

When an OTRB has an accessible door, two

tie-downs, movable arm rests, provisions for the

use of accessible restrooms facilities and means to

communicate with persons with sensory and

cognitive disabilities (i.e., the ‘‘nonlevel-change

accessibility features’ ‘), and has a vehicle-based

level-change device, it provides accessible service wherever it goes. OTA calls this OTRB a

‘‘traveler-complete OTRB” (see table l-l). If an

OTRB is outfitted with the nonlevel-change

accessibility features but no vehicle-based levelchange device, it is only accessible when it arrives

at stations outfitted with station-based levelchange devices. OTA calls this a ‘‘traveler-ready

OTRB,” In this section, OTA addresses several

implementation issues concerning the purchase of

different types of equipment and the availability

of accessible service to persons with disabilities.

Fixed-Route Service

The implementation of accessible service for

any fixed-route OTRB provider will reflect that

company’s specific needs and capabilities. Implementation strategies are likely to combine travelercomplete and traveler-ready OTRBs. While the

purchase of station-based level-change devices

sounds appealing as a quick, low-cost route to

58 ~c law ~mct~ o~ t. dete~inc tie * ‘most Cost-effwtive’ me~@ of providing access tO OTRBS ad OTRB service. OTA hfo~d

no precedent in case history that provides a definitive definition of most cost-effective. However, the Office of Management and Budget (OMB)

defines ‘ ‘cost-effective analysls‘‘ in the case where benefits cannot be quantified (as is the case in this problem) to mean an analysis to fmd

the least costly approach. OMB Circular, No. A-94, Oct. 29, 1992, p, 4. Consequently, OTA defines the most cost-effective method to mean

the least costly method of providing accessible service within the rquircmcnts set forth by the ADA.

w o~~ompmies may purc~se mmy nonaccessible C)TRBS before the regulations go ifltO effCCt, delamg p~c~ses of accesslble

vehicles,
28 0ver-the-Road Bus Access

Figure 1-5—Percentage of Accessible Boarding

100701 -.

---- Random Implementation of station-based lifts

800/0 — Implementation of OTRBs with vehicle-based lifts

6 0 %

Opportunities, 1996-2016: Two Scenarios

4 0 %

..-

20”/0 “

. . .

---

1996 1998 2000 2002 2004

SOURCE: Office of Technology Assessment, 1993.

implementation, OTA analysis has determined

that in many situations a decision to implement

accessible service with traveler-complete vehicles may serve all parties best.

Traveler-complete OTRBs are accessible wherever they go; traveler-ready OTRBs are not,

unless there is a station-based level-change device at every stop. If 10 percent of a fixed-route

fleet of OTRBs are traveler-ready, 10 percent of

the stations have station-based level-change devices, and the OTRBs and station-based levelchange devices are randomly distributed, then

only 1 percent of the scheduled stops would be

accessible. Even if the station-based level-change

devices are placed advantageously, the number of

accessible scheduled stops by the OTRBs could

never exceed the number of stops that would be

accessible were the OTRBs equipped with vehiclebased level-change devices. In terms of the

number of accessible scheduled stops, therefore,

if station-based level-change devices are introduced along with traveler-ready OTRBs, accessi2006 2008 2010 2012 2014 2016

ble service will increase more slowly than if only

accessible OTRBs with vehicle-based levelchange devices are chosen60 (see figure 1-5).

In addition to these problems, the use of

traveler-ready OTRBs will present DOT with a

more complicated regulatory environment. OTRB

operators may not ensure that traveler-ready

OTRBs are matched with a station-based levelchange device to board passengers, so a regulatory structure may be necessary to achieve

accessible service.

While there are many potential schemes that

DOT could use to monitor bus companies compliance using traveler-ready OTRBs, OTA finds that

one option is preferable. Under this option, DOT

would instruct companies to operate travelerready OTRBs on routes where all of the stops

have station-based level-change devices. This

strategy provides the same amount of accessible

service with traveler-ready OTRBs as provided

by traveler-complete OTRBs on the same routes.

Since this option is tied to the purchase of

w ~s comp~son ~smes that O~S with lifts and OTRBS without lifts will be purchased at the same rate.
Summary and Conclusions 29

vehicles, it also provides flexibility to the bus

company and it is enforceable without registration of an ‘‘accessibility plan’ with DOT.

For these reasons, OTA finds that operators

providing fixed-route service must operate a

traveler-ready bus primarily on routes where

the stops are equipped with station-based

level-change devices. Since OTRBs break down

and scheduling difficulties can arise, bus companies cannot always operate every one of their

OTRBs on set routes, and some flexibility is

needed. Therefore, DOT could allow new traveler -

ready OTRBs in the interim before full accessibility is achieved to have, for example, a

maximum of 10 percent of their scheduled

stops in a given month at stations not equipped

with a station-based level-change device. Or

DOT may wish to allow a delay—for example,

2 years—between purchase of traveler-ready

buses and equipping all of the stations those

vehicles serve with station-based level-change

devices.61

Some bus companies cannot schedule their bus

fleets so that certain OTRBs run primarily on

specific routes. These companies will have difficulty meeting accessibility requirements using

both traveler-ready and travel-complete vehicles.

While it might serve the companies’ economic

interests to adjust their operations to have a

specific set of buses on certain routes, they may

find that they are actually best served by purchasing only traveler-complete OTRBS.

62

Another problem with implementing accessible service in a fixed-route OTRB system is how

best to offer accessible OTRBs before complete

accessibility is achieved. One way to designate

accessible service is to publish schedules showing which routes and times are served by an

accessible bus. Another way to match persons

with disabilities to accessible service is to allow

such persons to make reservations. The ADA

does not allow the mandatory use of a reservation

system by persons with disabilities when persons

without disabilities are not also required to use it;

however, while recognizing certain limitations,63

OTA finds that reservation systems in use by

companies for the general public could be employed to maximize the use of accessible vehicles.

OTA concludes that companies using a

reservation system for every passenger must

make a good faith effort to provide accessible

service to individuals with disabilities who give

notice, for example, 24 hours ahead. Companies that do not employ such a reservation

system must publish schedules with clear

designations of routes and times served by

accessible vehicles, and, for the OTRB routes

and times that are not accessible, the company

~ 1 In ~ ~tcmatlvc Opt Ion mat does not implemcn[ accessibility as cfficicntly, DOT could mandate an implementation schcdu]c in which

mcrea.smg pcrccntagcs of the total number of stops that will eventually usc station-based lifts reccivc such lifts (e.g., 25 percent after 5 years,

50 percent .aftcr 10 years, and so on). However, this option may not bear any relation to OTRB investment cycles. For mstcncc, such an

lmplcmcntation schedule could result in bus operators purchasing station-based lifts before there arc sufficient traveler-ready OTRBS. In

addition, an implementation schedule would require OTRB operators to register with DOT their plans to make their systems accessible, in order

to show compliance with the regulations, and it may be difficult for companies to certify that these plans are acceptable since they involve

decisions over a long lime period.

62 In ~ddl[lon Whllc Capital costs for station_ based Ilf[s my bC lower than for vehicle-based lifts, ~d Station-bred lifts displace ‘0 baggage

or seating capacity, the number of station-based lifts required on certain routes, the cost of storing a lift onsitc, and other factors may combine

to increase the cost of implementing a station-based lift scheme beyond than of vehicle-based lifts (see app. A).

63 one limitation is t~t, even if all passengers usc the same rcscwation system, passengers who do not need boarding assistance have tic

option of purchasing a ticket at the last minute. Yet riders who need boarding assistance do not have this option since they rmiy not be able

to board If the vehicle is not accessible to them, This point also shows one reason why a rescmation systcm in conjunction wilh a number of

trtivclcr-complete OTRBS could never satisfy the requirements of the ADA to provide a fully accessible fixed-route OTRB system.
30 0ver-the-Road Bus Access

Charter and tour transportation destinations change

and vary. Therefore, operators may prefer

accessibility technologies that travel with the vehicle.

can specify that persons call in advance if, and

only if, they need boarding assistance.64

Charter and Tour Service

OTA anticipates that charter and tour operators

will avail themselves of only traveler-complete

vehicles, because they will never be able to ensure

that every stop will have a station-based levelchange device. However, charter and tour companies could explore pooling arrangements as a

means to provide more cost-effective accessible

service.

Pooling arrangements arise when bus companies share equipment. Insurance coverage is

attached to the company that employs the driver,

and other costs are apportioned. Similar arrangements, in which access to lift- or ramp-equipped

vehicles would be provided, could satisfy the

demand-responsive requirements of providing

accessible service. In other words, when persons

with disabilities make arrangements with a charter and/or tour company, the company could

arrange for the use of an accessible OTRB

through a pooling agreement established prior to

the request for service. For many companies,

especially small ones, pooling arrangements could

reduce the cost of providing demand-responsive

accessible service, since fewer accessible vehicles may need to be purchased.

However, OTA finds that current pooling

arrangements are not sufficient to assure accessible service. First, pooling agreements are not

widespread throughout the industry, and they

often allow companies to renege if they need the

OTRB for another purpose. Second, if the demand

for accessible coaches exceeds availability, then

companies in a pool must determine whether and

how they will purchase another accessible coach.

To address these problems, DOT could require

that pooling arrangements used to satisfy the

demand for accessible service specify stringent

obligations for participating companies. In addition, DOT could make the conditions that lead to

the purchase of additional accessible service

capacity more explicit for all companies. If

pooling arrangements to provide accessible

service were sufficiently stringent, OTA finds

that DOT could consider certain pooling agreements acceptable as part of a demandresponsive system “in its entirety,” and could

64 At fii~t ~lace, it ~PPWs tit tie ~esemation system co~d & made VOlUJI~ ~ong witi a system where spectilc routes ~d O~S Were

desigmted as accessible in published schedules, but a second glance reveals a fundamental conflict. Any OTRB made available for a pickup

requested by reservation would be most likely taken from a route that had been designated as accessible in a schedule. This reallocation of the

bus would disrupt service for persons with disabilities who ride the accessible route that the bus normally serves.
Summary and Conclusions 31

Table 1-2—Reasonable Cost Estimates for Implementing Accessibility

Technologies (excluding accessible restrooms) on OTRBs,

Over the Lifetime of an OTRB

Capital costs of level-change devices

Capital costs of a second door, 2 tie-downs,

collapsible seats, and movable arm rests

Maintenance costs of level-change devices

(including capital expenses for overhauls)

over time with no discounting

Revenue over time with no discounting

Totals

Total cost outlays assuming funds on hand

Total costs assuming funds on hand arid

discounting over time

Total cost outlays assuming borrowing for

capital expenses

Total costs assuming borrowing for capital

expenses and discounting over time

$7,000 to $17,000 per vehicle-based lift

($4,500 per station-based lift)

$5,000 to $7,000 per vehicle

$5,000 to $13,000 per vehicle-based lift

($2,700 per station-based lift)

$5,000 gained to $3,000 lost per vehiclea

$20,000 to $35,000 per traveler-complete OTRB

($1 1,000 per traveler-ready OTRB)

$18,000to $31,000 per traveler-complete OTRB

($1 1,000 per traveler-ready OTRB)

$30,000 to $56,000 per traveler-complete OTRB

($19,000 per traveler-ready OTRB)

$22,000 to $39,000 per traveler-complete OTRB

($15,000 per traveler-ready OTRB)

a This figure depends Or-I the number of seats or amount of baggage space lost due to the presence of a

vehicle-based lift. Revenue gains are realized due to the increase in ridership from persons with disabilities.

SOURCE: Office of Technology Assessment, 1993.

allow the pooling of accessible buses to accommodate demand for accessible service.65

 Costs of Accessibility Technologies

The primary costs of implementing accessibility technologies can be classified into three

categories:66

1.

2.

capital costs (including the cost of the

level-change device, any major repairs involving replacement parts that may be

needed as the device ages, and features

related to the main OTRB structure);

maintenance (including routine cycling of

the lift and maintenance checks); and

3. lost revenue (that might result from reduced

seating or baggage and package storage

capacity).

Table 1-2 summarizes OTA’s calculations of the

costs for one new OTRB to be outfitted and

operated with accessibility technologies (not

including an accessible restroom). These estimates follow critical assumptions made by OTA

(see app. A). As with all future cost estimates,

there is a high degree of uncertainty.

While OTA has developed a detailed model to

estimate costs for implementing OTRB accessibility (see app. A for description of the model and

calculations), these cost issues can be understood

in a simpler context. Additional capital costs for

65 pool~g could ~so be ~~owed for fixed-route carriers, but this does not alter the requirement for accessibility when ~1 f~ed-route ‘eMc*cs

arc purchased or leased.

66 ~s]iSt does not include ~mployce ~~fing costS, ~cauSe Om opcrators~Cady inc~ such costs. ApWn&x A discusses other excludcd

costs.
32 Over-the-Road Bus Access

accessibility features run in the neighborhood of

$12,000 to $25,000. Total real costs, including

capital expenditures, maintenance, and lost (or

gained) revenue over time, range from $18,000 to

$40,000.

Since it costs roughly $2.00 to operate an

OTRB for 1 mile in freed-route service, a typical

OTRB running for 1.5 million miles costs $3

million to operate. These expenses are for payroll,

insurance, maintenance, fuel, and other costs (see

ch. 2). In addition, new OTRBs typically cost

$250,000. Comparing the additional capital,

maintenance, and revenue costs for accessibility

to these capital and operating costs reveals that

accessibility costs are in the neighborhood of 1

percent of the total operating costs.

Two accessible restrooms were in production

or development in late 1992: one produced by

Neoplan that costs $2,000 in additional bus

modifications (over and above an OTRB with a

nonaccessible restroom) and permanently displaces three seats; and a prototype made by MCI

(for a 45-foot coach) that is estimated to cost

$30,000 more than a nonaccessible restroom and

permanently displaces seven seats (no additional

seats are lost due to tie-down occupancy).67

Assuming the installation of an accessible

restroom similar to the Neoplan restroom and a

low-cost lift ($7,000) carried in the baggage

compartment, it costs on average $29,000 to

$34,000 more than a standard nonaccessible

OTRB over 20 years for the additional real capital

and operational costs of this OTRB. Assuming

the installation of an accessible restroom and lift

package combining the MCI restroom and a

medium-cost lift,68 it costs on average $66,000 to

$81,000 more over 20 years to operate this OTRB

(see app. A).

Cost of Accessibility Technologies in

Fixed-Route Intercity OTRB Service

The results presented above for one accessible

bus or station can be used to infer the implementation costs of a completely accessible OTRB fleet.

OTRB operators will purchase accessible OTRBs

when the need arises and funds are available.

Thus, buses will be phased in over time as other

buses are retired.

If OTRB operators can choose to purchase

traveler-complete or traveler-ready vehicles, their

choice will depend on the nature of their OTRB

system. (See box 1-F for sample implementation

schemes.) For example, operators in urbanized

areas with many express buses (e.g., in the

Northeast Corridor) will benefit more from stationbased level-change technologies than will operators in rural areas with many stops. Within the

tri-State area of Connecticut, Rhode Island, and

Massachusetts, in late 1991, approximately 419

OTRBs traveled daily among 170 stations. Of

these stations, 117 serviced at least 10 stops daily

(i.e., large stations). Three-hundred thirty-one

OTRBs traveled only among the large stations,

and 88 of the OTRBs made at least one stop daily

at a smaller station. Operators in rural areas like

the State of Montana, on the other hand, will

benefit more from vehicle-based technologies.

On a given day (as of late 1991), only 39 buses

traveled in the State, but these buses stopped at

109 stations, only 3 of which had more than 10

stops daily (i.e., Billings, Butte, and Missoula).

Thus, OTA finds that operator choice in

where to use traveler-complete and travelerready vehicles is an important factor in minimizing costs. By mixing level-change device

types, operators can minimize their overall costs

(see app. A).69

67 AS of ew]y 1993, it is unclear whether these restrooms will meet DA s~tids.

68 MCI ~lm t. ~roduCe i~ 45.fmt accessible coach wi~ an a~essible res~oom ad aU option for a Stewm ~d Stevenson Powerhfl.

Norman Littler, coordinator, Regulatory Relations, MCI, Ltd., Winnipeg, Manitoba, CanadzZ personal communication August 1992.

69 AS noted a~ve, some comp~es may be ~b]e to use both station-based ~d vehicle-based Mt ~s, ~cause ~eY fired it diffic~t to

restructure their bus deployment so that certain buses only follow certain routes.
Summary and Conclusions I 33

Box l-F—Four Hypothetical Implementation Scenarios for Accessible

Over-the-Road Bus (OTRB) Service1

Case 1: A Large Carrier Providing Extensive Fixed-Route Service.

Clover Bus Lines provides freed-route over-the-road bus (OTRB) service, operating at over 700 stations in

both urban and rural areas. In order to meet Americans with Disabilities Act (ADA) accessibility standards,

Clover’s management developed a plan to phase in both traveler-complete and traveler-ready vehicles (see table

l-l).

An analysis showed that 70 percent of Clover’s passengers traveled between urban stations. To keep costs

down, management decided to furnish these high-traffic stations with station-based lifts; buses traveling to these

locations would be traveler-ready, with a wide door and two tie-down positions. Traveler-complete OTRBs would

serve the remaining stations. In accordance with U.S. Department of Transportation regulations, Clover purchased

accessible buses when its nonaccessible buses became too old to keep in service.

In 2000, Clover replaced 50 older buses with new traveler-complete OTRBs. This, in conjunction with an

existing computerized reservation and information system, allowed the company to send accessible vehicles

where needed. In the rare instances in which Clover could not get an accessible coach to a passenger requiring

one, a boarding chair was available.

By the year 2007,50 percent of Clover’s OTRB fleet had turned over. Most of Clover’s high-traffic urban

stations were equipped with station-based lifts, and traveler-ready OTRBs operated among them. In addition,

many traveler-complete buses served rural stations. The company continued to rely on the reservation system to

provide traveler-complete buses through an on-call service, all but negating the need for boarding chairs. In the

year 2016, all of Clover’s service was accessible, and reservations and boarding chairs were no longer necessary.

Case 2: A Small Urban Carrier Providing Commuter, Airport, and Demand-Responsive Service

Fleet Charter and Transit is a small urban carrier providing airport and charter and tour service. Fleet operates

routes from nine local hotels to the airport (running four to six buses daily) and provides charters to sporting and

cultural events in nearby cities, In the year 1999, Fleet needed to buy several new buses. Fleet decided the least

expensive method to implement accessibility was to purchase traveler-complete OTRBs, as the airport service

simply had too many stops to make station-based lifts feasible. On the printed airport bus schedules, Fleet noted

the times when accessible buses served the route. Since Fleet had no reservation system for its airport service,

passengers needing boarding assistance were carried onboard when an accessible bus was not available.

Traveler-complete OTRBs used for the airport run were also used for charter and tour service. When purchasing

new buses for charter and tour service, the company ordered special video and audio equipment on

traveler-complete OTRBs for passengers with sensory disabilities. When booking a charter bus, the operator asked

if the customer needed accessible service.

By the year 2006, 50 percent of Fleet’s fleet was accessible. In the year 2015, all of Fleet’s freed-route

coaches were accessible, and Fleet no longer marked special accessible routes on its schedules. Fleet was able

to meet its entire demand for accessible charter service with three accessible OTRBs. On the rare occasions that

the company needed a fourth accessible bus, it contracted with another carrier.

Case 3: A Small Rural Carrier Providing Fixed-Route Service

Faitsville Lines is a small rural carrier providing mostly fixed-route service. Faitsville operates 17 OTRBs

among Faitsville, Baxter, Rockville, and Sterling, the last being the largest of the four towns and the only one with

train or airport service. Faitsville Lines gets a little charter business from area schools, mostly taking students to

1 MI of&e ~es and companies used in this box are fiCtitOuS.

(Continued on next page)
34 Over-the-Road Bus Access

Box l-F—Four Hypothetical Implementation Scenarios for Accessible

Over-the-Road BUS (OTRB) Sevice-(Continued)

the symphony in Sterling. From 1970 to 1990, Faitsville’s ridership had dropped by one-half, and the company

often had trouble making ends meet.

In 1998, Faitsville Lines needed to replace several buses, and the owner determined that the least costly

means to provide accessible service was through traveler-complete vehicles. Many of Faitsville’s bus stops were

simply grocery stores, car dealerships, or in one case a sporting goods retailer. The infrastructure needed to support

station-based lifts was not present and was too costly to introduce. To maximize its options, Faitsville Lines set

up a noncomputerized reservation system. Customers could call to reserve seats on the bus and in the process were

asked whether they needed accessible service. Whenever possible, individuals who requested accessible service

were provided with an accessible bus. If an accessible bus was unavailable, the bus company arranged to have

employees carry the traveler aboard. In the year 2006, 50 percent of Faitsville Lines’ OTRBs were

traveler-complete. The same year, Rockville’s public high school enrolled a student who used a wheelchair.

Whenever Rockville High chartered a bus, Faitsville Lines was sure to send over a traveler-complete OTRB. Once

riders got used to using the reservation system, carrying became a thing of the past.

In 2008, Faitsville Lines faced severe financial difficulties and could no longer maintain service. It was

bought out by a neighboring company, Mountain Top Bus Lines, which dropped service to Baxter. Mountain Top

had also been purchasing traveler-complete OTRBs, and, by 2015, Mountain Top had replaced its entire fleet with

accessible OTRBs.

Case 4: An Urban Charter and Tour Company

Custom Tours specializes in overnight tours, taking its customers to nearby cities for sporting or cultural

events along with shopping and sightseeing. After the ADA requirments were implemented in 1996, Custom

Tours entered into a pooling arrangement with two other charter and tour companies. When customers called

requesting accessible service, Custom Tours reserved the accessible bus, which was normally operated by one

of the other carriers.

By the year 2005, the pool had expanded to include one other charter and tour company, and needed two more

accessible buses in order to satisfy consumer demand. Custom Tours began to market accessible tours for retired

persons as one of its specialties.

In 2010, Custom Tours needed to replace two of its coaches. The company had such success with its

accessible tours that it decided to discontinue its participation in the pooling agreement and to purchase both

OTRBs as fully accessible with vehicle-based lifts. As a result, Custom captured the elderly tour market, giving

the company a market advantage and reducing the demand for accessible service for other carriers in the area.

I Costs of Accessibility Technologies little operational data exists for charter and tour

for Demand-Responsive OTRB Service

For charter and tour service, the demand for

accessible service determines the number of

accessible OTRBs required. However, even with

the demand figures for accessible charter and tour

service derived above, the resulting requirements

for OTRB purchases are impossible to gauge

since the impacts on a specific company are

dependent on local demand. In addition, very

companies.

As above, if a charter and tour company

purchases a new bus with a vehicle-based lift and

an accessible Neoplan (low-cost) restroom, the

additional cost over the 20-year lifetime of the bus

might run $20,000 for capital expenditures, and

$4,600 for maintenance costs. However, this

figure does not include costs due to forgone

revenue. Due to the complexity of charter and tour
pricing schemes, OTA is unable to place a value

on lost seating and baggage capacity. Thus, it is

impossible to calculate the costs due to revenue

losses. However, they are expected to be greater

per bus than for fixed-route companies, since

charter and tour companies operate OTRBs at

higher capacity than do fixed-route operators.

IMPACT OF ACCESSIBILITY

REQUIREMENTS

This section discusses the impacts of the above

conclusions on: 1) privately owned public transportation systems using OTRBs; 2) persons with

disabilities; and 3) rural OTRB service. In general, mostly due to the large number of bus

companies and the proprietary nature of their

finances, there are too few data to measure the

impacts on OTRB service, except for the fixedroute industry and charter and tour industry in

their entireties.

For the fixed-route OTRB industry as a whole,

OTA calculated above that reasonable estimates

of the average cost to implement vehicle-based

level-change devices for each new bus will range

from $10,000 to $40,000, depending on the

choice of level-change technology (see app. A), or

approximately 1 percent of total operating costs

for that vehicle. Assuming a 20-year phase-in

period, costs to the industry as a whole would rise

approximately one-twentieth of 1 percent per

year.

In 1991, the average operating ratio (before

taxes) for Class I OTRB operators was 98.7

percent.70 Therefore, on average, 1.3 percent of

revenues were left over after deducting the

operating expenses.

71 The change in expenses for

the next several years should not significantly

affect the economic health of most OTRB carriSummary and Conclusions I 35

ers; the l-percent change in operating expenses

that would result 20 years after the implementation of regulations could do so-but only if one

assumes no improvements or deteriorations in bus

company finances, revenues, or operational factors, and assuming no government assistance.

It is unclear whether the bus industry will

continue to operate at such high operating ratios.

In 1991, Greyhound Lines, Inc., had Chapter 11

status through October, and the country was in a

recession, limiting travel of all types in most

sectors. Typical operating ratios in the mid- 1980s

were from 94 to 97 percent. Even with these

operating ratios, however, a l-percent change in

capital and operating costs would be significant.

Thus, accessibility requirements could eventually have some effect on the level of service, as

would any increase in costs. However, whether it

is in restaurants or in public transportation,

Congress found the loss of some service acceptable when it wrote in the ADA that accessibility is

required unless it ‘‘. . . fundamentally alter[s] the

nature of . . . [the] goods, services, facilities,

privileges, advantages, or accommodations[ .]”72

The fixed-route bus industry has been operating

under tough financial conditions for some time

due to competition from other modes of transportation and due to the limitations of OTRB service.

Thus, Congress may wish to consider financial

assistance for this industry-not because of

accessibility requirements imposed by the ADA,

but from the larger perspective of transportation

policy issues such as the provision of low-cost

public transportation alternatives and service to

rural areas (see below).

For the charter and tour industry as a whole,

the impact of the cost of accessibility technolo70 ~te~~tc commerce Commission, Office Of UOflO~cs, ‘*Large Class I Carriers of Passengers Selected Earnings Data” unpublished

documcn~ 1991.

71 since 1970, tie operating ratio for tie class I ~fiers ~sfisen from roughly 88 percent to is present value. However, from 1980 to 1991,

the average operating ratio for the Class I carriers has been especially variable, ranging from between 93 and 109 percent. For the purposes

of this report, OTA has used the most recent estimate for the average operating ratio of the Class I carriers.

~z ~blic ~w 101.336, Sec. 302@) (2)(A) (ti).
36 0ver-the-Road Bus Access

gies is difficult to gauge, especially since it is not

yet clear how many OTRBs must be purchased by

charter and tour companies (and because no

nonproprietary, nationwide data exist for charter

and tour companies). However, while the operating costs per bus-mile for the charter and tour

industry (from $1.60 to $1.90) are lower than for

fixed-route OTRBs, the operating ratios are

believed to be better than those of most fixedroute carriers (see ch. 2). Thus, presumably more

funds are available on average for charter and tour

carriers to purchase accessibility technologies

and to accommodate increased costs for the

accessible portion of their fleet required to meet

the demand for accessible service.

The impact on persons with disabilities of the

purchase-oriented phase-in of accessibility technologies means that full accessibility for fixedroute service will not be achieved for probably 20

years-well into the next century. In addition, for

a number of years, carrying will still be used as a

method of boarding assistance. This means a

delay in the full benefits to both persons with

disabilities and the bus companies.

In addition, if the costs of accessibility are

passed on to passengers in the form of price

increases, some passengers may choose not to

ride OTRBs. Indeed, as OTRB transportation

systems are low-cost providers of public transportation, the market for OTRB transportation, in

particular the intercity portion, is very price

sensitive. However, given the lack of data on

these issues, the nature and effect of a potential

price increase are impossible to predict. However,

OTA estimates the eventual change in ridership

when accessibility is fully implemented to be at

most 1 to 2 percent (see app. A).

Congress instructed OTA to examine the impact of accessibility requirements on service to

rural communities. As stated above, the volume

of OTRB fried-route rural service has declined

dramatically over the past two decades for a

variety of reasons, mostly related to the low

profitability of these routes. It is unclear whether

alone will precipitate further route cuts. The loss

of routes affects persons both with and without

disabilities.

The need to invest in accessibility technologies

may lead to abandonment of some service points.

However, since fixed-route OTRB operators have

been consistently dropping service points over

the last two decades, without an analysis of each

route and more data detailing the profitability of

all routes, it is impossible to determine whether

the cost of accessibility requirements in and of

itself will cause abandonment. This analysis is not

meant to minimize the impact of loss of rural

service, which can be quite devastating in many

areas. OTA concludes only that the extent of

any potential losses in service is impossible to

quantify exactly, but OTA estimates that, as

with ridership, the effect will be marginal.

PUBLIC FINANCIAL ASSISTANCE

FOR OTRB OWNERS

OTRB access for persons with disabilities is

required by the ADA, and implementation of

accessible service will proceed in accordance

with the law and DOT regulations. However, the

debate over implementation is likely to include

discussion of additional financial assistance for

OTRB operators.

Many OTRB operators, particularly those offering fixed-route service, operate with small

margins for profit or capital improvements. Since

the 1970s, the industry has been in decline in the

number of passengers and stops served. In addition, available financial data document a decrease

in the profitability of intercity OTRB transportation, especially during the 1980s. This decline is

due primarily to competition with other modes of

public transportation, such as airplanes, trains,

and, most importantly, automobiles. This industry is far from robust and its future is in jeopardy.

Continued loss of OTRB service would affect

primarily the rural areas served only by this mode

the additional costs of accessibility requirements of public transportation and passengers who
-

OTRB scheduled service is the only form of public

transportation in some rural areas.

require the low-cost transportation alternative

that OTRB service has provided.

With the additional costs due to accessibility

requirements imposed by the ADA, some OTRB

companies have said that they may be more likely

to discontinue service, either partially or altogether. However, the ADA provided very few

means by which to compensate private sector

entities for investment in the accessibility technologies necessary for compliance with the law.

Several small tax breaks were initiated, primarily

to benefit the smallest companies, but no direct

subsidies were enacted.

Summary and Conclusions 37

Although Congress clearly did not intend to

provide further financial assistance to alleviate

the financial burdens of implementing the ADA,

in the case of the operators of public transportation using OTRBs, four arguments for financial

assistance warrant consideration. First, since

OTRB transportation is an essential service for

some segments of the U.S. population, especially

those with low incomes and those living in rural

areas, it would be in the public interest to ensure

its continuation and to avoid OTRB companies

passing on the costs of accessibility in the form of

higher rates for these passengers.

Second, the implementation period for accessible OTRB service will extend over a 20-year

period, beginning after the 1996 enactment of

regulations by DOT (already 5 years later than

regulations published for other public transportation operators). Thus, the benefits to persons with

disabilities of accessible OTRB service will be

delayed during much of that time. Carefully

crafted financial incentives, available over a

limited time period, are a possible means of

encouraging transportation providers to purchase

accessible OTRB

accelerating the

service.

Third, the level

is not excessive.

mentation costs

, earlier rather than later, thereby

implementation of accessible

of financial assistance required

OTA estimates that the impleborne by OTRB fixed-route

operators nationwide are less than $10 million

dollars annually .73

Fourth, several new accessibility technologies

are in the concept phase, but their originators lack

the funding necessary to develop this equipment

for the market (see box l-G). A traditional Federal

role has been to support development and testing

of technologies that can aid in transportation

services. For example, the Canadian Government

has supported the development of several accessible OTRB prototypes (see ch. 3). Government

73 This flWres assumes that 5,()()0 OTW3S arc currenfly used in OTRB fixed-route service and that 5 percent are turned over annuallY. ~

Congress decides to ensure that the OTRB industry continues to function at present levels of service or higher, additional funding may be

necessary.
38 0ver-the-Road Bus Access

Box l-G—Concepts in Search of Development Funds

In the face of an over-the-roadbus (OTRB) indusry struggling to survive, the need for low-cost accessibility

equipment is acute. Although equipment alternatives exist within a wide range of costs, all may not be practicable

for some operators, and the availability of further inexpensive accessibility technologies could ease the burden

of complying with Americans with Disabilities Act (ADA) standards.

Several companies have researched ideas for new accessibility technologies, but for various reasons have

not gone ahead with development plans. For instance, one company has a concept for a portable lift that folds up

and rides on the back of the OTRB. The lift, projected to cost $4,500 to $5,500, would take up no baggage or

seating capacity. OTA has calculated that the cost savings of such a lift could be as much as 10 to 25 percent over

the least expensive vehicle-based lift (see app. A). The details of the mechanism to move the lift from the rear

of the bus to the doorway have been worked out, but the company is concerned about the vulnerability of the

exterior parts to harsh weather conditions. Simulations and field testing are required. Another company has an

idea for an accessible restroom that collapses to the size of a normal restroom when not required to be accessible.

This innovation would reduce the number of seats displaced by an accessible restroom.

Representatives of these companies have explained these concepts to a number of potential buyers, many

of whom are enthusiastic, but none can help the company with the need for capital to finance further development

and testing. These representatives doubt whether their companies on their own can afford to invest the money it

would take to develop these concepts, especially in the face of an uncertain market. Yet the investment amount

is relatively modest (e.g., $250,000 for the external lift concept).

research and development (R&D) funding, pro- Presently, Federal and State Governments asvided during the early part of the implementation sist OTRB owners in several ways, including

phase, could accelerate progress in this area and direct and indirect financial assistance. The two

result in less costly accessibility devices available forms of assistance from the Federal Government

at an earlier date. are: 1) limited direct assistance with capital costs

Therefore, OTA concludes that congres- for accessibility technologies, and 2) tax breaks.

sional support for appropriate financial assis- The Federal Transit Authority’s Section 18(i)

tance and/or incentives might help prevent the program has authorized the purchase of accessiloss of service that could result from the bility technologies as capital expenses that are

implementation of accessible OTRB service. eligible for partial government funding for up to

This assistance could also accelerate the imple- 90 percent of the cost for rural intercity bus

mentation of accessible service. In addition, services. In fiscal year 1992, Section 18(i) fundcongressional support of R&D funding for

ing was $5.3 million. 75 However, this funding

accessibility technologies could be instrumen- source was primarily intended to provide funds

tal in providing safe, reliable, and low-cost for the preservation of rural intercity service.

In addition, all businesses may deduct up to accessible service.74

$15,000 per year at present in “. . . barrier re74 Oher bu~in~-~e~ ~fected bY tie ADA, such as resta~~ts, stores, ~d heaters, do not receive subsidies kyond small tax breaks for Capital

improvements. In the case of OTRB providers, Congress may wish to consider further financial assistance due to the need of rural communities

and disadvantaged groups for the public transportation services offered by OTRB operators, and the challenging financial circumstances

experienced by most OTRB companies.

75 ~s Pmwm o~y ad&esses he needs of f~ed-~ute service, and only freed-mute OTRB OpeHMOrS sen~g ~~ ~eas we eligible for

these funds. Federal Transit Administration, “Section 18 Draft Circular Revisions Proposed Changes to FfA C 9040. IB,” Aug. 9, 1992.
Summary and Conclusions I 39

moval expenses . . . for the purposes of making

any facility or public transportation vehicle . . .

accessible and usable by handicapped and elderly

individuals. ”76 The expenses cannot include new

construction or comprehensive renovation costs,

but can encompass expenses that are modifications to existing facilities or vehicles. Small

companies are allowed a tax credit for 50 percent

of the first $10,000 of eligible costs of complying

with the ADA.77

I Options for OTRB Financial Assistance

Congress could choose to augment existing

financial assistance mechanisms or to develop

new ones. For instance, Congress could choose

to:

. Augment Section 18(i) funding. Since Section 18(i) funding goes for other purposes,

however, Congress will need to take care

when appropriating the funds to ensure that

other purposes for Section 18(i) funding are

not shortchanged, while at the same time

ensuring that funds for accessibility equipment are spent. Augmenting Section 18(i)

funding has the added benefit of addressing

OTRB systemwide concerns as well as

accessibility needs. In addition, the apparatus to distribute the funds has already been

developed by DOT.

. Enact a new financial assistance program

specifically targeted to the purchase and

operation of accessibility equipment on

OTRBs, most likely at less than $10 million

●

annually. Such a program could provide

incentives for bus operators to purchase

accessibility equipment earlier rather than

later. For example, subsidies for accessibility equipment could be highest in the first 5

years of the program’s operation and progressively decrease from that point. In addition, several public policy issues could be

addressed. For instance, the program could

target rural providers and be geared to

maintaining low-cost transportation. Such a

program could sit in the Office of the

Secretary of Transportation or elsewhere in

DOT.

Support R&D for accessibility technologies on OTRBs. A traditional Federal role

has been to provide monies to research,

develop, and evaluate technologies that can

aid in transportation services. New accessibility technologies could provide lower cost

and safer equipment. Technologies to provide accessibility are continually evolving,

and government R&D funding could accelerate progress in this area. Congress could

initiate an R&D program specifically targeted at accessibility technologies. Such a

program could be limited in duration, perhaps 5 to 8 years, and could capitalize on

existing R&D developments in industry. In

addition, DOT could incorporate R&D for

accessibility technologies into its current

assistance priorities.78

76 JI~cl c. Schtifer, ‘‘Tax Incentives, ’ The Americans With Disabilities Act: From Policy to Practice, Jane West (cd.) (NJew Yorlq NY:

Milbank Mcmorial Fund, 1991).

77 ~ addltlon t. F~crd Section 18(]) funding and tax breaks, several State Governments have supported the pMCke of accessible ‘e~cles

through contracts for fixed-route accessible service. For example, the State of California has issued several contracts to private companies to

provide fixed-route OTRB service to Amtrak train stations, All of these OTRBS must be accessible, and these contracts budget for the purchase

of accessibility equipment. State funds have also been used to maintain OTRB service to prevent the loss of semice on certain routes.

78 OTA ~~ reviewed two additio~l Optiom, F~st, congress could choose to augment the c~cnt tax brc~ orcnact new ones for the OTRB

industry. However, many bus company owners claim that, untcss the tax breaks arc in the form of tax credits, they are useless for tbe bus industry

because too many companies make little or no profit. Ln addition, this option would aid some companies much more than others, and not

necessarily those with the most need. Second, Congress could choose to allocate funds through contracts for fixed-route service, to maintain

rural routes or to serve other needs. However, this approach would be in all likelihood too piccemcal to address the concerns of the OTRB

indus~ in general.
Over-the-Road

Bus Industry

and Accessible

Service 2

FINDINGS

●

●

●

●

The 3,500 private companies that operate over-the-road

buses (OTRBs) range in size from Greyhound Lines, Inc.,

with 2,300 OTRBs, to small companies with fewer than a

half-dozen buses. This essentially unregulated, unsubsidized industry provides a variety of services: fixed-route,

regular-route service links some 6,000 communities; charter and tour services provide group travel opportunities; and

commuter, airport, and other services play important

roles in the lives of many Americans.

Since the 1930s, OTRB fixed-route service has been an

established mode of intercity travel. Since the 1960s,

however, the bus industry has faced increasing competition

from other transportation modes. In addition, deregulation

of the bus industry in 1982 permitted bus companies to drop

less profitable routes. Consequently, freed-route OTRB

service now covers a much smaller passenger base (shrinking from 130 million passengers in 1971 to 37 million in

1990) and decreasing numbers of points served (from

17,000 in 1968 to 5,700 in 1991).

The demographics of the markets served by bus companies

vary. People who use fixed-route bus service tend to occupy

the lower rungs of the economic ladder. (Roughly one-half

had incomes below $15,000 per year, in 1991 dollars.) In

contrast, one study showed that charter and tour bus

passengers had average household incomes in excess of

$47,000 per year (1991 dollars).

Most fixed-route OTRB companies have small net operating incomes when compared with their overall revenues.

41
 

42 0ver-the-Road Bus Access

(The average operating ratio for the largest

carriers in 1991 was 98.7 percent.)l While

most charter and tour companies appear to

run with larger net operating incomes, there

is very little nonproprietary data from which

to make a comparison.

. The OTRB industry has been subject to

limited Federal regulation. Since 1982, Federal regulation has primarily governed vehicle safety and driver qualifications, which

apply to motor carriers generally. State

agencies have other intrastate requirements.

Some States have developed small programs

for financial assistance to the bus industry.

The Federal Government also has a small

assistance program geared to improvement

of rural bus service (under Section 18(i) of

the Federal Transit Act, which was funded at

$5.3 million in fiscal year 1992).

. Before passage of the Americans with Disabilities Act (ADA), private OTRB transportation operators were not required to provide

accessible transportation to people with

disabilities. A number of bus companies,

however, have provided accessible service

under contract to public agencies that, because of Federal or State assistance, were

required by law to purchase lift-equipped

vehicles. As of early 1993, virtually all

lift-equipped OTRBs (approximately 350 in

the United States) operated by private bus

companies had been purchased or operated

with the aid of public monies.

OTRBs wait in a loading bay at a large intercity bus

terminal. Over 5,000 OTRBs provide scheduled,

intercity service daily.

CHARACTERISTICS OF THE INDUSTRY

The privately owned and operated bus companies comprising the OTRB industry2 offer many

types of service. The two principal service

categories are fried-route scheduled service, and

charter and tour service.3 Some companies provide both, thus maximizing use of their vehicles.

Some 3,500 bus companies in the United States

operate an estimated 23,000 to 27,000 OTRBS.

4

(See box 2-A for a description of an OTRB.) Only

about 450 of the 3,500 companies, or 1 in 8,

provide fixed-route scheduled service; most of

these also offer charter and tour service. Some

supply commuter, airport, scheduled sightseeing,

and other specialized services, sometimes under

contract to public entities. Bus package express is

often provided in conjunction with fixed-route

service, competing with numerous other package

‘ This 1991 operating ratio figure reflects Greyhound’s bankruptcy status, and thus may be anomalous.

2 Sometimes called the motorcoach industry,

3 The Americans with Disabilities Act (ADA) defines “fixed-route system” as , , a system of providing designated public transportation

on which a vehicle is operated along a prescribed route according to a fixed schedule. ” (Public Law 101-336, Sec. 221(3 ).) It describes both

the fixed-route services of transit systems and what is usually referred to in the OTRB industry as fixed-route service, regular-scheduled service,

or intercity bus sewice. Whether operated exclusively or as an adjunct to freed-route, the charter and tour segment of OTRB operations is

“demand responsive. ” The ADA states that: “The term ‘demand responsive’ system means any system of providing transportation of

individuals by a vehicle, other than a system which is a fixed-route system. ’ (Public Law 101-336, Sec. 301(3 ).)

4 The most common estimate of the number of OTRBS in this country is 25,000, “Metro’s 1991 Top 50 Motorcoach Survey, ” Metro

Magazine, January/February 1991, p. 32.
Over-the-Road Bus Industry and Accessible Service I 43

Box 2-A—What Is an OTRB?

The Americans with Disabilities Act (ADA) defines an over-the-road bus (OTRB) as “. . . a bus

characterized by an elevated passenger deck located over a baggage compartment.”l In practical terms, this

describes a bus 35 feet or longer, usually seating 40 or more passengers (depending on configuration), and

commonly called an intercity bus or motorcoach. This defintion does not include transit buses, vans, minibuses,

school buses, and a variety of other types of vehicles that can be used in intercity transportation.

The exact dimensions of OTRBs vary. Before passage of the Intermodal Surface Transportation Efficiency

Act of 1991 (ISTEA), some States did not permit buses longer than 40 feet. However, ISTEA now authorizes the

use of buses up to 45 feet long in all 50 States. The height of an OTRB passenger deck ranges from 55 to 60 inches

above the ground. Prominent exceptions to this were the GMC Scenicruiser and Flxible Vistaliners, manufactured

in the mid- 1950s, with seating on two levels. OTRB widths are either 96 or 102 inches. Aisle widths range from

a standard 14 inches to as much as 20 inches, and door widths from 24 to 36 inches (40 inches on a Neoplan

double-deck model).2

Most new standard OTRBs cost approximately $250,000. Although most OTRBs include a restroom as a

standard feature, OTRBs providing freed-route service tend to have fewer additional features than those used for

tours. More and more tour buses are equipped with video systems and other extra features. Wider doors and aisles

are available by special order, as are larger (tinted) windows for sightseeing. Reading lamps, card tables, and

AM/FM stereo/cassette players are becoming more common. These additional features cost more money, of

course, and manufacturers equip their OTRBs with custom features as specified by the purchaser.

The average life of an OTRB in the United States is about 20 years. Most bus operators expect to replace

a vehicle after 10 to 15 years, but replacement schedules are determined by a number of factors, including the

availability of capital and the status of the bus resale market. The resale market consists of a handful of large

national firms that sell, lease, recondition, and rebuild used buses, plus an unknown number of small used-bus

dealers. Some bus companies handle their own resales. Purchasers of used buses are usually small bus companies,

private organizations, and nonprofit groups.

1 Public Law 101-336, Sec. 301(5).

2 At one time, AFc, Crown Coach Eagle, Flxible, General Motors, MCI, and Neoplan all had OT’RB production

facilities in the United States. Now only MCI, Eagle, and Neoplan remain. MCI, originally a Canadian company bought by

Greyhound in 1948 and now owned by Greyhound Lines of Canada, Ltd., produces OTRBS in Manitobz Cana&V a U.S.

presence is maintained by an assembly plant across the border in Pemb~ North Dakota. Neop@ a German company, has

manufacturing facilities in Colorado. Eagle, owned f~st by Trailways, then by Greyhound, has been acquired by Mexican

interes~Moto Diesel Mexicana S.A. de C. V., Aguascalientes, Mexico-and has resumed OTRB production on the United

States-Mexican border. In addition to MCIS, Neoplans, and older buses no longer manufactured here, OTRBS used in this

country include Prevost (Canadian), %% Hool and LAG (Belgian), and Setra (German). A Wisconsin company, SABRE Bus

and Coach Corp., plans to manufacture a European-style touring OTRB. A European-style coach is characterized by larger

windows and made-to-order features, such as wider aisles and doors.

express services. The remaining 3,000-plus com- fixed-route scheduled service providers. 5 Grey -

panics offer charter and tour service exclusively. hound Lines dominates the fixed-route industry

Approximately 7,500 OTRBs, or 1 in 3, are with its transcontinental network of routes. Grey -

found in the fleets of the 43 largest bus compa- hound and 27 other companies are Class I carriers,

nies, and only 10 of those firms are essentially defined by the Interstate Commerce Commission

5 $ ‘MCUOIS 1992 Top 50 Motorcoach Survey, “ Memo Magazine, January/February 1992, p. 18.
44 0ver-the-Road Bus Access

(ICC) as those carriers having over $5 million in

gross annual revenue.6

About one-half of the Class I companies, and

about two dozen slightly smaller fins, are

considered regional carriers. 7 Their operations, if

linked together, could form the basis of a national

system comparable to Greyhound’s network of

routes. Many of the regional carriers are members

of the National Trailways Bus System (NTBS), a

group of 28 companies that coordinate schedules

and share terminals and stations.8 All other

companies providing freed-route scheduled service in the United States offer intercity transportation and specialized transportation services in

smaller, often local geographic areas.

To provide transportation services within a

State, whether freed-route, charter and tour, or

special services, a bus company often must

register with its State Public Utility Commission

(PUC) and file tariffs of services and fares. If the

company wishes to offer interstate transportation

services, it must also register with the Interstate

Commerce Commission (ICC) and file tariffs of

services and fares with that body.

A Brief History of U.S. OTRB Service

The first recorded fixed-route bus service

began in 1913 between the towns of Hibbing and

Alice in northern Minnesota. By 1926, 4,040

companies were operating nationwide, including

Greyhound. The rapid growth of bus service

throughout the country led individual States to

establish regulatory control over intercity bus

service within their borders. Pennsylvania was

the first to act, and by 1930 all but Delaware had

some form of regulation. Passage of the Motor

Carrier Act of 1935 authorized ICC to regulate

interstate fares, routes, safety, and other activities

of the motorbus industry. Under its policy of

‘‘universal service,’ ICC permitted some monopolistic practices, ensuring companies an absence of competition in exchange for making

services widely available. The industry developed rapidly during the Depression and World

War II years, growing from 10 billion passengermiles in 1940 to 27 billion in 1945.9

Developments in the 1950s, however, led to

erosion of the freed-route passenger base. The

number of personal automobiles burgeoned, construction of the Interstate Highway System began,

and air travel increased rapidly. To combat the

loss of ridership, the bus industry added package

delivery and charter service. Many bus companies

sought to scale back on their unprofitable routes,

primarily in rural areas. In many cases, this was

met with fierce resistance from State authorities,

who could reject requests for abandonment of

routes deemed to be in the public interest.

The bus industry was further challenged in the

1970s by the formation of Amtrak and by airline

deregulation. Amtrak offered comfortable rail

service at rates comparable to those for bus travel,

thus cutting into market share, especially in the

densely populated and highly profitable North6 Interstate Commerce CormnissioG Office of Economics, “Transport Statistics in the United States: Passenger Carriers, ” draft rcpo~

1991. Class II carriers have gross annual revenues between $1 and $5 million and Class III carriers less than $1 rnillio~ but ICC neither collects

nor maintains data on Class II and Class III carriers. The designation is a holdover from the days before emctment of the Bus Regulatory Reform

Act of 1982.

7 Of the 28 Class I carriers in 1991, 21 were classified by ICC as ‘‘intercity carriers” and 7 as ‘‘local carriers. ” Interstate Commerce

Commission, OffIce of Economics, “Transport Statistics in the United States: 1991,” draft document, table 5. As ICC explains: “Passenger

carriers are classified as intercity carriers if the revenues received from intercity traffic equal or exceed 50 percent of the total revenues received

from intercity and local or suburban traffic. If the intercity revenues are less than 50 percent the passenger carriers are classified as 10ML’

Interstate Commerce Commission, Office of Economics, “Transport Statistics in the United States: Motor Carriers Part 2, for the Year Ended

December 31, 1990, ” unpublished report, p. 2.

* Greyhound purchased Trailways Lines, Inc. inrnid- 1987, consolidated routes, schedules, and stations, and in November 1991 discontinued

use of the Trailways name, also withdrawing from the National Trailways Bus System.

9 John Meyer and Clinton V. Oster, Jr., Deregulation and the Future ofIntercity Passenger Travel (Cambridge, MA: The MIT Press, 1987),

p. 171.
Over-the-Road Bus Industry and Accessible Service I 45

Passengers wait for a bus in Gettysburg, PA in

September 1943. Since the 1940s, OTRB fixed-route

service has diminished, serving many fewer

communities and passengers.

east Corridor.10 Airline deregulation created a

market for carriers such as Peoples Express, with

longer distance rates often less expensive and

travel almost always faster than by bus.

Federal deregulation of the bus industry came

with the Bus Regulatory Reform Act (BRRA) of

1982. Among the BRRA’s findings were that:

. . . the existing Federal and State regulatory

structure has tended . . . to inhibit market entry,

carrier growth, maximum utilization of equipment and energy resources, and opportunities for

minorities and others to enter the motor bus

industry; that State regulation . . . has . . . unreasonably burdened interstate commerce; [and] that

overly protective regulation has resulted in operating inefficiencies and diminished price and

service competition in the motor bus industry.11

The BRRA expedited the entry of new carriers,

eliminated most of the ratemaking authority of

ICC, and allowed the Commission to overrule any

State decision preventing abandonment of service

points. Bus companies were able to discontinue

service to unprofitable locations and concentrate

on their more profitable service points, usually

the larger cities. (See the discussion of Rural

Service later in this chapter.)

FIXED-ROUTE SCHEDULED SERVICE

A 1990 survey of bus companies revealed that

452 firms operated fixed-route or regularly scheduled service. 12 These companies operate a complex web of interconnecting routes, linking approximately 6,000 communities of all sizes, some

with no other means of public transportation.

Greyhound has dominated the fixed-route bus

industry since the 1930s. For 1991, the operating

revenues of all 2 I Class I intercity carriers totaled

$980 million, with Greyhound accounting for 70

percent of this sum.13 Greyhound is the only bus

company providing scheduled service coast-tocoast and, as of January 1993, it served 2,730

locations. 14 Inevitably, Greyhound’s actions influence the rest of the industry, including many of

the other Class I carriers and additional smaller

companies that provide extensive fixed-route

service on a regional and local basis. Some of

them, especially the independent companies now

part of NTBS, interline with Greyhound.

Interlining allows a passenger to travel from

origin to destination on a single ticket via two or

10 me Nofieast Corridor is the concentrated area of urbanized population from Richmond, VA to Bosto@ MA.

11 ~b]ic ~w 97-261, Sec. 3, Sept. 20, 1982, 96 SQt. 1102.

12 The ENO Foundation for Transportation k., ‘‘Report on the American Bus Association Confidential Survey of Intercity Operations,’

unpublished report, December 1990. Russell’s Guide includes only 107 intercity fried-route carriers. Russell’s Guides, Inc., RusseZZ’s Ofl”ciul

National Motor Coach Guide (Spokane, WA: Friendship Publications, Inc., September 1991), p. 1.

13 Intem@te Commerce Commission op. cit., footnote 6.

14 Greyhound Lines, In C., “Greyhound Lines Fact Sheet, ” April 1992, p. 1.
46 0ver-the-Road Bus Access

more carriers.15 If a bus company belongs to the

National Bus Traffic Association (NBTA), it

issues tickets and accepts those issued by another

carrier with the assurance that NBTA will allocate

among the interlining companies the percentage

of the proceeds to which they are entitled.

For example, if a bus company issues a ticket

to a passenger’s destination and does not serve

that community, the company will carry the

passenger to a point where he or she can connect

with a second company, which accepts the ticket

and transports the passenger to the final destination. The two companies share the proceeds

according to agreed on allocation factors. At

present, many companies do not regularly inform

subsequent carriers of any specific information

about passengers (e.g., if they have disabilities

and require assistance) who will be interlining

with their service.

Pooling, a less common method of intercompany coordination, is a formal agreement among

carriers that enables the passenger to take a single

bus from origin to destination over the routes of

several carriers. For example, a company issues

the ticket and carries the passenger on its own bus

with its own driver from point A to point B. At

point B, another driver from another company

continues the journey on the original bus. If the

journey is long enough, the same bus might end

up at the destination point, having been driven by

drivers of three or four companies under this type

of pooling agreement. Often the participating

companies contribute buses to the pool of equipment operated on such a route.

Decline of Fixed-Route Service

The freed-route intercity bus industry declined

in virtually every measure of output or financial

performance from 1967 through 1986.16 Figure

2-1 shows the decline in the number of passengers

during this period, with key events affecting the

bus industry highlighted. Immediately after deregulation, many companies acted to reduce

costs. For instance, Greyhound embarked on a

planned shrinkage of the firm, leading to further

ridership losses from 1985 to 1988, even steeper

than those of previous years.

In March 1987, Greyhound was sold to GLI

Holding Co. (GLIH), which also purchased Trailways Lines, Inc., the second largest bus company

in the United States. The new owners sought to

maintain their reduced operating costs while

offering lower fares, marketing actively, and

improving services. With these attempts to gain

ridership, Greyhound increased its passengermiles by 23 percent from 1986 to 1989. In 1990,

these efforts were overwhelmed by the strike of

the Amalgamated Transit Union Greyhound

Council, representing most of the firm’s unionized drivers, and by the bankruptcy filing of GLIH

in June of that year.

17 Other fixed-route providers

were affected by these developments because of

their interlining arrangements with Greyhound, or

because their service fed into Greyhound routes.

They were also subject to many of the economic

trends affecting Greyhound and had taken similar

steps to improve their operating ratios.18

Figure 2-2 shows the steady decline in the

number of points served by the entire freed-route

15 Interlining is much less common since deregulation.

16 Much of this discussion is adapted from Wosometrics, ~c., ‘‘Background Paper on the Accessibility for the Disabled and the Intercity

Bus Industry,” OTA contractor report, Mar. 31, 1991.

17 From JUe L$, 1990 ~ough OCt. 31, Igpl, Greyhound operated p~suant to Chapterm of me Fe&rd Bankruptcy Code. & Of eitdy 199s,

the company was still operating under an approved Chapter XI reorganization plan.

18 opera~g ratio is c~culat~ as operating expenses divided by opemt~g revenues.
Over-the-Road Bus Industry and Accessible Service 47

Figure 2-1—lntercity Bus Ridership: Class I Carriers, Regular Route Service, 1971-91

160 -Amtra k

subsidies begin Energy

140 , crIsIs 1 begins Airline Energy crisis 2

120

40

deregulation begins

begins Bus Regulatory

Reform Act

strategy

,< ‘- >

GLIH purchase of

Greyhound and

2 0

0 1 1 1 I 1 1 1

1971 1973 1975 1977 1979 1981 1983 1985 1987 1989 1991

SOURCE: Interstate Commerce Commission, Office of Economics, “Transport Statistics in the United States: Second and Final Release,

Passenger Carriers, ” unpublished reports, issued annually for the years 1970-91.

industry during the 1968 to 1991 period. Even

before passage of the BRRA, the fixed-route

network was contracting, despite State regulations that made service discontinuation difficult.

Much service ended due to firms going out of

business, or approved changes allowing routes to

shift to the Interstate Highway System. An ICC

report found that between passage of the BRRA

in September 1982 and January 1986, 3,763

points lost all intercity service.19 This wave of

abandonment included discontinuance of service

to some 1,300 points on Greyhound’s routes. As

of mid-1990, an additional 481 locations served

by Greyhound or Trailways had been abandoned.

As of November 1991, the number of service

points nationwide had declined from 16,800 in

1968 to an estimated 5,690.20

Figure 2-2—Points Served by Regularly Scheduled

Intercity Bus Service, 1968-91

20,000 [

‘ - 1

8-- ---

~ 16,000-4

:

In

g? 12,000 “

6Q

E

; 8,000 ~ D

E3

z 4,000-

m

“ \

‘\

\ I

.

.

\

‘\.

J

/ 01 i I 1 1 1 1 1 1 1 1968 1977 1982 1986 1991

SOURCE: U.S. General Accounting Office, Surface Transportation:

Availability of Intercity Bus Service Continues to Decline, Report to the

Chairman, Subcommittee on Surface Transportation of the Senate

Committee on Commerce, Science, and Transportation (Washington,

DC: June 1992), p. 50.

19 Hmhcr J. Gra~S~n, ~mm, lnters~te Commerce commission, ]etter to Senator Larry Fressler, Sept. 8, 1986.

20 U.S. Generat Accounting Office, Su&ace Transportation: A)’ailabilify of ]nterciry Bus Service Continues @ DecZine, Report to the

Cbairrnan, Subcommittee on Surface Transportation of the Senate Committee on Commcrcc, Science, and Transportation (Washington DC:

June 1992), p. 50.
48 0ver-the-Road Bus Access

Box 2-B—Use of ICC Data in This Study

The best data on the financial and operational performance of the over-the-road bus (OTRB) industry have

been collected from individual bus companies by the Interstate Commerce Commission (ICC). However, the

portion of the industry reporting to ICC and the comprehensiveness of those reports have not been consistent over

time. Therefore, ICC data must be used cautiously.

ICC has collected data from bus companies since 1938. Until passage of the Bus Regulatory Reform Act of

1982 (BRRA), data were collected from all carriers registered with ICC to perform interstate service. Large,

medium, and small carriers, referred to as Class I, Class II, and Class III carriers respectively, were classified by

their adjusted annual gross operating revenues. After passage of the BRRA, data were no longer collected from

Class II and III carriers, and data collected from Class I companies were less detailed. Thus, any attempt to use

ICC data to measure performance of the OTRB industry over the past decade must be confined to Class I carriers.

OTA’s use of ICC data also recognizes the following inconsistencies and shortcomings.

● Class I definitions

The ICC definition of Class I carriers since 1938 has been based on adjusted annual gross operating

revenue in excess of a certain threshold. However, this threshold has been changed four times since

1938.1 In addition, from 1970 to 1991, the numbers of bus companies with adjusted gross incomes

above the threshold varied from year to year.2

● Definition of “Intercity Service Providers”

For purposes of this study, (OTA used ICC data on intercity service providers. ICC classifies carriers

as intercity if more than 49 percent of their total revenues comes from intercity traffic. Many of the

Class I intercity carriers, however, provide a mix of services. ICC breaks out these costs by type of

service, but it is unclear how these numbers are calculated. In addition, OTA discovered that at least

one of the Class I carriers providing primarily local service did not report to ICC revenues in the form

of extensive public subsidies it received for certain of the local services it provided. As a

consequence, its operating ratio was substantially above 100 every year it appeared on the Class I

list.

● Quality control

ICC does not routinely check, and has few means to verify, whether carrier figures are accurate.

1 w~eshold, initially establ@h~ at $100,000, was raised to $200,000 in 1950, to $1 million ill 1%9, tO $3 million

in 1977, and to the current level of $5 million in 1988.

z h 1970, tire w=e 71 CIass I carriers providing essentialIy intercity service; in 1990, bW- 21. m1991 Ck

I carrier report has been compiled by ICC and, as of early 1993, waa under internal review.

ICC publishes very limited data on carrier net at that time, as receiving revenues over $1

operating income.

21 (For a discussion of the million) had a collective net operating income of

problems with ICC data, see box 2-B.) However, $260 million (1989 dollars). In 1989, the 20 Class

in 1970, the 71 Class I intercity carriers (defined, I intercity carriers (then defined as receiving

21 Meuuement by ICC of tie ~ctivi~ of cl~s I c~ms h~ v~ed considerably over me yWS. The ICC definition of (3i.tss I ChW3 SillCe

1938 has been based on adjusted annual gross operating revenue in excess of a certain threshold. Through 1979, the level of detail in the Class

I carrier reports was considerable. The reports of 1980 to 1986 were less detailed, and those from 1987 to 1991, the latest year available as of

autumn 1992, were far more rudimentary. However, not until 1987 were data displayed by carrien before that they were broken down only

by geographic district and region.
Over-the-Road Bus Industry and Accessible Service 49

Figure 2-3-Intercity Bus Industry: Class I Carriers,

Operating Ratios, 1971-91

1990 and 1991

data reflects

Greyhound strike

and bankruptcy ‘J

10“/0 A:

100% ‘

90% ~]

80% ~

I

I

70% ‘ Key:

Operating ratio=

600/0 ~

operating costs/

I operating revenues

50% J 1 1 1 1 1 1 1 1 1 1 1 I

1971 1975 1979 1983 1987 1991

SOURCE: Interstate Commerce Commission, Office of Economics,

“Transport Statistics in the United States: Second Release, Passenger

Carriers,” issued annually for the years 1971-91,

revenues in excess of $5 million) had a collective

net operating income of $72 million. By 1991,

that figure had dropped to $13 million.22

Figure 2-3 reveals a steadily worsening operating ratio for Class I fried-route carriers, from 87.6

percent in 1971 to 94.0 percent in 1989 and 98.7

in 1991. The energy crises of 1973-74 and 1980

had relatively little effect on this trend, which frost

peaked in 1983, the first full year of regulatory

reform. Subsequent cost reduction efforts improved the operating ratio, but were overwhelmed

by the insurance rate spike in 1986-87 (see box

2-C), the strike and bankruptcy of Greyhound

Lines, Inc., and the recession of 1990-92,

Figure 2-4 illustrates the allocation of finds by

category of expenditure for an average bus

company. 23 Payroll expenditures were the largest

category (28 percent), followed by maintenance

(16.3 percent), property costs (14 percent, including rental, mortgages, and taxes), insurance (12.6

percent), and debt service (1 1.8 percent). The

remaining allocations are for fuel and oil (10

percent), and “other,” including profit (7.3

percent).

While these figures show general trends for the

industry, individual companies vary substantially

in their financial outlook. Carriers differ tremendously in:

●

●

●

●

●

●

●

size,

number of passengers carried,

annual mileage per bus,

sizes and numbers of communities served,

use of temninal facilities,

computerization of operations,

ability to increase fixed-route

rates over the past 10 years,

and charter

Figure 2-4-Average Allocation of Funds by the

Typical Bus Company

50% T

I

10“/0

0%

Expenditure

SOURCE: United Bus Owners of America, NTS, Inc., SnapShot: 1991

(Washington, DC: 1991), p. 7.

u Intersmte Commerce Commissio~ Office of ECOIIO~CS, ‘‘Transport Statistics in the United States: Second and Final Release, Passenger

Carriers, ’ unpublished reports, issued annually for the years 1971 through 1990 and the draft report for 1991.

23 Both f~~.route ad ~~ermd tom cfier5 ~~cipat~ ~ the unit~ Bus Owners of ~efica swey from which these data were taken.
50 0ver-the-Road Bus Access

Box 2-C-How Over-the-Road Buses Are Insured

Insurance for over-the-road buses (OTRBs) covers bodily injury, personal property damage, collision, and

general liability on or around the bus and on any premises owned or operated by the carrier. The operator of a

public transportation vehicle is legally responsible for providing safe passage to all riders, whether boarding,

riding, or leaving the bus, under both normal and emergency conditions.

A handful of insurance companies provide OTRB coverage.* The few bus companies unable to secure

insurance directly for financial, operational, or other reasons have access to the assigned risk pool maintained

through each State’s insurance commissioner’s office. A few of the largest bus companies self-insure, but these

must secure Interstate Commerce Commission (ICC) permission to do so. In addition, product liability insurance

is available for manufacturers of OTRBs and accessibility equipment. Whether the increased numbers of

passengers with disabilities and their use of accessibility equipment will affect insurance rates for OTRBs is

difficult to predict.

The Commercial Insurance Market—Rates for the bus industry and for individual operators are based on

‘‘10ss experience”—accidents that result in the insurer paying a claim. Four years of data are usually necessary

to develop hard loss experience figures. 2 Only then is the insurance industry confident that its rates reflect reality.

In the absence of hard data, insurers may be inclined to believe that a perceptible increase in the number of

passengers with disabilities will lead to an increase in claims, but it is impossible to predict what effect this

supposition may have on rates.3

In the mid-1980’s, bus operators found their insurance rates to be quite unstable. Until 1985, the bus industry

obtained its insurance from a small number of company’s, the most prominent of which were Transit Casualty

Insurance Co., CIGNA, National Indemnity, AIG, and Carriers Insurance Co. In late 1985, Transit

1 Less than a dozen insurance companies write policies for public transportation operators: Progressive, Lancer, Lincoln

National, National Interstate, Great Americaq Carolina Casualty, Reliance, Clarendon Natio@ and Aetna. Aetna does an

extensive business in paratransit, and is thought to have the best industry data on transportation of disabled individuals.

Progressive, Lancer, and ReIiance are the principal imurers of OTRB operators.

2 ~~e dati are expressed in “bus-years,” tith a minimum of 1O,(K)O bus-years of data required to develop a

satisfactory level of confidence. Kenneth G. Sisl& assistant vice president, Transportation Division, Progressive Companies,

Cleveland, OH, personal communicatio~ Dec. 6, 1991.

3 Ibid.

● operating ratio, Terminals and Stations

● gross revenues, and Facilities for fixed-route services provided by

● net operating income. OTRBs are either terminals or stations.24 The bus

Many differences are attributable to the nature of terminal serves the needs of intercity bus passenthe companies’ service areas and the magnitude gers. Most terminals in cities or large towns

of competition from other bus companies or other handle ticketing, baggage, and package express

transportation modes, but each company is also service. A station is a business location that

unique in its operation and the type of service provides services to bus passengers as a secondoffered. (For a description of a mid-size carrier, ary activity. These are usually gas stations,

see box 2-D.) grocery stores, restaurants, motels, or similar

~ The ADA considers terminalsand stations to be public accommodations. Section 301(7)(G) specifically identiles as such . . a terminal,

depot, or other station used for specified public transportation.’ Section 302(a) states that “. . . (n)o individual shall be discrimina ted against

on the basis of disability in the full and equal enjoyment of. . . any place of public accommodation by any person who owns, leases (or leases

to), or operates a place of public accommodation.”
Over-the-Road Bus Industry and Accessible Service I 51

Casualty Insurance Co. and Carriers Insurance Co. became insolvent, and CIGNA dropped its participation in a

plan under which coverage was provided at group rates for members of the United Bus Owners of America.

Without these major providers, insurance became more difficult to obtain and rates increased dramatically, in

many cases doubling. By mid-1987, however, with the entry of other insurance companies into the field, rates

began to drop.

Assigned Risk Pools—The insurance industry adminis ters most assigned risk pools. Risk pool premiums

can be twice those available directly from a commercial insurer. Anyone reasonably entitled to insurance and

unable to obtain coverage in the open market is placed in the pool. In Washington State, for example, the only

eligibility criterion is that an applicant’s coverage must not have been canceled for nonpayment within the past

2 years. Pool rates are currently set at 150 percent of the standard rates for commercial vehicles within the State. 4

Self-Insurance--ICC requires each motor carrier applying for self-insurance to provide financial, safety,

and claims data for the last 3 years and evidence of safe operations in the form of a satisfactory safety rating from

the U.S. Department of Transportation. ICC reviews this and other information under general guidelines; wide

differences in motor carriers’ size and operational characteristics preclude the use of specific criteria.5 Once

permission to self-insure is granted, ICC monitors the carrier, requiring quarterly financial reports and claims data.

As of summer 1992, only two bus companies were self-insured: Greyhound and Peter Pan. Three other

companies had permission to self-insure but had not done so. Some companies may want to self-insure only for

the first $1 million of the required $5 million and buy the rest on the open market, where the first $1 million of

coverage is the most expensive. Other companies may view permission to self-insure as a bargaining chip with

insurance carriers.6

Product Liability Insurance-Product liability insurance protects the manufacturer of a lift device or an

OTRB, but not all manufacturers carry such insurance. Manufacturers generally retain legal and engineering

experts to advise them on how best to prevent accidents and lawsuits.

q Mien Morrow, deputy insurance commissioner, State of Washington, pWSOnd COIIUUUnkdOIL Jm. 14, 1992.

5 Interstate Cornmercs Commissio~ “EX Parte No. MC-178: Investigation Into Motor Carrier Imurance Rates,”

decided Jan. 20, 1987, p. 6.

6 Alice ~sey, assistant to tie deputy director, Section of Operations and Enforcement Interstate Commerce

Comrnissio~ personal commurticatiou Feb. 18, 1992.

small business establishments whose proprietors study identified 1,991 terminals and 1,775 staserve as agents for the freed-route lines serving tions for a total of 3,766 fixed-route passenger

the community. The flag stop-locations by the facilities. More than 80 percent of these facilities

side of the road where the bus picks up passengers— were owned or leased by Greyhound, Trailways,

is far less prevalent with the decline of rural and the members of NTBS. Independent carriers

service. accounted for the remainder.

In 1984, a combined ICC/U.S. Department of The subsequent shrinkage of the Greyhound

Transportation (DOT) study found that in cities of and Trailways networks, the sale of many termimore than 100,000 population, 84 percent of bus nal properties by Greyhound, the purchase of

facilities were terminals compared to only 39 Trailways by Greyhound, and the consolidation

percent in towns under 15,000 population.25 The of facilities, have resulted in far fewer terminals

‘5 U.S. Department of Transportation, Office of the Secretary, Transportation Systems Center, and Interstate Commerce Commission, OffIce

of Transpoflation Analysis, “The Intercity Bus Terminal Study: A Report to the President and the Congress of the United States,” unpublished

report, December 1984, p. 13.
52 I Over-the-Road Bus Access

Box 2-D-Profile of a Fixed-Route Carrier

Acme Busl is a family-owned mid-size intercity bus company that has operated in the Midwest since shortly

after World War I. The company’s routes and services have evolved with the changes in the intercity bus business,

but do not connect on a regular basis with publicly operated rural bus service or paratransit.

Acme serves more than a half-dozen States in the Midwest and interlines with Greyhound. Scheduled

freed-route service represents about threequarters of the company’s ridership. The remainder consists of charter

service plus a bit of tour service. Its fixed-route service has changed considerably since the passage of the Bus

Regulatory Reform Act. The company has eliminated most service to small towns in favor of large and

medium-size cities, although a couple of routes linking major cities have been dropped. Acme managers estimate

that more than 90 percent of its passengers board at full-service terminals. Only one or two bus stations operating

out of a food store or gas station remain on the system; there are no bus shelters on Acme’s routes, and it serves

no flag stops.

The company’s freed-route passengers are seniors, students, and middle- to low-income persons who do not

fly for financial or other reasons. Since 1981, ridership has declined steadily. Although Acme has conducted no

marketing surveys, management views the private automobile as its prime competitor and believes that its

passenger profile has not changed since the early 1980s.

None of Acme’s nearly three dozen over-the-road buses-average age about 10 years-is lift-equipped.

Acme’s managers estimate that each year they receive around 15 inquiries about accessible service from

passengers who use wheeled mobility aids and that perhaps 100 of its 250,000 passengers need some kind of

assistance to board. Boarding assistance extends to lifting and carrying if necessary.

Acme has 50 or so drivers and approximately one dozen mechanics, all of whom are male. These employees

are unionized; employees who perform supervisory, managerial, clerical, and other support functions are not.

Acme uses computers for accounting and for charter information, but not for dispatching. The company does not

have an advance reservation system.

The company’s operating ratio for 1985 to 1990 was around 95 percent. Like many similar companies that

interline with Greyhound, Acme was affected by that company’s 1990 strike. Acme’s operating ratio was further

hurt by the recession of the early 1990s and the reluctance of some individuals to travel during the Gulf War in

early 1991. However, Acme’s worst year coincided with the insurance crisis of 1986-87. Due to competitive

pressures, Acme has not raised its fixed-route fares since a 10 percent increase in 1983. Its charter rates rose in

1985 by 6 percent and again, in 1991, by 5 to 10 percent.

When asked, “If you could do anything you wished, what would you change about your business?” Acme

management replied: “The company has changed about as much as it could over the last 10 yearn, eliminating

most of the nonproductive routes and cutting out a lot of fat. Not much more can be done. ” The managers think

the future of the industry lies in cooperative arrangements among bus companies, through the sharing of systems,

terminals, and technology.

1 “Acme” is a fictitious name; the bus company is real.

and stations than a decade ago. Generally, termi- figures show that, as of May 1991, the company

nals are no longer staffed by bus company used a total of 1,967 terminal and station faciliemployees, but by contract agents. Greyhound ties. 26

26 Econometrics Inc., ‘‘Description of Available Intercity Services, OTA contractor report, May 21, 1992, p. 35.
Over-the-Road Bus Industry and Accessible Service I 53

Fixed-Route Ridership

In August 1989 and 1991, Greyhound conducted onboard passenger surveys to establish an

updated passenger profile.27 Results characterized the income, age, employment, and other

demographics of riders. The questions posed in

the two surveys varied only slightly (see table

2-l). Along with the high percentages of lowincome, female, minority, and elderly individuals

using intercity buses, the surveys found that most

trips were taken to visit friends or relatives, over

one-third of bus travelers took 4 to 10 trips of 50

or more miles per year, over 20 percent defined

their communities as rural, and almost 50 percent

did not own an automobile capable of a 500-mile

trip. 28

In the 1991 survey, 47 percent of riders had

household incomes under $15,000 per year. That

same year, the poverty line for a family of four

was $13,400. Census data for 1990 indicate that

approximately 16.9 percent of all families had

incomes below $15,000. A 47-percent ridership

among individuals at that income level means that

those with incomes below $15,000 are roughly

three times more likely to be bus riders than a

random draw of the population would predict.29

Similarly, 1977 census data show that lowincome families (then under $10,000 per year)

accounted for 45 percent of intercity bus passengermiles, compared to 25 percent of rail passengermiles, 18 percent of auto passenger-miles, and 15

percent of air passenger-miles (see figure 2-5).

Figure 2-6 shows the age distribution of bus, rail,

auto, and air travelers. The bus passenger is

characterized by extreme youth and age. Business

was the travel purpose of only 4.6 percent of bus

Table 2-l-Characteristics of Greyhound Riders

1989 1991

Personal characteristics

Incomes under $15,000 per year. . . .

Female. . . . . . . . . . . . . . . . . . . . . . . .

Minority a

. . . . . . . . . . . . . . . . . . . . . . .

Never married. . . . . . . . . . . . . . . . . . .

High school graduate or less. . . . . . .

A g e

Ages 16-24 . . . . . . . . . . . . . . . , . . . . . .

Ages 65 or over. . . . . . . . . . . . . . . . . .

Employment

Full time. . . . . . . . . . . . . . . . . . . . . . . .

Retired. . . . . . . . . . . . . . . . . . . . . . . . .

Part time. . . . . . . . . . . . . . . . . . . . . . .

Full-time student. . . . . . . . . . . . . . . . .

Unemployed. . . . . . . . . . . . . . . . . . . .

Active military duty. . . . . . . . . . . . . . .

Purpose of trip

To visit someone. . . . . . . . . . . . . . . . .

Business. . . . . . . . . . . . . . . . . . . . . . . .

Total annual trips of 50+ miles

1-3 trips. . . . . . . . . . . . . . . . . . . . . . . .

4-10 trips. . . . . . . . . . . . . . . . . . . . . . .

11-30 trips. . . . . . . . . . . . . . . . . . . . . .

30+ trips. . . . . . . . . . . . . . . . . . . . . . .

Miscellaneous

Traveling alone. . . . . . . . . . . . . . . . . .

Never traveled by air. . . . . . . . . . . . . .

Do not own auto capable of 500-mile

trip. . . . . . . . . . . . . . . . . . . . . . . . . . .

Describe home community as rural. .

44.30/0

60.9

37.8

41.9

42.6

26.3

15.1

41.3

19.0

13.5

13.6

10.9

1.7

55.4

3.8

35.1

36.3

18.8

9.8

64.2

21.3

49.7

20.4

47.20/.

57.8

41.8

43.8

41.7

28.1

12.2

40.4

15.5

15.3

14.0

13.3

1.5

53.2

6.2

33.2

36.7

20.2

9.9

64.4

23.2

46.0

21.7

a Minority includes nonwhites, listed as Asian, Black, Hispanic, and

other.

SOURCE: Greyhound Lines, Inc., “Greyhound On Board Passenger

Profile Surveys,” unpublished surveys, 1989, 1991.

passengers, compared to 50.7 percent of airline

passengers and 37.2 percent of rail passengers.30

27 Econometrics, Inc., op. cit., footnote 16, pp. 2425.

‘s A Bureau of the Census survey in 1977 found that more than 30 percent of bus riders came from rural areas.

29 Ric&d V, Bur&~uscr, professor of economics, The Maxwell School, Syracuse University, personal cornmunicatio% Jme 26, 1992.

30 Ecosornetfics, Inc., op. cit., footnote 16, p, 25. OTA notes that these da~ and those in figures 2-5 and 2-6 are from 1977, before airltic

and OTRB deregulation and many other changes in U.S. transportation. Thus, they may not be entirely applicable to OTRB service in the 1990s.

However, OTA analysts spoke with a number of bus companies in early 1992 to determine if company officials had noticed any change in the

composition of their ridership over the past 10 years, Responses indicated no changes, except to reflect trends in the mix of services, e.g., if

fixed-route services to smaller communities were reduced, and charter and tour services were increased, the overall ridership tended to have

a higher percentage of older, retired people with more discretiomry income.
54 0ver-the-Road Bus Access

Figure 2-5-Intercity Passenger Travel, by Family

Income and Transportation Mode, 1977

100% ~

90% ‘

8 0 %

70%

~

~ 60%

F

: 50%

5

cl40%

30%

r

- ,-

Commerclal Auto Bus Train

aircraft

(1977 dollars)

_ Low Income: less than S10,000

~~ Medium Income: SI0,000 to S19,999

~ High Income: $20,000 and over

NOTE: In 1977, the poverty threshold for a family of four was $6,191.

SOURCE: Robert R. Nathan Associates, Inc., from data in U.S.

Department of Commerce, Bureau of the Census, “Travel During

1977,” October 1979.

CHARTER AND TOUR SERVICE

The charter and tour industry is the largest user

of OTRBs. One study found that some 12,750

intercity coaches in use in North America in 1990

were in tour and charter fleets, compared to

10,500 in scheduled service.31 As noted earlier,

however, firms that offer both fixed-route and

Charter and tour service provides many opportunities

to travel to sites in North America, such as the Lincoln

Memorial.

charter and tour services might use the same

coach for any of these purposes. (See box 2-E for

a description of a company providing a mix of

services.)

Prior to deregulation, ICC and individual State

PUCs granted charter authority only to those

companies operating freed-route service. Profits

from charter and tour service often subsidized

financially weak fixed-route service. Deregulation enabled this linkage to be broken.32 Following passage of the BRRA in 1982, many smaller

firms abandoned freed-route service to concentrate exclusively on charter and tour operations.

Indeed, during the first year of regulatory reform,

ICC processed 2,028 applications for new authority, one-half of which were from first-time

applicants and 1,775 of which were for charter

only. 33

31 { ‘Coach Sale Grow~ is Predicted Through 1994, ” kferro Magazine, January-February 1991, p. 20. Other coaches nOt included in ~ese

numbers may be owned by churches, private and public organizations, or other groups.

32 ~ ~ctiga, 24 bus comp~es provided both fixed-route and charter service during the late 1960s. There are now 128 bus compties

in the State, of which only 6 operate any freed-route service, and 4 of the 6 provide only local commuter or airport limousine service. Similarly,

Virginia now has 3 firms supplying fixed-route service, compared to 13 prior to deregulation. Frederic D. Fravel et al., “Rural Inter-Regional

Public Transportation Study, ” prepared for the Virginia Department of Transportatio~ Rail and Public Transportation Division, November

1988, p. 4, Although national data have never been collected, evidence suggests that the non-Class I carriers still providing scheduled service

are more than likely supplying it as commuter service, airport service, or scheduled sightseeing. Econometrics, Inc., op. cit., footnote 16.

u Intcm~te Commerce Commission, The Inrercity Bus Industry (Wash@toq DC: JaDWMY 1984), pp. 75-76.
Over-the-Road Bus Industry and Accessible Service I 55

30%

25%

20%

15%

1 0 %

5%

0 %

Figure 2-6—lntercity Passenger Travel, by Age of Traveler and Transportation Mode, 1977

(percent of total, by mode)

Commercial aircraft

— . . . . . . . ———.. 1

.. .-,.

.

I

... .. —.—.——. ——. --— 1

J

c18 18-24 25-34 35-44 45-54 55-64 65+

3090

i---l

Bus

250/o

50/01 11111 1

o,ouJ_LLLd

<18 18-24 25-34 35-44 45-54 55-64 65+

30%

250/o

20%

15?L0

10%

5%

00/0

30%

250/o

20%0

15%

10%

5%

0%

Auto

<18 18-24 25-34 35-44 45-54 55-64 65+

Train

<18 18-24 25-34 35-44 45-54 55-64 65+

SOURCE: Robert R. Nathan Associates, Inc., from data in U.S. Department of Commerce, Bureau of the Census, “Travel During 1977,” October

1979.

The total number of bus companies grew from on a charter basis, or may itself serve as tour

less than 1,000 in 1982 to an estimated 3,600 in operator, selling tours to the public. These differ1990, with much of the increase provided by ing roles are described by three types of service:

small firms. However, when insurance rates rose ●

dramatically in 1986-87, and increased competition in charter and tour service created severe cost

pressures, some large companies with both fixedroute and charter and tour services focused on

fixed-route because of its relatively stable revenue. ●

Of the 3,000 providers of charter and tour

services, about 750 classify themselves as operators of escorted group tours, either with their own

buses or with charters.34 A bus company may ●

provide only a bus and a driver to the tour operator

Charter transportation provides group travel

where the schedule, origin, and destination is

set by members of the group. The company

providing the bus receives payment from the

group; no transaction occurs between the bus

operator and individual passengers.

Charter tours include additional services

requested by the group and arranged by the

bus operator, such as meals, lodging, or

attractions.

Retail tours include the same services as

charter tours but are sold directly to the

34 Stephen M. Jolm.son, (iircctor, Government and International Relations, National Tour Association+ ~c., personal cornrn~catio~ MM.

16, 1992.
56 0ver-the-Road Bus Access

Box 2-E—Profile of a Carrier Providing Mixed Services

Anchor Bus Co.1 is a large carrier operating in a major metropolitan area in the Northeast. Founded in the

late 19th century, the company has been owned by the same family since before World War II. Anchor provides

a variety of services with 65 over-the-road buses (OTRBs), 15 transit buses, and 1 van. one-quarter of its OTRB

fleet is lift-equipped, with 10 lift-equipped buses acquired through a State-financed program to promote OTRB

accessibility, and 6 through contract arrangements with a public agency. The van and three transit buses are also

lift-equipped.

Ninety percent of Anchor’s service is fixed-route; the remainder consists of charter and tour. The fixed routes

link outlying suburban and rural communities in the metropolitan area to downtown and the airport.The maximum

distance one-way is about 115 miles, with most riders traveling shorter distances. This mostly commuter service

operates all day, with peak frequency during rush hours. As a result, the company’s OTRBs are available for

charter and tour service, primarily on weekends.

About 75 percent of the company’s ridership is handled at three full-service terminals in the metropolitan

area. The terminals are owned by other operators; Anchor is a tenant. Other passengers, mostly commuters, board

at ‘‘Park & Ride’ stations; a few are picked up at flag stops. The company has done some marketing surveys,

confirming that its market for fixed-route services is blue- and white-collar workers traveling to and from the

central business district. Retirees and students predominate during off-peak hours. The charter market is

comprised largely of suburban groups.

Some persons with disabilities travel regularly on Anchor’s Ml-equipped OTRBs; most are commuters. The

vehicle-based MCI internal lifts are used about 75 times per year. Anchor keeps records of lift usage, but does

not track the number of passengers whose disabilities may require other boarding assistance. The company has

a 24-hour advance reservation system for passengers requesting accessible service, and works closely with the

disability community to publicize the availability of its lift-equipped buses.

Anchor’s 100-plus drivers and 12 mechanics are all unionized. About 10 percent of the drivers are women.

Drivers undergo an intensive 4-week training program, and mechanics are subject to continuing training

requirements. The company has not computerized any of its operations.

Anchor’s operating ratio runs between 90 and 95 percent. In a tight market, the company has been able to

raise its freed-route fares by only 5 percent over the last 10 years. Its chief competition is a State-subsidized van

pool system, and its main concern is the regional transit authority’s proposed extension of commuter service into

Anchor’s service area. Looking ahead, Anchor management believes the company’s future as a provider of

commuter and airport services may lie in securing more contracts with competing public bodies.

1 ,c~kr,, is* fictitious z;tk bm co~~y is ‘d”

public on an individual basis by a tour Comparing Fixed-Route and Charter and

operator who makes all arrangements for Tour Service

meals, attractions, accommodations, tour The 1990 American Bus Association (ABA)

guides, and so forth. The tour operator may survey of the 452 firms performing fixed-route

be a bus company or a travel agent. (See box service as well as charter and tour operations

2-F for a profile of a medium-size tour bus revealed that, of their estimated total revenue of

operator.) $1.8 billion, charter and special service accounted

for an estimated 30 percent, and tour transporta-
Over-the-Road Bus Industry and Accessible Service I 57

Box 2-F—Profile of a Medium-Size Bus Tour

Ajax Tours, Inc.1is a medium-size bus tour operator, in business for almost 20 years, and based in a midwest

community of about 100,000 population. Ajax operated 150 tours in 1991, about 75 percent of them between May

and October, the peak season in that part of the country. Business is fairly good during the shoulder seasons from

October to early December and again from March to May. During the winter it falls off drastically.

The company owns two new over-the-road buses, which are not lift-equipped but have a kneeling feature

for easier boarding.2 Four 12-passenger vans are used mostly for passenger pickups. Ajax charters six to eight

additional over-the-road buses from a bus operator located a few miles out of town, making reservations 6 to 8

months in advance. The operations of Ajax Tours, Inc. are completely computerized.

The company conducts tours throughout the continental United States and Canada with its own buses and

its charters. The most popular and frequent tours, representing 25 percent of the company’s total business, are to

Nashville, Tennessee, and Branson, Missouri, centers for country music. Sixty percent of all tours are for 1 day.

The typical longer tour is 3 to 5 days, with some tours as long as 30 days.

Most passengers are over 55 years of age, with disposable income, who like to travel but can no longer drive

or who prefer not to. In recent years, the number of passengers in their fifties has increased, and females clearly

predominate. In a typical tour group of 40, only 4 to 8 are males.

Customers tend to be less interested in tours of 2 weeks or more, preferring in such cases to fly to their

destinations and spend more time touring locally. Increasing numbers seem to want less structured tours than in

years past, with more options to see sites of particular interest to them.

In a given year, Ajax will accommodate from 12 to 15 persons using wheeled mobility aids who thus far,

with the kneeling feature of the bus, have been agile enough to board by themselves. Their wheelchairs or scooters

are stowed in the baggage compartment. Larger numbers of passengers who have limited mobility but do not use

wheeled mobility aids, and others with visual and hearing impairments, tour on Ajax during the course of a year.

The company’s chief competition is nonprofit organizations running tours for their members. Over the past

5 years, Ajax has been able to raise its tour rates by 10 to 15 percent and remain competitive in the commercial

tour market.

1 “Ajax” is a fictitious name; the company iS Rd.

2 me ~eel@ fea~e ~eduCes he height of tie f~st st~ to 9 inch- above tie gro~d, a rtiuction of 4 1/2 inches.

tion for about 6 percent.35 Fixed-route service charter passenger and $21.18 per fixed-route

accounted for 57 percent and package express for passenger. These figures also reflect differences

7 percent of revenues.36 in average trip lengths. Of particular note is that

The 452 firms provided an estimated 38 million the average passenger revenue was $1.97 per

passenger-trips on charter and special services, fixed-route bus-mile compared to $1.63 for charand 1.5 million trips on tours. The average ter and special services, and $1.83 for tour

services. 37 However, a subset of 56 firms operat- revenue for tour passengers is estimated to be

$64.04 per passenger, compared to $12.98 per ing only fixed-route OTRBs reported $2.21 per

35 Mark Beavers, “A Picture of the Industry, ” Destinations (American Bus Association), December 1990. Magazine survey respondents

tend to be self-selecting and therefore do not always represent the target audience.

36 ENO Foundation for Tr~PO~tiO~ InC., op. cit., footnote 12 percentage of revenues de~ved ffom pactige express VarieS frOIll C~er

to carrier, ranging from about 5 to 15 percent.

37 ibid., p. 3.

330-069 0 - 93 - 3 QL:3
58 0ver-the-Road Bus Access

bus-mile. This may be due to the fact that some

OTRBs on freed-route service generate income

from package express.

These revenue estimates suggest that although

freed-route ridership is shrinking, it is the only

service capable of paying higher operating costs.

For charters and tours to be profitable, operating

costs must be lower on a bus-mile basis. This may

be the reason why a number of the unionized

fins, which pay higher wages, such as Greyhound Lines, Jefferson Lines, and Carolina Coach,

have substantially reduced their charter and tour

operations, focusing instead on their fixed

routes. 38 The large increase in the number of

companies offering charter and tour services has

also increased competition, severely limiting the

ability of some higher cost firms to compete in

this market.

Ridership

Little nonproprietary information about charter

and tour passengers is available. A 1986 market

research effort to identify the characteristics of

the customers of one particular firm showed that

bus tour patrons have a median age of 60, and take

an average of nearly five l-day vacation trips per

year, 4.1 overnight or weekend vacation trips, and

2.3 extended vacation trips annually.39 They

travel primarily to socialize, attend sporting or

cultural events, and go sightseeing; have a household income of over $34,000 (1985 dollars, over

$47,000 in 1991 dollars), and an average auto

ownership of 1.8 autos per household; prefer

package tours and economy vacations and are

relatively averse to planning their own vacations;

are more likely to be female; and prefer group

travel to travel on their own. Most groups contain

I

u)

Many OTRB companies offer both fixed-route and

charter and tour service. These buses are part of such

a mixed fleet.

sizable numbers of widows or widowers. Studies

undertaken by the National Tour Association, Inc.

show that the average tour patrons are welleducated, middle to upper middle-level income

seniors living in metropolitan areas, with no

children residing at home.40 One tour operator,

with tours ranging from 1 to 30 days, describes

the day-tripper as typically less affluent than

those taking much longer tours.41

The primary market for escorted bus retail

tours includes persons ages 50 and above, a group

totaling about one-quarter of this country’s population.42 The American bus tour industry generated $13.8 billion worth of escorted tour business

in 1990, carrying more than 60 million passengers

on more than 1.5 million trips. Sixty percent of

these passengers were over the age of 64.43

From this limited statistical information, it can

be inferred that the median income of tour patrons

is likely to be much higher than that of fixed-route

passengers. However, both tour and fixed-route

38 Some Class I firms have been able to develop tour operations into a major revenue provider despite higher Cost s~ctures.

39 Lawrence F. Curmingham, ‘Proftig Tour Patxons and Non-Patrons in Interehy Bus Passenger Markets,’ paper presented at the Annual

Meeting of the Transportation Research Board, Washington DC, January 1986.

~ National Tour Association, “NTA Today,” newsletter, 1991, pp. 7-9.

41 S. Burkett Milner, vice president/general manager, Capital Tours, hc., personal commtiatio~ June 4, 1992.

AZ Natio~ TOW Association, op. cit., footnote w, pp. 7-9.

AS James su~i, wastin~o~ DC Representative, National Tour Association personal communication, March 1992.
Over-the-Road Bus Industry and Accessible Service 59

patrons are more likely to be over 65 than

travelers on other modes of transportation. This

group will be a growing percentage of the

population in coming years. The Bureau of the

Census projects a growth in population in the 65

and over category, from 31 million in 1990 to

more than 65 million in 2050, rising from 12,5

percent to 22.9 percent of the overall population.

SERVICE TO RURAL AREAS

Among the six specific areas the ADA directs

OTA to analyze is: “The impact of accessibility

requirements on the continuation of over-the-road

bus service, with particular consideration of the

impact of such requirements on such service to

rural communities. ”44 

The OTRB is often the only public carrier

option for the resident of a rural area or small

town.45 The approximately 6,000 U.S. communities served in 1992 by fixed-route bus service are

only one-half as many as those reached in 1982,

yet far more than the 477 served by air carriers or

the 498 linked by Amtrak. Indeed, over 30 percent

of fixed-route passengers describe their home

community as rural, a far greater percentage than

for either air or rail travel.% (See figure 2-7.)

These riders have been affected by the loss of

rural services. One survey estimated that 83

percent of the communities that lost bus service

after deregulation had no other means of public

intercity transportation.47

Figure 2-7—lntercity Passenger Travel, by

Travelers’ Area of Residence

100”/0 r “ ‘-- ‘- - ‘- ‘-

1

800/o -

I

3

~ 600/0 ‘

z

E

a)

2 40 ”/0

:

20%

0%

Airplane Bus Train

m Nonmetropolitan Statistical Area”

~ Metropolitan Statistical Area c 1 million

~ Metropolitan Statistical Area >1 million

● Metropolitan Statistical Areas are defined as a county or group of

counties that include: 1 ) a city of 50,000 or more residents, or 2) an

urbanized area of at least 50,000 people that is part of a county or

counties with at least 100,000 total residents.

SOURCE: Robert R. Nathan Associates, Inc., federal Subsidies for

Passenger Transportation, 1960-1988: Winners, Losers, and lmplications for the Future (Washington, DC: May 1989), p. 18.

Meanwhile, the rural population of the United

States has declined, from 49 percent in 1920 to 27

percent in 1990.48 (For further characteristics of

44 Section 30.5(1))(6) of tie ~A

45 Robefl R. Nati Associates, Inc., Federal Subsidies for Passenger Transportan”on, ]960-1988: Winners, hsers, ati Imp/icaliOnsfOr

the Furure (Washington, DC: May 1989), p. 17.

46 A smey by Greyhound pl~ed tie figure at 20.4 percent, while a su~ey conducted by the Bureau Of the CeIISUS ti 1977 found MI over

30 percent of bus riders came from rural areas. Although it is over 16 years old, the census survey still provides the most accurate demographic

breakdown of modal ndership. Ibid., p. 17.

47 Paul Shultz, “In the Gateway of Commerce: The Impact of Deregulation on Intercity Transit Service, ” Community Transportation

Reporter, vol. 5, No. 8, September 1987, p. 8.

48 U.S. Dcp~ent of Commerce, Bureau of the Census, ‘Summary: Number of Inhabitants for 1980,” PC 80- l-Al (WashingtorA DC: U.S.

Government Printing Office, 1980), p. 1-335; U.S. Department of Commerce, Bureau of the Census, 1990 press release, CB 91-344, December

1991; and OTA analysis. The U.S. census defines rural areas as those that are not urbzq i.e., 1) central cities and their immediate surroundings,

with a combined population of at least 50,000, and 2) towns outside of these areas with a population of at least 2,500. The Office of Management

and Budget defines populations on the basis of metropolitan and nonmetropolitan areas (see table 2-2). U.S. Congress, Office of Technology

Assessment, Defining ‘ ‘Rural’ Areas :Impact on Health Care Policy andResearch (Washington DC: U.S. Government Printing Office, 1989),

pp. 5-7.
60 0ver-the-Road Bus Access

Table 2-2—Selected Characteristics of Metropolitan and Nonmetropolitan Populationsa

Metro Non metro

Total population. . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Population density per square mile. . . . . . . . . . . . .

Median age. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Percent of population under age 18.. . . . . . . . . . . .

Percent of population age 65 and over. . . . . . . . . .

Median family income. . . . . . . . . . . . . . . . . . . . . . . ,

Percent with family incomes below poverty level. .

Unemployment rate. . . . . . . . . . . . . . . . . . . . . . . . . .

Median years of education completed. . . . . . . . . . .

187,072,000

328

30.0

27.8%

10.7Y0

$33,131

12.5%

6.9%

11.6

56,324,000

19

30.2

29.4%

13.0%

$24,397

16.9?4.

8.4%

10.9

a Based on office of Management and Budget definitions: Metropolitan Statistical Areas (MSAs) are counties or groups of

counties that have either a city of 50,000 or more people or an urbanized area that has at least 50,000 people located in a

county or group of counties of at least 100,000 population. Counties that do not have central cities can be counted as MSAs

if they have other characteristics of metropolitan areas such as significant commuting to other counties or high population

density. Nonmetropolitan populations reside in all other counties.

SOURCE:U.S. Congress, Office of Technology Assessment, Health Care in Rural America, OTA-H-434 (Washington, DC: U.S.

Government Printing Office, September 1990), p. 40.

metropolitan and nonmetropolitan populations,

see table 2-2.) For example, Iowa, with an

extremely large rural population of 39 percent,49

has a higher percentage of the elderly than all but

three States, two of which, Florida and Arizona,

are retirement havens.50 This demographic picture appears to make rural America a good fit for

the fixed-route bus market, whose passengers

tend to be disproportionately made up of the poor,

young, and elderly.

Effects of Deregulation on Rural Service

The passage of the BRRA resulted in significant point abandonment, with service lost to

2,154 communities in the first year alone.51 This

abandonment did not necessarily eliminate service to entire rural areas; often just unprofitable

stops were dropped. Further, many bus operations

shifted to the Interstate Highway System, eliminating stops along parallel local routes using

older U.S. and State highways. This meant that,

for individuals able to travel a short distance

outside their home town, intercity service was

sometimes still available.52 How much of the

reduction in service points was due to deregulation is a matter of debate. Quite possibly, economic trends would have eventually forced the

shut down of service to some communities.53

Small towns bore the brunt of deregulation

because of their lack of ridership and locations off

of main routes. In Iowa, 70 percent of the points

that lost service served fewer than 10 passengers

per month. 54 Figures such as these did not

translate into profits for the intercity carriers,

especially when the bus had to travel off the

beaten path to pick up only a few riders. In a

@ U.S. Dep~ent of Commerce, Bureau of the census, ‘‘Percent Urban and Rural Population, 1990 and 1980, ” The Census and You, vol.

27, No. 1 (Washington DC: U.S. Government Printing OffIce, January, 1992).

50 os~ Gray Davidson, Broken Heartla~: The Rise of Americans Rural Ghetto (New York NY: The Fr= press. 1990)} P. 63.

51 Ecosome~cs, Inc., op. cit., footiote 16, p. 17.

52 All ~om~ties in~on~ tit lost Semicehad ~o~er ~temity bus stop ~tween9 md 21 miles away. In Iowa, 37 percent of ticket agents

in communities that lost semice reported that the nearest stop was over 20 miles away. John Due et al., Transportation Service to Small

Communities: Effecfs of Deregulation (Ames, IA: Iowa State University Press, 1990), p. 86.

53 Meyer and Oster, op. cit., footnote 9, p. 219.

54 Ma.ry KihI, “TheImpact of Bus Deregulation on Small Towns, ” Tratqwrtation Research Record1012 (Washington DC: Transportation

Research Board, National Research Council, 1985), as cited in Eric Hansen et al., The Berrefils of Zntercity Bus Service (Milwaukee, WI: The

School of Architecture and Urban PIarming, The University of Wisconsin-Milwaukee, October 1986), p. A9.
Over-the-Road Bus Industry and Accessible Service I 61

Figure 2-8—North Dakota Fixed-Route Service,

1979 and 1990

●

✎ = Minot *.*. * .* .. ** .

. = * .“ 1’ d ‘* ! Grand *-.**

Williston {

.

-% L

1

Forks

● .’

1979

1991

● = Service points

SOURCE: U.S. General Accounting Office, Surface Transportation.’

Availability of Intercity Bus Service Continues to Decline (Washington,

DC: June 1992), pp. 21-22.

sample of 12 States, of the communities that lost

service in the first 2 years of deregulation, 82

percent had populations under 2,500 and 94

percent had populations of less than 10,000.55

When given the option, the major carriers concentrated on the most profitable routes, those between large central cities. Unlike the Airline

Deregulation Act of 1978, which provided subsidies for continued air service to small communiFigure 2-9-Fixed-Route Service From Columbus

to Grand Island, Nebraska

r

‘L - - . .

-\.

L.

Columbus 2 hrs ‘

, 1.5 hrs~ P -—–->o/ \,Omaha

.’

b, 1, ‘ 1.15 hrs

I

b- I J-—--- ●

Grand Island Z i’s hrs Lin~o’@

(

~.–~

‘ -- Old route — New route

SOURCE: Russell’s Guides, Inc., Russell's Official National Motorcoach

Guide (Spokane, WA: Friendship Publications, Inc., October 1982 and

November 1991), cited in U.S. General Accounting Office, Surface

Transportation: Availability of Intercity Bus Service Continues to

Decline (Washington, DC: June 1992), p. 25.

ties, the BRRA included no such provision for

communities left without bus service.

For example, the two maps in figure 2-8

compare freed-route service in North Dakota in

1979, when 129 locations were served, and in

1991, when 68 locations received service.56 All

communities south of Interstate 94 (I-94) lost

service during that period. Bus service along the

I-94 corridor still connects Fargo, in the east,

through Jamestown and Bismark to the Montana

border. However, I-94 now serves 17 intervening

points compared to 34 in 1979. Service was also

discontinued for points along the route linking

Jamestown on I-94 and Minot, and the route

between Minot and Williston. Williston, the

Williams County seat, and eight other communities in that part of western North Dakota, now

have no bus service.

Unlike Williston, Jamestown is still linked to

Minot by bus, but the Jamestown passenger must

now go through Bismark, adding approximately

25 percent to the distance traveled. Similarly,

figure 2-9 demonstrates why, in 1992, travel by

55 ~~~ton@p.r ~~ C. ~~ am, The jmp=ctf of Regulat~q R.@or~ on ~n~ercify Bus se~ice (Bloomi~gto~, IN: Indiana u?l~VtTSiQ,

September 1984.

56 U.S. Gene~ Accounting Office, Suflace Transportation: A~*ailability of Intercity Bus Service Continues to Decline (w~~@o% Dc:

June 1992), pp. 21-22.
62 0ver-the-Road Bus Access

bus within Nebraska between Columbus and

Grand Island is less convenient than it was 5 years

earlier and less attractive as a travel option.57

Formerly a 1 l/2-hour trip, the journey now takes

6 1/2 hours.

Figure 2-10 illustrates how areas served by

intercity bus routes in Illinois correspond to

Interstate highway routes.58 Communities in 51

Illinois counties have fixed-route service; 39 of

those counties are intersected by Interstate highways. Communities in the remaining 50 counties

have no intercity bus service; only 13 of those

counties are intersected by Interstate highways.

Rural Bus Stops

Besides differing ridership levels, the most

signifilcant distinction between rural and urban

intercity service is in the facilities servicing the

bus. In a large city center, a traveler goes to a

full-service terminal, usually with its identity

prominently displayed outside. In small communities, buses often stop at stations, where servicing the bus is not the primary business function.

Because businesses usually either break even or

lose money as ticket agents, they view the

enterprise more as a public service operation than

a profitable venture.59 Thus, it can be difficult for

carriers to find business owners willing to operate

stations and publicize their service. As a result,

while stations may be known to town residents,

other potential riders do not always know where

the bus stops or where they can purchase a

ticket. 60

Figure 2-10-Fixed-Route Service in Illinois and the

Interstate Highway System

——

“\

F!orwT-l

Iapolls

WH---i3 w

vTo

——

SOURCE:

Guide (Spokane, WA: Friendship Publications, Inc., November 1991),

cited in U.S. General Accounting Office, Surface Transportation:

Availability of Intercity Bus Service Continues to Decline (Washington,

DC: June 1992), p. 24.

Memphis

Served by intercity bus

No intercity bus service

Interstate highway

Russell’s Guides, Inc.., Russell’s Official National Motorcoach

37 Ibid., p. 25.

58 Ibid., p. 24.

59 ~dyIS~c-, &=ctor of Smte Government Aff~s, Greyho~d Lines kc., perso~ Cc)tnmuniCritiOn, Aug. 13, 1991.

60 In order t. ~lcviate MS problem, Michigq North Carol@ and Oregon have established programs to place signs iden@@ bus stoPs.
Reliance on Service

The extent to which rural areas depend on

fixed-route passenger and package service is

difficult to determine. Studies of rural communities that have lost service have concluded that,

while on the whole the adverse consequences to

towns were usually not severe, some individual

businesses and people who had used the bus

endured significant hardship.61

Dependence on Passenger Service

With the exception of the private automobile,

no readily available alternative exists for travel

along many passenger bus routes. Therefore, the

potential adverse effect of abandonment can be

very high in rural communities. But in any

analysis, the perceived need for the intercity bus

must be separated from the actual demand for the

service.62

Community Dependence—Studies have consistently shown that route abandonment has had

minimal effects on rural communities in general.

A study of 15 States facing substantial route

discontinuance after the passage of the BRRA

found no formal protests from communities

losing service,63 Whether this was due to indifference or because of ignorance of how best to

protest is unclear. In the few States where

significant protest has occurred, a proposed abandonment has often been stalled, or the route has

been partially subsidized by government funds. In

Nebraska, the work of a‘ ‘Save the Bus’ committee eventually led to State funding of a rural route.

Citizens were able to demonstrate that bus service

Over-the-Road Bus Industry and Accessible Service I 63

was in the public interest and that a substantial

portion of the community wanted to maintain the

service. The route from Omaha to Rapid City,

South Dakota, was maintained by Arrow and

Black Hills Stage Lines for several years after a

Federal Transit Authority study recommended

State subsidies. However, ridership continued to

decline, and the bus company stopped operation

of the route on June 1, 1991.@

Because most residents of rural areas never use

bus service, its loss has little impact on their lives.

The business community is seldom affected

significantly, either, as most fixed-route bus trips

are taken for purposes of visiting friends or

relatives, and not for shopping or business trips.65

A nationwide study of service to rural areas

concluded that ‘‘. . . most intercity trips taken by

rural residents . . . are not critical to their day-today needs [and] do not materially relate to the

basic economic functions of rural areas, ”66 

Individual Dependence—For individuals dependent on bus service, however, community

abandonment often means increased isolation. In

the Wisconsin study, 20 percent of bus riders from

small towns said they would not be able to make

a similar trip if bus service were unavailable.

Among the elderly, dependence on the bus is even

more striking: 48 percent of those over 65 said

they would not be able to make the trip if bus

service were unavailable.67

However, community abandonment does not

seem to have occurred disproportionately in

towns with numerous poor and elderly residents.

c1 The wisco~fi Dep~cnt of Transportation conducted a study on the benefits of intercity bus service, which included an @ysis of

towns that have lost service. Similar studies have been conducted in Iowa and other States. Hansen et al., op. cit., footnote 54.

62 Due et al., op. cit., footnote 52, p. 88.

63 Ibid., p. 89.

ti U.S. Department of Transportation Comprehensive Study cflnterciry Bus Service in Nebrasb (Washington, DC: March 1988); and

Frederic D. Fravel, Ecosornetrics, Inc., personal cornmunicatiom Feb. 16, 1993.

65 Due et aI., op. cit., footnote 52, p. 85.

66 JOhII Weus et a]., U.S. Dep~ent of Tr~po~tio~ Office of the Assistant Secretary for Policy and International AfftiS, ~nter-cify~u$,

Rail, and Air Servicefor Residents of Rural Areas, 1980 (Washingto~ DC: U.S. Government printing Office, 1980), cited in Hansen et al.,

op. cit., footnote 54, p. Al.

CT Hansen et al., op. cit., footnote 54, p. B2.

. —

Over-the-Road Bus Industry and Accessible Service 65

Because the elderly and poor use the bus at a high

rate, they often provide sufficient ridership to

justify continuation of bus service in places where

their numbers are large. In fact, communities that

retained service after deregulation had lower per

capita incomes and higher percentages of elderly

citizens than small towns where service was

discontinued. 68

Dependence on Package Service

Bus package delivery finds its largest market in

rural areas, serving small businesses, farmers, or

hospitals. However, with the expansion of next-daydelivery services, the importance of bus package

delivery has diminished greatly. Greyhound saw

a significant drop in its revenue from package

service as these companies expanded; Federal

Express, for example, now delivers to innumerable locations.@

Those who use bus package service find it

attractive because it often supplies the only

available same-day delivery of important perishable items, such as blood and agricultural products,

cargoes not handled by carriers such as Federal

Express or United Parcel Service (UPS). OTRBs

have less stringent weight and size restrictions

than other services, allowing heavy packages,

such as auto parts, to be shipped in a timely

fashion. Although package air service is becoming increasingly available to small communities,

its cost compared to bus freight shipment makes

the latter more appealing to some businesses.70

Individuals who had relied on package service in

areas where bus service has been eliminated have

been forced to adjust. For example, when bus

service was curtailed in Bishop, California-a

Most passengers travel on intercity, fixed-route

OTRBs for vacations, visits to relatives, and

shopping trips.

town of 3,500-blood had to be rushed from Reno

by the California and Nevada State highway

patrols. 71 Businesses that need to transport larger

or different objects than UPS handles now rely on

personal delivery or travel to the nearest intercity

bus station to ship their packages.

Given the low volume of packages shipped by

intercity bus in most communities, the adverse

economic effects of service discontinuance are

not widespread. For example, 81 percent of the

routes abandoned in Iowa handled fewer than 50

packages a month.72 In most of the small towns

that lost bus service following deregulation, the

few small businesses that used bus package

service have switched to other alternatives, primarily UPS, and the towns’ general economic

health was rarely affected.73

68 Meyer and Os[er, Op. ClI., fOOtUOte 9. p.

 219

.

69 Randy 15a.acS, director of State Government Affairs, Greyhound Lines Inc., personal COmmUni@iOG Sept. 17, 1991.

70 For ~x~ple, ~ be case of a l~pomd pz~ge Shipped from Wausau, WI to Rhinelander, WI, a town of under lo,o~ residents, United

Parcel Service would not take the package because of weight restrictions; sending it by Federal Express would cost $146 more than shipping

it by bus. Hansen et aI,, op. cit., footnote 54, p. 43.

71 JohII E. Gallagher, “Where There’s No Bus, There’s No Exit,” Time, Mar. 26, 1990, p. 59.

72 Kl~, op, cit., fOOtllOtc 54, P ‘9.

73 Hmen et ~., op. Cit., fOO~Ote .54, P. 50
66 0ver-the-Road Bus Access

Government Assistance to Rural Transit

Federal and State Governments offer financial

assistance for rural transit services, which are

generally provided by vehicles other than OTRBs.

The principal instrument for this assistance is

Section 18 of the Federal Transit Act, successor

to the Urban Mass Transportation Act of 1964.

●

●

●

Section 18 authorizes the Secretary of Transportation, through the Federal Transit Administration (FTA), to provide funds to each State

to be used for public transportation projects

in nonurbanized areas .74 The funds may be

used for planning, capital, and operating

assistance by State and local government

bodies, nonprofit organizations, operators of

public transportation services, and others.

The Section 18 program aims to facilitate

rural residents’ access to health care, education, employment, public services, and other

activities through improvement of public

transportation systems in rural and small

urban areas. It also seeks to encourage as

much as possible the participation of private

transportation providers in rural and small

town transportation service.

State agencies receive additional funds under

Section 16(b)(2) of the 1978 Surface Transportation Assistance Act. These FTA funds

assist private nonprofit organizations to

purchase vehicles and equipment to transport the elderly and individuals with disabilities in both rural and urbanized areas.

Transportation providers serving primarily

rural areas may receive both Section 16(b)(2)

and Section 18 funds from their State agenT4 states rwelve funds based on their Percenbge of the Nation’s total rural population usfig the census definition of ~.

75 The Dep~~ent of He~fi and Human Services provides $1 billion for transportation. However, that money Often is Spread out over a

variety of local agencies, and coordinating resources among transportation providers is a major stumbling block in rural tm.nsportation. U.S.

Department of Agriculture, Reconnecting Rural America: Report on Rural lnfercify Regional Transportation (Washington DC: U.S.

Government Printing Office, July 1989), p. 2.

76 Conmul~ty Transportation Association of Americ~ A Profile of the Sec[ion 18 program (was~to~ DC: 19~), P. 4.

77 Due et ~1,, op. ~lt,, fwtnote 52, p. 85. [n a 1984 Smey, tie majofi~ of fo~er interci~ bus ticket agents in Iowa recaltcd that tb.KXqUarterS

of their passengers traveled less than 100 miles, usually within the State.

76 Community T~portation Association of Americ% op. cit., foo~ote 76> P 4.

Package express service, which delivers large,

perishable, or other special cargo, can generate

significant revenue for the bus company.

cies; some may also receive funds from the

U.S. Department of Health and Human

Services to provide transportation for certain

disadvantaged individuals.75

Over one-quarter of all rural transit agencies

operate in more than one county, their vehicles

often traveling long distances over several counties on individual trips.76 A number of these buses

travel distances similar to those of the average

rural freed-route bus trip (estimated at 125 miles),

making some rural transit operations suitable

surrogates for discontinued bus service .77 Persons

who use wheeled mobility aids make up 7 percent

of all riders of Section 18 systems; 39 percent of

all passengers are over 65.78 Many vehicles

operated by FTA-supported agencies are liftequipped, enabling passengers with mobility

disabilities to travel more easily.
Over-the-Road Bus Industry and Accessible Service 67

1991 Amendments to Section 18

Section 18 was amended by the Intermodal

Surface Transportation Efficiency Act of 1991

(ISTEA),79 which added Subsection (i) to encourage the further involvement of the OTRB industry

in serving rural areas. Section 18(i) calls for each

State to spend no less than a fixed percent of its

apportionment for that purpose, unless the Governor certifies that the State’s intercity bus needs are

adequately met.80

●

●

Section 18(i) provides funds to support a set

of national objectives that: 1) connect nonurbanized areas to the larger regional or national

system of intercity bus service; 2) meet the

intercity travel needs of residents of nonurbanized areas; and 3) improve the infrastructure of the fixed-route network.

Eligible activities for funding under Section

18(i) include planning and marketing, capital grants for shelters, joint-use stops and

depots, operating grants through purchase-ofservices agreements, user-side subsidies and

demonstration projects, and coordination of

rural connections between small transit operations and fixed-route carriers .81 FTA draft

guidance specifies that capital assistance

may be used to purchase vehicles or vehiclerelated equipment such as wheelchair lifts

for use in intercity service. For vehiclerelated equipment required by the ADA, the

Federal share is 90 percent of its incremental

cost. For purposes of Section 18, charter and

sightseeing services are not eligible for FTA

assistance; commuter service is not included

in the definition of intercity service, but

package express is.

In connection with its June 1992 report on the

intercity bus industry, the U.S. General Accounting Office (GAO) identified 20 States with

intercity bus service programs ranging from

financial support for individual bus routes to

toll-free telephone numbers for route and schedule information.82 Seventeen of these States use

Federal funds, 14 also use State or local government funds, and 3 use only funds generated within

the State.83 While 30 States have no programs for

supporting fixed-route service, 43 States indicated to GAO that they expect to use the Section

18(i) set-aside moneys for improvement of intercity bus transportation.

Rural Connector Programs

As major freed-route carriers dropped rural

stops from their routes, community leaders and

industry sought ways to provide transportation to

potential riders in isolated areas. In 1987, Greyhound, with the cooperation of the Community

Transportation Association of America (CTAA)

and FTA, sought to link existing intercity routes

with public providers of rural transit by establishing the Rural Connector Program (RCP).84 As of

December 1991, 73 transit agencies serving over

850 communities in 20 States were participating

in RCP.85 Local transit systems took passengers

79 public Law 102-240.

go Five percent in fiscal yew 1992, 10 percent in fiscal year 1993, and 15 percent in fiscal year 1994 and thereafter. The fiscal Yc~ 1992

appropriation for Section 18 activities was $66.13 millio% the fiscal year 1993 appropriation is $90.83 million.

SI The IIUMimUm Federa sh~e is 80 percent of capital expenses and 50 pWCCIM Of Operating costs.

13Z U s, General Accounting Office, Op. Cit., footnote 56, PP. 3W1

83 Fouflwn of fie 20 States provide ope~ting subsidies, typically designed to m~nt~n pub[ic ~~po~tion services forrurld ad Small tOWn

residents. Six have vehicle programs whereby State-owned buses are leased to private operators to provide intercity bus service. Five offer

assistance for construction or remodeling of terminal facilities, particularly for intermodal transportation. Ten provide other types of rmistance

such as promotional materials, maps, signage, passenger sheltem, and tax credits on fuel expenditures.

84 Greyhound Lines invested approx~ately $5M,000 in RcP, with CTAA contributing $200,~. cTAA’s cost.~ were offset by ag~t from

ITA. U.S. Department of Transportation, Intercity Bus Feeder Project Program Analysis: FinaZ Report (Washington, DC: September 1990),

p. S-13.

85 U.S. General Accounting Office, op. cit., footnote 56, p. 4.
68 0ver-the-Road Bus Access

to and from intercity bus stops and acted as ticket

agents for Greyhound, selling intercity bus tickets

along with the regular transit service fee. Between

1987 and the beginning of the Greyhound strike

in 1990, the program allowed Greyhound to add

941 points to its fixed-route service.86 The strike

and the company’s subsequent bankruptcy filing,

however, placed the program on hold in all but a

few communities.

The greatest concern surrounding RCP was the

lack of ridership. 87 After almost 2 years of

operation, the program had generated 2,744 total

trips, with average ridership for individual transit

agencies ranging from O to 64 trips monthly .88

Local operators offered the following reasons for

the program’s inability to attract passengers: lack

of advertising funds made marketing difficult;

Greyhound marketing materials were ill-suited to

small community needs; and intercity coaches

often arrived during hours not covered by local

providers. In addition, many rural transit operators serve primarily human service agency clients,

and have limited abilities to serve the general

public. 89

Another reason for the program’s low ridership

was that Greyhound was unable to serve a portion

of the Section 18 operators’ clientele—

individuals with disabilities, In fact, Minnesota’s

State Department of Transportation declared that

it would not support the participation of its

Section 18 operators in RCP in view of the

inaccessibility of Greyhound’s OTRBS.

90

OTRB ACCESSIBILITY PRIOR TO THE

AMERICANS WITH DISABILITIES ACT

Legislative Precedents, 1970 to 1990

Twenty years of legislation, rulemaking, and

court decisions involving access to publicly

funded transportation preceded the 1990 enactment of the ADA.91 Milestones during that time

included:

●

●

●

In 1970, the Urban Mass Transportation

Assistance Act established as national policy that individuals with disabilities have

equal right of access to publicly assisted

mass transportation facilities and services,

and that planning and design of such facilities and services should assure that right. It

authorized the use of up to 3.5 percent of

total mass transit appropriations for improved access. But suits brought by individuals with disabilities claiming that public

transit authorities must now purchase accessible vehicles were dismissed by the courts.

In 1973, Section 504 of the Rehabilitation

Act became law, stating that: “No otherwise

qualified handicapped individual . . . shall,

solely by reason of his handicap, be excluded from the participation in, be denied

the benefits of, or be subjected to discrimination under any program or activity receiving

Federal financial assistance. ”92

In 1976, the Urban Mass Transportation

Administration (UMTA, now FTA) of DOT

adopted regulations requiring public transit

$6 Ec050me~cs, IIIC.$ op. cit., foot(lotc 16, P. 19

87 ~ 1987, he s~te of M1c~gm fitituted i~ Om comector pro~~ wi~ ~A suppofl, provid~g f~ds LO IOCd tsansit agencies tO conduct

the service. By the spring of 1991, Michigan’s RCP had attracted more ndership than Greyhound’s national version. Once ITA funding ended,

however, even these ridership levels could not justify continuance of the program, which continued to lose money.

88 us, Dep~ent of Transportation, op. cit., footnote 84, p. s-1 1.

8!) Isaacs, op. cit., foomote 59.

90 David Rap~el, ~xecutlve dfiector, Comm@ly T’r~pofiation Association of Americ% pe~o~ comrm.micatlon, July 18, 1991; ~d

Randy Isaacs, Isaacs & Associates, personal communication, Oct. 6, 1992.

~1 The following materd is based on Paul Stephen Dempsey, ‘‘The Civil Rights of the Handicapped in Transportation: The Americans With

Disabilities Act and Related Legislation, ’ Transportation Law Journal, vol. 19, No. 2, 1991, pp. 314-317,

w public hw 93.112, approved ScpI. 26, 1973, 29 USC 794.
.

Over-the-Road Bus Industry and Accessible Service I 69

agencies to make special efforts to accommodate individuals with disabilities, but

without indicating how that should be done.

Some agencies responded by purchasing

Lift-equipped buses and others established

dial-a-ride or paratransit services.93

In 1978, the then-Department of Health,

Education, and Welfare issued lead agency

guidelines requiring that individuals with

disabilities be “mainstreamed’ into Federal

programs. Retrofitting of buses and subway

systems was required, with the provision of

specialized services allowed to supplement

or substitute for accessibility. In 1979, UMTA

issued rules requiring that all new fixedroute buses be made accessible to individuals with disabilities, including those using

wheelchairs. The rule required that 50 percent of peak-hour buses be accessible within

3 years.

In 1981, however, the courts held that such

specific requirements were beyond the scope

of DOT authority. Congress then enacted the

Surface Transportation Assistance Act (STA)

of 1982, with provisions requiring DOT to

establish minimum service criteria for individuls with disabilities, but requiring neither equal access nor comparable service.

In 1986, UMTA issued final rules pursuant

to the STA, giving transit agencies three

options: installing lifts on buses, establishing a paratransit system, or establishing a

mixed system of accessible buses and paratransit. In rulings on suits brought against the

mixed system approach, the courts held that

mixed systems were legal since no right for

equal access existed at that time, either

legislatively or constitutionally.

● In 1990, however, equal access became the

law with passage of the Americans with

Disabilities Act, which for the first time

addressed private entities providing public

transportation.

I Current Status of Accessible Service

Prior to passage of the ADA, the statutes,

regulations, and court decisions noted above

required federally assisted public transit systems

to provide some accessible transit buses and vans,

and by 1990 considerable progress had been

made. However, examples of accessible OTRBs

were few. The first lift-equipped OTRBs appeared in 1985 in Canada under governmentsponsored demonstration programs. In 1986,

Massachusetts initiated its own program providing publicly financed, lift-equipped OTRBs to a

number of private operators within the State for

freed-route, commuter, and other services, In

1987, two public transit agencies, the Denver

Regional Transportation District and the Golden

Gate Bridge, Highway and Transportation District of San Rafael, California, began operating a

total of 39 lift-equipped OTRBs. (See chapter 3

for a discussion of the Denver RTD project.)

Privately Operated Service

As of late-1992, OTA had identified 26 bus

operators nationwide who ran some 350 liftequipped OTRBs. At that time, these 26, plus

other operators without lift-equipped buses, had

an additional 100 accessible buses on order. Of

the 26 bus operators, 7 are public transit authorities. The remaining 19 are private companies, but,

with two exceptions, they operate their accessible

93 pMatrmSit, ~lsO fomcrly ~efemed t. ~~ di~.a-ride, is ~~~actcrimd by flexjb]e routes and schedules, curb-to-curb or door-to-door pickup

and dropoff points, requested in advance by a user eligible for the service. Under the DOT Interim Regulations (issued pursuant to Sec.

306(a)(2)(A) of the ADA), paratransit “. means comparable transportation service required by the ADA for individuals with disabilities who

are unable to use fixed-route transportation systems, 56 Federal Register 45624 (Sept. 6, 1991).
70 0ver-the-Road Bus Access

Greyhound cares about our customers If you would

like assistance while traveling because of a disability).

please ask any Greyhound employee for assistance.

. 

En Greyhound. m.~m es su mamcnte mwxmmle

SI nemsita ayuda debkkr a algunsr MCfWIM. dicIte aswmcur de cwfquier ctnplcak) dC

GrAluu&. ,“**

A few travel agents and tour operators have

persons with disabilities as their primary client

base.96 Travel agents and tour operators specializing in travel for individuals with disabilities claim

that arranging accessible motorcoach tours in the

United States is next to impossible, although a

few small bus companies may have accessible

vehicles for highly localized tours, and some tour

destinations are thoroughly accessible, most notably Disney World. (See chapter 3 for a discussion

of the charter and tour market for individuals with

disabilities.)

A sign at a Greyhound terminal in February 1993

indicates the company’s willingness to serve persons

with disabilities.

OTRBs under contract to public bodies.94 (One of

the exceptions is a tour operator whose single

lift-equipped OTRB was purchased and operates

without public financial assistance. See box 2-G.)

Fewer than 5 of the 26 operators are principally

providers of traditional freed-route service; the

others provide essentially commuter, airport and

special services, and charter and tour services.

Approximately 40 companies list themselves

in the 1992 Motorcoach Marketer as providers of

accessible tours to persons with disabilities.

However, OTA has been able to confirm only six

of these as having lift-equipped OTRBs.95 The

rest provide accessible service with minibuses,

vans, school buses, and other vehicles.

PRESENT DOT REGULATIONS

DOT regulations require privately operated

OTRBs to provide handrails, stanchions, increased lighting, slip-resistant flooring, contrasting edge surfaces, and a door width of 30 inches

where possible and in no cases less than 27

inches. The ADA also called on the Secretary of

Transportation to issue interim regulations 1 year

after enactment, so that each private entity using

an OTRB provides access for persons with

disabilities .97 These regulations could not require

structural changes in OTRBs or the purchase of

boarding assistance devices, and remain effective

until supplanted by the Secretary’s final regulations.98

The DOT interim regulations require private

entities operating OTRBs to assist individuals

with disabilities in boarding and disembarking,

~ ~ ~~tion t. the private bus companies participating in the Massachusetts demonstratio~ and the two public agencies, the Denver

Regional Transportation District and Golden Gate, the following private operators provide accessible OTRB semice, all under contract to public

agencies: California— Laidlaw Transit, Antelope Bus Co., Inc., Gray Line Tours, Goodall’s Charter Bus Service, Inc., All-West Coach Lines,

Amtravel; Comecticut-Post Road Stages; and New York-Central New York Coach Lines, which owns a lift-equipped OTRB but has never

operated it. A public transit authority operating its own accessible OTRBS is Dallas Area Rapid Transit. Houston MefropoMa.nTransit Authority

ordered 40 accessible OTRBS in early 1992. This list may not be all-inclusive.

95 Brush HiU, Central New York Coach Lines, Goodall’s Charter Bus Service, Inc., H&L Bloom, Inc., Post Road Stig% md peter pa.

96 *$A &avel agency i5 a ~e~l mem&[ who ,@ls &avel to me co~umer. A tour operator is a Wholeder Who puts tours together, then Se~S

them to a travel agency. Many travel agencies are also tour operators.” Helen Hecker, Directory of Travel Agencies for the Disabled

(M.ncouver, WA: Twin Peaks Press, 1991), p. 2. Some foreign travelers with disabilities who are interested in touring the United States by

motorcoach assume accessible coaches are available, and foreign travel agents making inquiries on their behalf are often astounded to fmd

otherwise. Yvonne Nau, Nautilus Tours, Inc., Tarzana, CA, personal communication, Jan. 28, 1992.

97 fiblicly oWmt~ Oms(orpfivately o~ed Oms operated~der con~ct to apubfic e@r) must meet all of the service requirements

applying to public entities, and all of the vehicle accessibility requirements that apply to transit buses under Part 38 of DOT’s regulations.

9856 Federal Register 45624 (Sept. 6, 1991).
Over-the-Road Bus Industry and Accessible Service I 71

Box 2-G—An Accessible Tour Bus: Evergreen Travel Service, Inc.

Evergreen Travel Service, Inc., of Lynnwood, Washington, has been operating tours since 1960. After 20

years of conducting tours all over the world for persons with disabilities, proprietors Betty Hoffman and her son

Jack decided they needed their own bus. The Hoffmans bought a used bus, equipped it with a Crow River lift,

rebuilt the restroom to make it accessible, and installed 16 tie-down positions. Its current configuration

accommodates 12 tie-downs. The Crow River is an external lift, takes up no baggage space, and is located in front

of the rear wheels and immediately in front of the restroom. The restroom is equipped with a 40-inch-wide door

facing the aisle.

Jack Hoffman says the bus was used for only 1 year before the insurer discovered it was being used to

transport a number of passengers with disabilities and raised the insurance rates to $3,000 per month. Hoffman

claims he was told he could pay normal rates only if he were to tear out the lift. Instead, he parked the bus and

left it unused for 7 years. Meanwhile, he unsuccessfully tried to secure coverage through the State of Washington

high-risk pool. He was later placed in a high-risk pool in San Francisco where he could have obtained coverage

for $900 per month, but that figure was not economically feasible. Only in early 1992 was the Evergreen bus put

back into operation, after being insured at $525 per month through a pooling arrangement with another eight buses

operated by a family company in the Seattle area. Hoffman believes that rate to be about $125 per month above

the going rate for OTRBs in Washington State.l

In more than 30 years, Evergreen has conducted tours to more than 100 countries for individuals with a

variety of mobility and sensory disabilities. In some countries, accessible coaches can be arranged easily. Britain,

Scandinavia, several other countries in Western Europe, and Israel are favorite destinations where accessibility

presents few major problems. In other countries, including Tibet, Nepal, India, and Burma, accessible buses do

not yet exist, nor are facilities accessible. In such cases, lifting and carrying are the only options. Hoffman has

conducted six tours to China and in 1991 took a group of 23 individuals with disabilities there. He tells the story

of getting persons who use wheeled mobility aids or scooters to the top of the Great Wall of China via routes

unknown to his Chinese guides, using ramps initially built for supply horses and encountering only five steps

along the way.

1 It is I-Ioffm’s belief that insuranc e company concerns are misplaced. Most suits brought by individuals with

disabilities are dismissed, he claims, with the court finding that they are already disabled, and proof of further disability as a

result of an accident di.fflcult to establish. Suits brought by formerly able-bodied people disabled in accidents, however, are

frequently found in favor of the passengev it is in these cases that insurance companies end up paying claims. Hoffman believes

that insurance companies should not focus on a company’s ability to transport disabled passengers but on its safety record.

including moving to and from the bus seat. ment, size permitting. If this is not possible, they

Carrying is a disfavored method of assistance, but

since the purchase of boarding assistance devices

cannot be required, there may be times when

carrying is the only available means of access. In

such cases, it is the responsibility of the entity to

ensure that personnel providing boarding assistance, especially by carrying or direct physical aid,

are trained to do so safely and appropriately.

Wheelchairs and other mobility aids and assistive devices may be accommodated in the areas

for personal effects in the passenger compartare to be stored in the baggage compartment of the

bus. At any stop, a person with a wheelchair or

other assistive device would have the device

loaded before other items at the same stop,

although luggage already on the bus could not be

“bumped” to accommodate the device.

The OTRB operator may require up to 48 hours

advance notice, but only if boarding assistance is

necessary. “While advance notice requirements

are generally undesirable, this appears to be a case

in which a needed accommodation may be able to
72 I Over-the-Road Bus Access

be provided successfully only if the transportation

provider knows in advance that some extra

staffing is needed to accomplish it. ’ ’99 If advance

notice is not provided, the entity still has the

obligation to offer boarding assistance, if it can be

done with available staff.

One year after submission of the OTA study,

DOT must issue final regulations specifying the

level of service required on accessible intercity

coaches for individuals with disabilities. These

regulations will be enforced by a governmental

framework divided among many different agencies. While modes such as air and rail have entire

administrations within DOT geared to their oversight, private OTRB companies find regulatory

authority splintered not only within DOT but

throughout the State and Federal Governments

(see app. B.) Within this complex regulatory

environment, DOT must determine how best to

administer and enforce accessibility regulations.

9956 Federal Register 45756 (Sept. 6, 1991).
I

Demand for

Accessible

Over-the-Road

Bus Service 3

FINDINGS

●

●

●

●

●

The number of persons with disabilities is very difficult to

estimate. Data-collection methods differ, and in many cases

the data conflict. In addition, the definition of ‘disability”

varies by source.

The prevalence of disabilities correlates with advanced age.

U.S. Bureau of the Census projections indicate that the

65-plus age cohort is growing rapidly, from 12.5 percent of

the total population in 1990 to as much as 25 percent by

2050. Thus, it is likely that the proportion of persons with

disabilities will increase as well.

The profile of over-the-road bus (OTRB) ridership resembles in key ways the profile of the population of persons

with disabilities. The similarities include age, gender, and

income characteristics.

A handful of programs and demonstration projects have

offered accessible OTRB service. In general, the use of

accessibility equipment in these projects has been very low.

However, since the projects covered limited areas with

infrequent service, and since several are new and still

building ridership, it is not possible to generalize from their

ridership levels to total ridership in a nationwide, completely accessible OTRB system.

To calculate the level of OTRB ridership (for both

fixed-route and charter and tour service) by persons with

disabilities, the Office of Technology Assessment (OTA)

extrapolates from OTRB usage for the entire U.S. population. This methodology estimates the annual trips by

persons using wheelchairs at 0.5 to 0.6 percent of the current

annual trips by persons without disabilities; the annual trips

73
74 10ver-the-Road Bus Access

●

by persons using any type of mobility

technology device comprise 1.2 percent; the

annual trips by persons with hearing impairments come to 5.6 percent (annual trips by

those using hearing technology devices total

1.5 percent); annual trips by persons who are

legally blind amount to 0.4 percent; annual

trips by persons who are sight impaired

comprise 2.0 percent; and annual trips by

persons using vision technology devices

total 0.1 percent. Data on the number of

persons with cognitive impairments are too

vague and inadequate to predict the number

of such persons who require assistance in

riding OTRBs.

OTA cautions that these calculations of

potential demand are only estimates, and

that projecting demand for accessible service that has not yet been offered is next to

impossible.

BACKGROUND

Section 305 of the Americans with Disabilities

Act (ADA) requires that OTA study “. . . the

anticipated demand by individuals with disabilities for accessible over-the-road buses and accessible over-the-road bus service. ”1 The law asks

OTA to develop figures about how many persons

with disabilities are likely to use accessible

OTRBs; it does not state that the results of OTA’s

study will affect the requirement to make OTRBs

accessible.

This chapter presents OTA’s analysis of the

demand for accessible service in three sections: 1)

a discussion of persons with disabilities, their

characteristics, and their numbers; 2) a description of demonstration projects that have attempted to provide accessible OTRB service to

persons with disabilities; and 3) an explanation of

OTA methodology and the resulting demand

projections.

PERSONS WITH

UNITED STATES

DISABILITIES

Accessible OTRB service must

IN THE

accommodate

a population of persons with various types and

degrees of disabilities. The following section

includes estimates of the occurrence of various

types of disabilities, the characteristics of some of

the more common types of disabilities, demographic data on persons with disabilities, and a

comparison of the demographics of bus riders and

persons with disabilities.

While data on persons with disabilities have

been compiled at the national level, there is little

available at the State and local level. The national

level data have been developed from the perspective of health and medical services, public assistance, education, employment, and income, but

little has been done with regard to transportation

services or needs. The data that are available vary

in their definitions of “disabled’ and “disability.” In a report on its workshop on Disability

Statistics held in April 1989, the Committee on

National Statistics observed:

Statistics on persons with disabilities are produced by many government agencies whose

needs for information are governed and driven by

their respective administrative requirements. These

agencies, neither individually nor collectively,

provide a consistently applied, widely accepted

definition of disability.2

Confusion concerning the number of individuals

with disabilities arises from several factors: some

persons have multiple disabilities, the severity of

a disability can vary, and survey methodologies

and questions can differ significantly.

In Section 3 of the ADA, Congress establishes

a three-pronged definition of the term ‘ ‘disability’: 1) a physical or mental impairment that

substantially limits one or more of the major life

activities of an individual; 2) a record of such an

impairment; or 3) being regarded as having such

1 Public Law 101-36, Sec. 305(b).

2 Committee on National Statistics, “Disability Statistics: An Assessment,” workshop summary on disability statistics, April 1989.
an impairment. Senate report language expands

on this definition; under the first prong, a‘ ‘major

life activity” means functions such as caring for

oneself, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and

working. A ‘‘substantial limitation’ is a restriction of a major life activity in terms of the

conditions, manner, or duration under which it

can be performed. In Section 2 of the ADA,

Congress finds that “. , . some 43,000,000

Americans have one or more physical or mental

disabilities. This figure is one of several,

ranging from 20 to 50 million and based on data

developed by the National Center for Health

Statistics, the International Center for the Disabled, the National Council on Disabilities, the

Bureau of the Census, the Health Care Financing

Administration, and others.

Types of Disabilities

Disabilities are difficult to quantify and categorize; they manifest differently in each individual,

and have different effects. For example, a mobility impairment may affect a particular individual’s ability to board an inaccessible bus, while

having no impact on that person’s ability to use a

computer. Thus, persons with disabilities are in

no way a homogeneous group. 3 For the purposes

of this discussion, OTA presents three categories

of disabilities: 1) mobility impairments; 2) sensory impairments; and 3) cognitive impairments.

Mobility Impairments

National Health Information Survey (NHIS)

data 4 indicate that approximately 1.4 million

Americans use wheelchairs, 1.7 million use

Demand for Accessible Over-the-Road Bus Service 75

Individuals with physical disabilities participate in

many aspects of life.

walkers, a total of 3.0 million use mobility

devices other than canes or walking sticks5 (table

3-l), 4.4 million use canes or walking sticks, and

0.9 million use leg braces.

The NHIS relied on self-identification to determine the use of technology devices for mobility

and sensory impairments. The study thus might

exclude persons needing accessible services who

do not use devices, as well as some individuals

with temporary disabilities.6 Thus, the survey

probably underestimates the numbers of persons

with mobility and/or sensory disabilities. However, the NHIS is the most comprehensive source

of national data on persons with disabilities.7

When considering level-change devices to

assist individuals with mobility impairments to

board an OTRB, it is useful to consider the

activities involved in boarding a bus to understand how some persons would have difficulty

3 ‘<who tie tie Disabl~?”The cQ Researcher, vol. 1, No. 32, Dtw. 27, 1991, p. 999.

A Numbers do not add up to one overall total because of duplication. Derived from U.S. Department of Health and Human Services, Advance

Data Vital Health Statistics of the Centers for Disease Control/National Center for Health Statistics, Sept. 16, 1992 and Dec. 15, 1992. The

Natioml Health Information Survey is a statistical analysis of health-related issues, including disability prevalence.

f’ This number includes crutches, walkers, wheelchairs, scooters, and other mobility equipment in a total with no duplication.

b As an example, this latter group might include people recovering from broken bones or surgery. Similarly, table 3-1 indicates that crutches

are used most often by persons between the ages of 25 and 64.

7 Remarks at Office of Technology Assessment Workshop, ‘‘Building Accessible OTRB Service, ” July 15, 1992.
76 0ver-the-Road Bus Access

Table 3-1-Disability Statistics (number of persons in thousands)

All ages 24 and under 25-44 45-64 65-74 75 and over

Any hearing technology device. . . . . . . . . . . 3,987 152 257 818 1,142 1,618

Any vision technology device. . . . . . . . . . . . . 261 12 67 39 32 111

Any mobility technology device. . . . . . . . . . . 3,040 223 350 629 620 1,218

Crutch. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 671 87 173 209 137 64

Walker . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1,687 34 72 275 350 957

Wheelchair . . . . . . . . . . . . . . . . . . . . . . . . . 1,411 139 168 304 924 476

Scooter . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64 6 11 18 18 11

Other mobility equipment . . . . . . . . . . . . . . 254 18 28 66 57 85

NOTE: Totals may not add beeause some persons may use more than one device.

SOURCE: U.S. Department of Health and Human Serviees, Advance Data, From Vita/Health Statistics of the Centers for Disease

ControlNational Center for Health Statist&s, No. 217, Sept. 16, 1992.

with the current OTRB system. Functions necessary to use an inaccessible OTRB include the

ability to walk, climb stairs, stand up, sit down,

and grip. The loss or impairment of one or more

of these functions may result from age, disease,

birth defects, or injury. A person who is unable to

perform one or more of these actions will likely

need some form of assistance, ranging from the

support of a steadying hand to a level-change

device. 8 (For a profile of a person who uses a

wheeled mobility aid and must travel for his

work, see box 3-A.)

Among conditions affecting these key functions are loss of muscle control (e.g., as a result of

multiple sclerosis), loss of balance (associated

with inner ear problems, nerve damage, and

vision impairments), amputations, breathing difficulties, chronic pain, arthritis, spinal cord damage, heart disease, cancer, and weakness from

cancer treatments. Many of these conditions are

associated with advanced age.9

Sensory Impairments

Estimates of the number of persons with

sensory impairments vary according to the source

of the information and the definition of impairment. For example, the Survey of Income and

Program Participation (SIPP) in 1984 counted

11.1 million individuals “. . . who have difficulty

seeing ordinary newsprint with eyeglasses or

contact lenses. ” 10 The 1978 Survey of Disability

and Work, however, found less than 1.8 million

people “. . . who have difficulty seeing well

enough to read ordinary newsprint even with

glasses. ’ ’11 The NHIS, meanwhile, gave a total of

4.5 million people who have difficulty seeing

even when wearing corrective lenses, and 261,000

who use a vision technology device. These data

illustrate that estimates of the numbers of persons

with sensory disabilities can vary greatly according to the nature of the study .12

Visual Impairments—According to one count,

two-thirds of the 1.1 million individuals defined

as legally blind still have some perception of light

8 William H. Henderson et al., Passenger Assistance Techniques: A Training Manual for Vehicle Operators of Systems Transporting the

Elderly and Handicapped (Fort Wort& TX: Transportation Management Associates, 1982), p. 3.

g Ibid., pp. 3-9.

10 ~tchelI p. LW~te md Ustie A. Grant, “PeHons Who Need or Benefit From Accessibility Features in the Built Environment’ paper

prepared for the Architectural and Transportation Barriers Compliance Board, April 1988, p. 18.

11 Ibid., p. 19.

12 Ibid., pp. 19-20.
Demand for Accessible Over-the-Road Bus Service 77

Box 3-A—Profile of a Traveler Who Uses a Wheelchair

Randall Martin,l of Houston, Texas, is a senior vice president of a research institute and a professor

of rehabilitation medicine at a medical college. Randall is a quadriplegic as a result of a spinal cord injury

and uses a motorized wheelchair.

When relocating to Houston 2 years ago, Randall and his wife looked for a house as close as possible

to his workplace in order to minimize commuting time. A quadriplegic can sit in a wheelchair for only a

limited number of hours each day, and commuting time directly affects available productive hours.

Randall has a subscription arrangement for paratransit service for the 4-mile trip to and from work.

On a given day, if he is unable to meet the prearranged schedule, Randall attempts to arrange alternative

paratransit service, which can be time consuming because of the heavy demand for paratransit services in

his city.

Randall’s other transportation options include a regular city bus route to his office that stops in front

of his house, but only 50 percent of those buses are accessible and they run randomly; two or three buses

might pass before an accessible one comes along. However, another bus route that is 100 percent accessible

travels within about l/4-mile of both his office and his home. His wife, who also uses a wheelchair, can

drive their lift-equipped van as her own schedule allows.

Randall travels frequently by air, almost always accompanied by an attendant. On business-related

travel, he sometimes arranges for a lift-equipped van from his office at the medical center to the airport.

Otherwise, he tries to schedule paratransit in advance, or relies on his wife. When traveling to Washington,

DC, he prefers to arrive at National Airport, where he has two options: the Metro rail system or accessible

taxis. Randall claims that next to Vancouver, Canada, Washington has the best accessible on-call taxi

service. However, whereas a cab trip from the airport to a nearby hotel costs a person without disabilities

$4.50, it runs $20 for the accessible service.

Randall wishes that accessible over-the-road bus (OTRB) service were available for some of his travel

needs. For instance, from time to time he travels to Princeton, New Jersey, flying from Houston to Newark.

As of late 1992, no accessible OTRB service existed between Newark and Princeton. Instead, at a cost of

about $200, he must arrange for ground transportation to Princeton via the nearest provider of accessible

service, a contractor in Philadelphia with a lift-equipped school bus.2

One of the worst travel experiences Randall had was in Chicago en route from the airport to his hotel.

He had arranged for airport pickup by a lift-equipped van operated by a contract service. The driver

operated the lift without much difficulty, but events proved that he did not properly secure the tie-down

mechanism. The van swerved in traffic and Randall’s wheelchair tipped over, throwing him onto the lift

mechanism. The result was a 4-inch gash on his head, which bled profusely. At a nearby hospital, Randall

was treated for a concussion and stitched up. He sued the van company; the outcome was an insurance

settlement to replace his damaged wheelchair and cover his medical expenses.

1 R-_is a fictitious namq the person is real

z ~ceton ~s ~ ~m~ smtiom titit is not ~ily r=~ from tow. Wratrausit systems aboti h New Jersey,

serving county-wide areas. However, they are fimded through State and county resources, and Randall’s experience has been

that only residents are eligible for the service.
78 I Over-t he-Road Bus Access

Persons with hearing impairments rely on several

forms of communication, including sign language.

Persons with vision impairments often use aids, such

as dogs or canes.

and shape. 13AS many as 5 million persons are not

legally blind but have vision impairments to a

degree that makes travel difficult (see box 3-B).

As with many disabilities, vision impairment

correlates with advanced age.14

Auditory Impairments—Hearing loss has a

strong correlation to advanced age and is considered a wide-spread condition in the United States,

affecting as many as 14 million persons.15 Some

individuals with auditory disabilities benefit from

hearing aids, but many do not. While persons with

acute hearing sometimes expect individuals with

auditory impairments to read lips, this is an

ineffective means of communication in which as

much as two-thirds of the conversation must be

guessed. 16

Cognitive Impairments

The ADA includes mental retardation, emotional or mental illness, and learning disabilities

as part of its definition of ‘mental impairment,’

referred to by OTA as ‘‘cognitive impairment. ’

In addition, an injury, disease, or condition

affecting the brain can create a situation in which

an individual may have difficulty with particular

functions. Examples include the following:

. Mental retardation, also referred to as subaverage intelligence, has many causes, most

of which are not well-understood. Categories of mental retardation include borderline

retardation, which encompasses Intelligence

Quotients (IQs) of 84 to 71; mild retardation

(IQs 70 to 50); moderate retardation (IQs 49

to 35); severe retardation (IQs 34 to 20); and

profound retardation (IQs 19 and below).

Depending on the level of retardation, individuals with this type of cognitive disability

may require simple, more explicit instruc13 Hen&so~ et al., op. cit., footnote 8, pp. 3-9.

14 Ibid., 3-9.

15 my fewer ~~vldu~s ~ve sp~ch disabilities, some of w~ch stem from audito~ ~p~en~ or he fiereffw~ of strokes or cancer

surgery. Ibid., pp. 3-9.

16 Ecosome~cs, hlC., ‘‘Potential Demand for Over-the-Road Bus Services by Individds With Disabilities,’ OTA contractor repo~ July

15, 1992, p. AA.
Demand for Accessible Over-the-Road Bus Service 79

Box 3-B—Profile of a Traveler Who Is Blind

Geraldine Dolel is a middle-aged social worker in a large city in the Mid-Atlantic region. She is totally blind

and uses a seeing-eye dog. Her work requires that she travel around the metropolitan area to visit clients and attend

meetings. Advance planning for even the simplest of this travel is necessary and time consuming.

In a recent week that Geraldine describes as typical, she attended a meeting in a location not served by local

transit. She arranged with a friend and colleague to provide her and her seeing-eye dog with automobile

transportation there and back. The following day she visited a client in the hospital and was able to take local

transit both ways. She determined from the driver that his bus was the one she wanted and relied on her dog to

guide her onto the bus and to a seat. Later that same week she arranged automobile transportation to a reception.

On the way back, in the rain, she tried her luck on paratransit, with the help of a friend using a wheelchair who

had arranged a paratransit pickup for herself. In Geraldine’s city, only persons with mobility disabilities are

eligible for paratransit service. With her friend’s intervention and the willingness of the paratransit driver to look

the other way, Geraldine was able to ride to within 2 blocks of her home.

Geraldine flies frequently. While making advance ticket reservations she asks for assistance at the other end

and requests either a window or middle seat. She must reconfirm these arrangements at the airport; quite often,

airline personnel presume she would prefer an aisle seat and change her seating assignment without checking with

her. An aisle seat is riskier for her dog, who is more exposed to being stepped on. The dog lies facing the front

of the aircraft, with as much of her body as possible under the seat in front of Geraldine.

Over-the-road bus travel is the least convenient of all modes for Geraldine. She claims that assistance from

bus personnel for people with disabilities is less available since the Greyhound strike. The entrance to the bus

terminal in her city is less accessible by car than is the airport, and she has no escort into the bus terminal if she

takes a cab; if she is taken by a friend who can escort her, parking is inconvenient and expensive, Without a guide

she has no idea where the ticket counter is, and there seem to be no bus personnel around to help with directions

or luggage. It is very difficult to hear announcements of bus departures and finding the departure gate is a major

challenge unless someone, usually a fellow passenger, helps.

Rest stops on Interstate highways are particularly difficult. All of the buses seem to arrive at once, and even

helpful fellow passengers make a bee-line to the restrooms or the lunch counter to beat the inevitable lines, leaving

Geraldine, and her dog, wondering which direction to take. In such circumstances, she says, it is important to be

able to rely on the driver for courteous and considerate assistance in guiding the passenger in the right direction,

understanding that the rest stop is for both passenger and dog, and refraining from moving the bus to a different

location without warning.

Geraldine believes training of bus personnel in dealing with persons with disabilities is a critical need. She

maintains that lack of awareness of others’ disabilities and how to deal with them usually underlie the occasional

uncaring behavior or rudeness.

1 Geraldine Dole is a fictitious name; the person is real.

tions than other persons need in order to function, a stroke can affect an individual’s

travel. ability to speak, read, make purposeful

. Strokes, which occur predominantly in peo- movements, use certain muscles, recognize

ple over the age of 55, can cause losses of shapes and objects, remember, and maintain

both physical and mental functions. While emotional control.

rehabilitation therapy may eventually re- . Autism is a poorly understood condition that

store part or sometimes all of the lost exists from birth. Persons with autism re-
80 ! Over-the-Road Bus Access

quire explicit instructions in order to travel

independently. Among the manifestations of

autism that bus company personnel may

encounter are a tendency for persons with

autism to repeat back what is said to them, a

reluctance to contact other persons even

when needing assistance, and a loss of

emotional control when interrupted or confronted with a disorderly environment.17

No reliable data exist on the numbers of

persons with cognitive disabilities. Depending on

the breadth of the definition used, estimates of the

number of persons with cognitive disabilities

range from 1 to 20 percent of the population at

large.

Demographics

In order to compare

with disabilities with

current OTRB system,

the population of persons

that of the riders of the

it is necessary to examine

the demographics of each group. In addition to the

1980 NHIS, a 1977 study by the Urban Mass

Transportation Administration (UMTA) and the

1984 SIPP provide data on the demographics of

persons with functional difficulties. These data

tend to be consistent in key measures.

Demographics and Travel Characteristics of

Persons With Disabilities

The UMTA study focused on persons with

disabilities that limited their ability to travel.18

These included individuals using wheelchairs and

other mobility aids, as well as those with vision

and hearing impairments. The results describe

persons who:

●

●

●

Are older (67 percent are over 55 years of

age; 47 percent are over 65 years of age);

Have lower incomes (34 percent had household incomes of $4,000 or less in 1977

dollars-$9,000 in 1991 dollars); and

Have demographic characteristics associated with older age and lower incomes,

including: predominantly female (63 percent); less education (41 percent have an

8th-grade education or less); and unlikely to

be employed (only a 15-percent employment

rate).

Working-age persons with disabilities were employed at a rate of 23 percent, low compared with

64 percent of the population in general. Characteristics for individuals using wheeled mobility

aids did not differ significantly in the above

categories. l9

The 1984 SIPP presented statistics very close

to those of the UMTA study .20 The SIPP found

that women, African Americans, and persons

with lower levels of education were disproportionately represented among the groups with the

most limitations of function. For example, women

accounted for 51 percent of the working-age

population, but they made up 61 percent of those

with “. . . a substantial limitation in functioning.” 21 Similarly, in a total population that was 11

percent African American, 16 percent of persons

with severe limitations in functioning were African American. While marriage rates for workingage adults were similar for persons with and

without disabilities, this was not true for the total

population of persons with disabilities who were

more likely to be older and to have had spouses

17 Henderson et al., op. cit., footnote 8, PP. 3-9.

18 some ~ysts~~tie ~Sabfii~ com~~ ~ve rw~atiom about ~S study. Heavy discoun~g of potential riclership on accessible

transportation occurred when persons with disabilities did not give particular responses. For example, when asked if the absence of “curb cuts’

would be a problem, a person with disabilities who had a means of coping with sidewalk curbs and therefore answered “no’ would have his

or her response dropped. Thus, in some cases numbers as high as 60 percent were discounted to as little as 3 percent.

19 Econometrics, Inc., op. cit., foomote 16, pp. 4-12 tO 4-13.

20 ~~ernatica Policy Research, ‘‘Task I: Population Profile of Disability,” report for the U.S. Department of HeaIth and Human Services,

OffIce of the Assistant Secretary for Pkmnin g and EvrduatioQ October 1989, pp. xvii-xx.

21 Ibid., p. 57.
30% ;

20% “

10“/0

0%

Demand for Accessible Over-the-Road Bus Service 81

Figure 3-1—lntercity Passenger Travel, by Age of Traveler and Mode of Transportation, 1977

(percent of total)

—

1

18-24

-..

—

25-34

.—

1 .

—

35-44

Age

— —

45-54

—

55-64

. . . . . .

I

.

I

i “

—

65+

SOURCE: Robert R. Nathan Associates, Inc., from data in U.S. Department of Commerce, Bureau of the Census, “Travel During 1977, ” October

1979.

who died.22 For elderly persons with no physical one rather than for business purposes, they

limitations, the SIPP found that 26 percent lived are likely to be paying for the trip out of

alone, compared to 37 percent for elderly persons personal funds. According to 1991 Grey -

who needed some form of assistance. These data hound passenger survey data, roughly oneindicate that elderly persons with disabilities may half of its riders have incomes under $15,000

not find it easy to bring traveling companions .23 per year, and do not have a car capable of a

500-mile trip.24

Demographics of OTRB Riders .

Fixed-Route Travelers-For Class I carriThese numbers are even more pronounced

ers, age, income, gender, and race are distinguishwhen compared to similar data from other

ing variables of the fried-route OTRB market. intercity transportation modes. Figure 3-2

shows that in 1977, families with $10,000

●

●

Age. Surveys of intercity bus passengers

tend to support the observation that fixedroute passengers include riders who are

younger or older than passengers in other

modes of transportation (see figure 3-l).

Low income. The intercity bus rider is much

more likely to have a low income than is the

air or rail passenger. Furthermore, because

most OTRB passengers travel to visit some-

(1977 dollars-$22,500 in 1991 dollars) or

less annual income accounted for 45 percent

of fixed-route intercity bus-miles, compared

to 25 percent for rail, 18 percent for automobiles, and 15 percent for air. However, less

than 5 percent of bus riders were traveling on

business, in contrast to 37 percent of railroad

passengers and 51 percent of those opting to

22 Ibid., pp. 57-61.

23 Ibid,, pp. 115-117.

24 GreyhoMd Lines, Inc., “Greyhound Lines Passenger profile, ” unpublished report, August 1991, as cited in Econometrics, Inc., op. cit.,

footnote 16, p. 1-18.
82 0ver-the-Road Bus Access

Figure 3-2—lntercity Passenger Travel,

by Family Income and Transportation Mode,

1977 (percent of total)

80% r

~Train ~Aut o

~ ‘d Airplane m BU S

60% ~

,rl

410,000 $10,000-$19,999 >$20,000

Family Income

SOURCE: Robert R. Nathan Associates, Inc., from data in U.S.

Department of Commerce, Bureau of the Census, “Travel During

1977,” October 1979.

fly. These patterns continue to hold true into

the early 1990s.25

Gender and racial characteristics. Riders

of fixed-route OTRB service are largely

female. The percentage of persons from

minority groups riding intercity buses is also

high. Fifty-eight percent are female, compared to51 percent of the overall population,

and 42 percent are nonwhite compared to 16

percent of the overall population.26

Charter and Tour Service—Information is

not readily available regarding the demographics

of charter and tour passengers. However, a 1986

survey shows that unlike fixed-route passengers,

they have an average household income of over

$34,000 (1985 dollars; over $47,000 in 1991

dollars) and own 1.8 autos per household. But

similar to fixed-route passengers, they are likely

to be older, with a median age of 60.27 Thus,

advanced age, which has a strong correlation to

disability, also characterizes charter and tour

travelers.

Demographic Projections—The Bureau of

the Census projects that the proportion of the U.S.

population age 65 and over will increase from 12

percent in 1990 to around 18 percent in 2020,

reaching 21 to 25 percent in 2050 (see figure 3-3).

With the high incidence of disabilities among the

elderly, it is possible that the growth of this age

cohort will correspond to growth in the number of

persons with disabilities (see box 3-C). While

data are not available quantifying the numbers of

‘‘ii-ail’ elderly, it seems likely that this group will

grow along with the percentage of the population

80 and over (3 percent in 1990,4 percent in 2020,

and 8 percent in 2050).28 Frail elderly persons

might not have specific disabilities, but may still

need assistance. As age is a strong correlate of

both disabilities and use of OTRBs over other

modes of transportation, the aging of the U.S.

population could lead to increased ridership.

EXPERIENCE WITH ACCESSIBLE

SERVICE29

Because there has already been a great deal of

experience with technologies for persons with

sensory and cognitive impairments (see ch. 4),

this section focuses on experience with technologies for persons with mobility disabilities. U.S.

experience with accessible OTRB service for

persons with mobility impairments is extremely

limited. In seeking programs that might shed

~ u.S. Dep~ent of Commerce, Bureau of the Census, ‘‘Travel During 1977, ’ October 1979, as cited in Econometrics, Inc., op. cit.,

footnote 16, p. 1-20.

26 GreyhoWd L~es, Inc., op. Cit., footnote 24, p. 1-18.

27 Lawrence F. Cunningham, “Proftig Tour Patrons and Non-Patrons in InterCity Bus Passenger Markets,” paper presented at the Annual

Meeting of the Transportation Research Board, Washington DC, January 1986.

Zl us, Dep~ent of Co-erce, B~eau of me Cemus, Projections of the populations of the United States by Age, Sex, and Race: 1988

to 2080, Current Population Reports, P-25, No. 1018 (Washington, DC: U.S. Gov emment printing OffIce, 1989).

29 Except where noted, this section is based on Econometrics, kc., Op. CiL, fOOmOte 16.
25%

20%

15“/0

10“!0

5%

0%

Demand for Accessible Over-theRoad Bus Service 83

Figure 3-3-Growth of Population, Ages 65 and Over, Actual and Projected

t 1 [ r 1 1 1 1 1 1

Highest

Middle

Lowest

1900 1910 1920 1930 1940 1950 1960 1970 1980 1990 2000 2010 2020 2030 2040 2050

SOURCE: Data for 1990 from 1990 Census of the Population (CPH-L-74, modified age and race counts). U.S. Department of Commerce, Bureau

of the Census, Projections of the Population of the United States by Age, Sex, and Race: 1988-2080, Current Population Reports P-25, No. 1018

(Washington, DC: U.S. Government Printing Office, 1989).

some light on the likely demand for such OTRB

service, OTA discusses one State-sponsored program in Massachusetts, a demonstration project

in Canada, and a portion of the Denver transit

system. Data from these programs are of marginal

use, because such factors as poor lift reliability

(especially with early generation lifts), inadequate marketing, incomplete coverage of routes,

There is a strong correlation between disability and

age.

and unsatisfactory service affected the ridership.

Indeed, many of these operations collected data in

such a way that lift usage is extremely difficult to

quantify. Further, some lift-equipped OTRBs

served limited regions; only a few traveled to

major destinations.

The Massachusetts Program

Sustained accessible intercity bus service did

not exist in the United States prior to 1986, when

Massachusetts began a project to make OTRBs

operating in the State accessible. The program

stemmed from the convergence of three efforts:

●

●

●

the Massachusetts Coalition of Citizens with

Disabilities (MCCD) identified improvement

of inter-regional travel options for persons

with disabilities as a priority;

the Governor’s Commission on Accessible

Transportation found a need for improvements in the public transportation system;

and

the State moved to assist private bus operators whose services linked Boston with

outlying areas.
84 10ver-the-Road Bus Access

Box 3-C-The Aging of America

The Bureau of the Census, using data from 1990 and earlier, has projected the growth of the Nation’s older

population through 2050.1 Projections are based on a Lowest, a Highest, and a Middle Series of assumptions about

fertility, mortality, and immigration. The Middle Series projections through 2050 illustrate the passage of the Baby

Boom generation and provides an interesting glimpse into the future of an aging America During this 60-year period,

those 65 and over grow from 12.5 percent of the population to 22.9 percent, and those 85 and over increase from 1.2

percent to 5.1 percent of the total (see figure).

In 1990, 31,079,000 Americans were 65 years and over, in a total population of 248,710,000. The Bureau of

Census projections break these figures into 5 categories ages 65 to 74 (7.3 percent), 75 to 79 (2.5 percent), 80 to 84

(1.6 percent), and 85 and over (l.2pecent); the fifth category, those 80 and over, represented 2.8 percent of the Nation's

1990 population.

The first 20 years of the 1990-2050 period begin with the proportion of elderly in the total population increasing

to 13.9 percent. Most growth is among the upper ranks of the elderly and is not matched by those entering the 65 to

74 year category. As a percentage of the population, the 65 to 74 group actually declines in 2000, rises to 1990 levels

in 2010, then swells in 2020 as the Baby Boom generation begins its march through the ranks of the elderly.

By 2020, the number of those 65 and over will have increased to more than 52 million. Their portion of the

population will rise from 12.5 to 17.7 percent. The number of persons in the 65 to 74 age bracket will have grown by

72 percent, and those in each of the next two categories by less than 50 percent. The 80 and over cohort, however,

increases by 75 percent, and the over 85 category jumps an astounding 120 percent.

In 2050, the total population of the United States is projected to decline for the first time since 1900, falling below

300 million. Those 65 and over will comprise 22.9 percent of total population, however. The two categories

encompassing age 75 through 84 will decline noticeably, and the over 85 cohort will reach 5.1 percent of the population,

compared to 1.2 percent in 1990.

85+

80-84

75-79

70--74

65-69

60-64

55-59

50-54

 45-4 9

40-44

35-39

30-34

25-29

20-24

15-19

10-14

5-9

o-4 L~ -–2

1950

U.S. Population Pyramid, 1950-2030

L-------J

L 1

~

( J

I

[ 1

[ I

c------- l

~

[ 1

r-

!

r J

1980 2000 2030

SOURCE: National Research Council, Transportation Research Board, Transportation in an Aging Society:lmproving Mobility and

Safety for Older Persons-Volume 1 (Washington, DC: 1988), p. 21.

1 From U.S. Department of Commerce, Bureau of the Census, 1990_ of POpuhttion (H-~74, mtiled We

and race counts), T&le l+rowtb of the Older Populatio~ Actual and Projected: 1!XW2050.
.

Demand for Accessible Over-the-Road Bus Service I 85

As a consequence, the State’s Office of Transportation created the Intercity Bus Capital Assistance

Program (IBCAP) to purchase new intercity

coaches that would be leased to the private

carriers at rates 50 percent lower than commercial

lease rates.

Six of the first 28 coaches ordered under

IBCAP were equipped with lifts. At the time, the

only lift available was an elevator-style lift,

developed for a Canadian demonstration project

(discussed below) using MCI coaches, and commonly referred to as the first generation MCI lift.

All 28 coaches had a retractable first step, extra

handrails, and public address systems. The first

accessible service began in May of 1986 with six

regional carriers.30 In 1989, 22 more coaches

were delivered, all accessible with secondgeneration elevator-style MCI lifts, and the program was expanded to include 4 more bus

companies .31

The Massachusetts Port Authority obtained six

accessible coaches, leasing them to Plymouth &

Brockton to provide service to Logan Airport.

Using UMTA funds, the Taunton Regional Transit Authority purchased one lift-equipped OTRB

and the Brockton Area Transit Authority purchased six, leasing them to Plymouth & Brockton. The Greater Attleboro Regional Transit

Authority made plans to purchase nine accessible

OTRBs, to be leased to Plymouth & Brockton. As

of mid-1992, 15 percent of the total OTRB fleet

in Massachusetts was lift-equipped.

Route Restrictions

Eighty percent of the routes traveled by buses

purchased under IBCAP must be within the State

of Massachusetts. This requirement is determined

by total bus-miles operated in freed-route service,

which allows bus companies to schedule accessible travel to limited destinations outside Massachusetts, as Peter Pan does with its route from

Springfield, Massachusetts to Albany, New York.

Another restriction is that no more than 15

percent of the bus-miles can be operated in charter

and tour service, with no charters to be operated

during peak commuting times. Initially, all chartermiles were to be operated in Massachusetts,

although this was revised to allow charters to go

outside the State.

Technology Issues That May Affect Demand

The first-generation elevator-style MCI lift on

the accessible buses had problems associated

with microprocessors, clearances, and loss of

seating positions (see ch. 4). Second-generation

MCI lifts addressed some of these issues. Overall

seating capacity improved, from a displacement

of six seats with both tie-downs occupied to a

displacement of only four seats with both tiedowns occupied, although decreased baggage

space remained a concern of the bus companies.

However, significant maintenance problems are

unsolved.

Passengers feel the effects of the imperfections

of this system-sometimes quite literally. When

the elevator platform settles, cold air from the

baggage compartment rushes into the passenger

compartment, and seals on the accessible door

sometimes let in more cold air. Most of the 10 to

15 minutes involved in boarding a person with a

wheeled mobility aid is taken up in the securement process. Securement is awkward and sometimes intrusive, creating difficulties for both the

driver and the passenger. Some drivers complain

that they are uncomfortable using the lifts to

board persons in wheeled mobility aids; drivers

also comment on lift reliability problems and

their own lack of experience using the lifts. A few

carriers have tried to limit such boardings to

terminal end-points.

30 ~e~e were peter pm Bus L@~, plwou~ & BrOckto~ ~ericm Eagle, Engl~der COWL -then Line, and hlterstate Coach.

31 me foU ~ompfie~ were Big W Tr~port~tio~, H&L Bloom Inc., Brush Hill Tr~portatio~ ~d Gulbanki~ BUS Lines. ECOSOme~CS,

Inc., op. cit., footnote 16, p. B-18.
86 0ver-the-Road Bus Access

Usage

Despite marketing efforts (discussed below),

usage has been low. While data are incomplete,

ridership statistics indicate that few individuals

had actually taken advantage of the lifts as of

mid-1992:

●

●

●

●

●

Peter Pan Bus Lines of Springfield, Massachusetts, the largest carrier in the program,

reports 361 reservations for accessible service since 1985, resulting in approximately

722 uses of the lifts.

Plymouth & Brockton, despite extensive

cooperative efforts with MCCD, the Equal

Opportunity Transportation Commission

(EOTC), and the Cape Organization for the

Rights of the Disabled, had approximately

50 lift-use reservations in 1991, out of a total

ridership of approximately 1.25 million for

that year.

Englander Coach Lines, which stopped doing

business in 1992, averaged less than one

lift-use per month for the time periods in

which it kept data.

American Eagle had four fixed-route liftuses in the first three-quarters of 1991, out of

a total of 47,000 boardings. In its charter

work, American Eagle had three lift-uses for

that same time period, and found that its

charter calls for accessible service tended to

come from cruise lines.

None of the carriers with data report a single

daily commuter.

Conclusions

In the debate over the ADA, industry sources

cited the operational problems and the low

demand in the Massachusetts project as reasons

not to require a lift on every bus. But both the

carriers and MCCD recognized that the operational problems with the lifts may have been a

factor in low usage, as individuals using wheeled

mobility aids shared with each other information

about problems with the lifts, schedules, and

drivers, thus discouraging greater use. Indeed,

with the need for reservations, the potential for

error, and the limited number of accessible

coaches, the possibility exists of a traveler with

disabilities, on a trip from Cape Cod to Springfield, having to spend the night in Boston.

Advocates for accessible service emphasize that

only 6 of the 226 OTRBs in the State were

lift-equipped through 1989.

The carriers involved had a mostly positive

attitude about providing accessible service; the

main thing they wanted was better lifts, although

a second priority was finding a means of retaining

the seats displaced by use of the tie-down

positions, especially on busy commuter runs. The

restrictions on charter and tour use outside the

State caused some carriers to feel they must reject

opportunities for business, such as tours of New

England or trips lasting longer than a weekend. It

is therefore likely that this low usage says little

about the possible demand for charter and tour

accessible vehicles.

Canada–The Newfoundland

Demonstration Project

The Massachusetts program began with technology developed in Canada. Transport Canada

has run two demonstration projects, one in

Newfoundland and a second in Ontario. Because

of the more complete data reviewed, OTA has

opted to present the Newfoundland project, examining the genesis of the program, technical issues

affecting demand, and actual usage. (For a

discussion of Canadian support for its OTRB

industry, see box 3-D.)

In the early 1980s, the Transportation Development Centre of Transport Canada began to study

the development of accessibility technologies.

Transport Canada’s Advisory Committee on Transportation of the Handicapped had previously

identified accessibility of intercity buses as a

concern. A September 1981 report prepared the

way for development of an accessible OTRB.

Between February 1985 and February 1988,

Canadian National Rail operated a lift-equipped
Demand for Accessible Over-the Road Bus Service 87

Box 3-D—The Canadian Experience

As in the United States, Canadian freed-route over-the-road bus (OTRB) service reaches more communities

than all the other public transportation services combined;l accessible intercity coaches are seen as an important

step in making Canada accessible for persons with disabilities. Although Canada does not have legislation similar

to the Americans with Disabilities Act, the Canadian Government has acknowledged the need for accessible

service, and several Provincial governments have conducted demonstration projects. However, as in the United

States, Canadian intercity coach operators face tough financial conditions, and it is unclear if some carriers can

afford to invest in new technologies.

In October 1991, the Transport Minister announced that over the next 5 years the Canadian Government

would provide $24.6 million (Canadian dollars) in financial incentives to the transportation industry to provide

accessibility for travelers. Of this sum, the government set aside $3.5 million for Canadian intercity bus operators

to purchase or retrofit buses with level-change devices and other accessibility features. Similarly, the government

provided $2.9 million to support fieldtesting, trials, and demonstrations of small-scale accessibility transportation

technologies. 2

In March 1992, the National Transportation Agency of Canada announced an inquiry into the accessibility

needs of persons with disabilities, and methods by which access could be provided to intercity coaches. The

agency has issued a draft national standard for accessibility, and expects to hear comments throughout 1993. The

agency has proposed an equipment standard, which includes:

● ramps, lifts, or other level-change devices;

● two wheelchair spaces with proper securement equipment on each coach;

● movable arm rests for at least five seats on every coach;

● appropriate signage;

● high ill umination levels;

● reduced height (less than 18 centimeters) for the first step onto the bus; and

● handrails and slip-resistant floors.

In addition, the proposed equipment standards reads: “Where no on-board restroom is accessible to persons in

a wheelchair, the operator shall idenify, in its schedule, specific stops which will be made to permit these persons

to use accessible facilities. ”3

The intercity bus manufacturing companies in North America market to both countries, so both the U.S. and

Canadian standards will affect the larger market in terms of accessibility technologies for intercity coaches.

1 ~mem both trains and airpkmes each serve about 500 communities, intercity buses seine over 3,000 C-dian

communities, many of them small towns. National Transportation Agency of Canada ‘*Inquiry Into Canadian Motor Coach

Semices,” discussion paper, March 1992, p. 2.

2 T-pen c~~ press Release No. 190/’91, Oct. 21, 1991o

3 Natio~ Transportation Agency of Canada op. cit., fOOtIIOtt? 1, pp. 6-7.

MCI MC9 across Newfoundland as part of a Technical Issues Affecting Demand

demonstration project. The program involved The Newfoundland project’s MCI demonstradriver training, public information, demonstra- tion vehicle used an internal elevator lift, which

tions to disability groups, a toll-free information became known as the first-generation MCI lift.

and reservation number, and other efforts. Ad- The two tie-downs eliminated eight seats; an

vanced reservations were encouraged but not accessible restroom was discussed but vetoed

required. when it was decided that it would be hazardous to
88 0ver-the-Road Bus Access

use while the bus was in motion, a particular

concern when heavy braking occurs. The accessible trips available were limited. They at frost

included one weekly round-trip from St. John’s to

Port Aux Basques and back, and another weekly

round-trip from St. John’s to Grand Falls and

back. In November 1986, this was changed to two

weekly trips from St. John’s to Port Aux Basques

and back; the original schedule resumed in 1988.

The lift technology functioned well enough,

but lift operations were so infrequent that even

trained drivers forgot certain aspects of lift use. In

addition, the high-technology aspects of the lift

intimidated some drivers, and some of the safety

sensors did not function.

Usage

For the 3-year period of the demonstration

project, the evaluation report counts 130 one-way

uses of the lift. Persons using wheeled mobility

aids accounted for 128 of these uses; only 9 times

did anyone opt to transfer from a wheeled

mobility aid to a conventional seat. While most

usage characteristics were similar to those of

other riders, persons with wheeled mobility aids

tended to take fewer long trips. For many of these

individuals, the bus schedule was more important

than the issue of accessibility-the project report

states that despite preferring the accessible bus,

persons needing the lift were more likely to deal

with the inconvenience and discomfort of a

nonaccessible bus than to adjust their schedules

for the arrival of the lift-equipped OTRB. Among

those using the lift, 55 percent of the trips were for

social or recreational occasions, 32 percent for

medical reasons, and 13 percent for education or

work. In 1988, ridership of persons using the lift

declined to 23 uses per year; by 1991, this number

was down to 13 uses. Total ridership during that

period declined as well, although much less

rapidly.

Conclusions

Does a demonstration project that runs a route

only once or twice a week present any basis for

extrapolating to a fully accessible service schedule? The short answer is that it does not. As shown

by the data, the Canadian operators learned that

the timing of the bus was a key factor in the

decision to travel. Problems with lift operation

may also have had an impact. In addition, the

population served by the project is quite small: in

a province about 500,000 people, both Grand

Falls and Port Aux Basques have populations

under 10,000, and the St. John’s greater metropolitan area barely exceeds 100,000. These factors,

combined with the small area of the Province,

make it unlikely that the data are relevant to the

demand for nationwide accessible OTRB service

in the United States.

The Denver Regional Transit District

Experience

Since 1987, the Denver Regional Transit District (Denver RTD) has purchased OTRBs to

serve a number of routes to outlying cities.

Denver RTD now has 102 OTRBs, 39 of which

are equipped with Stewart and Stevenson lifts.

One of the main routes using OTRBs connects

Denver, Stapleton Airport, and Boulder. Accessible service accounts for 37 percent of total

intercity service; weekend service is 100 percent

accessible, and weekday service runs between O

and 55 percent, depending on the route.

Technology Issues Affecting Demand

Denver RTD primarily uses an external lift

designed by Stewart and Stevenson Power, Inc.,

which has been installed on both MCI and

Neoplan OTRBs. Experience with this lift has

been positive; it is simple to operate and requires

little maintenance. Denver RTD reports that in

1991 a total of 39 labor-hours were spent on

maintenance of the 18 lifts used that year.

Criticism of the external lift centers on its

operation outside the bus, for it exposes to the

elements both the driver and the passenger using
Demand for Accessible Over-the-Road Bus Service 89

the lift, and it offers no enclosure for a passenger

leery of its 5-foot elevation.32

Usage

Early ridership on the lift-equipped OTRBs

was low, at perhaps one or two lift-uses per

month. Ridership by persons using wheeled

mobility aids has grown steadily, however, as the

overall accessibility of the fleet has improved.

From November 1990 to October 1991, lift usage

on routes with scheduled accessible service was

3,837, or 0.19 percent of total ridership. The

heaviest lift usage has been on the route linking

Denver, Boulder, and Stapleton Airport-with

2,885 total trips on a route that is 57 percent

scheduled for accessible service, the rate is about

eight lift-uses per day, or 0.28 percent of total

ridership on that route.

Conclusions

Like the other projects discussed here, the

experience of the Denver RTD does not provide

a look into the future of accessible fixed-route

OTRB service. The Denver RTD is a transit

operation, and its passengers use the service for

different reasons than they would a longer haul

bus service. However, the experience of the

system offers some lessons.

First, from a technical standpoint, the lifts

operate well and it appears that for the most part

both the operators and the passengers are pleased

with them. Second, ridership has increased over

time, as more and more routes became accessible

and as persons with disabilities became familiar

with the system. Finally, the heaviest use of the

lifts is to key locations: a large city (Denver), a

large college town with a nearby military base

(Boulder), and a major airport (Denver Stapleton).

Charter and Tour Service

The experience with accessible charter and tour

OTRB service in the United States is even more

limited than with fixed-route service. Nothing in

the way of a demonstration project has been done

with charter and tour service, although some

accessible buses purchased or operated with the

help of public financing do run the occasional

charter. Of the handful of private firms operating

accessible tours, only two use their own accessible OTRBs (Evergreen Travel Service, Inc. in

Lynnwood, Washington, and Sunrise Plaza, Inc.,

in Los Angeles, California-see ch. 2).33 These

numbers would seem to suggest that the demand

for accessible charter and tour service is very low.

In some European countries, however, many

more tour firms operate accessible coaches.

Indeed, this disparity between U.S. and European

OTRB services forces many tour operators servicing the disability community to arrange most of

their accessible tours abroad.

Why is accessible charter and tour service

available in Europe and not in the United States?

The European population of persons with disabilities is not appreciably different from that in the

United States. Nor are the technologies for

providing accessibility (e.g., lifts and ramps) less

expensive—although some governments pay part

of the costs for accessibility technologies on

OTRBs. Most likely, the difference between the

United States and Europe is that the demand for

accessible service was recognized much earlier

by segments of the European travel industry and

therefore, by fostering the market for accessible

sz OTA ~~ hewd ~e~e Cements from both bus operators and individuals with mobility disabilities. The Po~t is us~Y fisd bY bus

operators and usually discounted by people with disabilities as a small price to pay for accessibility.

33 me buS ~Omp~es p~lclpat~g in he Massachusetts ~terci~ Bus Capital Assist~~ ~0~~ Cm IUII ctier md tom service ~th theif

accessible OTRBS, but they are under time constraints and they have received public funding. Similarly, a number of California firms under

contract to local governments have the capacity to offer charter and tour service on accessible OTRBS, but they are under restrictions due to

the mture of their contracts.

330-069 0 - 93 - 4 QL:3
90 0ver-the-Road Bus Access

charter and tour services, accessible travel has

grown.

34 Consequently, although the lack of

supply of accessible charter and tour service in the

United States might be a function of the lack of

demand, it could well be the case that the lack of

demand is due to the lack of supply. (See box 3-E

on marketing of charter and tour services.)

Problems With Using Existing Ridership

To Indicate Demand

The demonstration projects discussed above

have tested the potential demand (and technologies required, see ch. 4) for accessible fixed-route

OTRB service. As noted, usage of lift-equipped

OTRBs in these demonstration projects has been

quite low.35 However, as discussed above, extrapolations from these data to estimate ridership by

persons with disabilities for nationwide accessible fixed-route OTRB services may be quite

inaccurate for several reasons.

●

●

●

●

Since there have been only a few examples

of accessible OTRB service, the overall

experience with such service has been extremely limited.

The accessible operations were limited in

geographical extent and served only a few

routes; many potential riders found that their

destinations and scheduling needs were not

addressed by accessible service.

Although the Canadian demonstration projects collected good data on lift usage and

ridership, the U.S. accessible systems have

collected very little data.

Little marketing accompanied the projects,

so persons with disabilities often did not

know that the service existed.

MNIA COACH CO.

hmndtefe ● Rwthe 11-‘W.a WmJR$ ~ “

-11 @5rCaft5rbwwumm——X9ta

P“

LOCAL & NATIONWIOE Cb4ARTM SERVU

t

- --l -. ., %4%%%%(E% (202) 7834684

LINE ~

-- n?? DAILY AltAllllC CtTY CASl#6 $t@U

--- . CHARTER TOURS %%’%.-% Wm. mulww ,OrJ,-i *.. -*-

Yellow Pages advertisements are the most common

marketing tools used by OTRB companies.

Much of the experience to date is based on an

early generation MCI elevator-style lift,

which was plagued with reliability problems.

Marketing

Fixed-route bus companies tend to do little

marketing. Some run an occasional advertisement, in which they may mention that they will

assist riders with disabilities who make a special

request. In addition, Greyhound has a toll-free

number for persons seeking such assistance. Past

this, however, OTA could find no efforts to reach

or assist persons with disabilities in using the

OTRB system.

Even with accessible fixed-route service, marketing efforts have been limited. The Massachusetts EOTC provided carriers with brochures on

the availability of service through their program,

and worked with MCCD to develop public

service announcements and to communicate with

disability groups. EOTC has made further efforts

~ Al~o@ it may k relatively easy to arrange a.naccessible tour in certain European countries, OTA could learn of no accessible fried-mute

OTRB service in Europe. So, for example, a person with disabilities might be able to take a tour of Berlin and its sights, but would be unable

to take a bus horn Dusseldoti to Vienna. While the U.S. guide to fried-route bus schedules, Russell’s Guide, is 540 pages long, its European

equivalent is a mere 40 pages. Instead, much European travel takes place on the extensive railroad system. Frederic D. Ravel, Econometrics,

Inc., personal cornmunicatiom July 1, 1992.

35 while some -it system ~ve s~n ridership by ~divid~ with &abifities hcrease dramatic~y once the entire SyStem became

accessible, transit smice differs signifkantly from OTRB service. For example, individuals with disabilities might use transit services to go

to work a usage that would be less likely for a freed-route OTRB passenger.
Demand for Accessible Over-the-Road Bus Service 91

Box 3-E—Charter and Tour Marketing for Individuals With Disabilities

Most accessible leisure or vacation travel for Americans with disabilities is by private auto, accessible van,

airplane, cruise ship, or Amtrak. Over-the-road bus (OTRB) travel is the least accessible and most difficult to

arrange. The result is that most opportunities for accessible motorcoach tours for Americans with disabilities lie

abroad, not in the United States. Americans with disabilities take their bus tours in Western Europe, Israel, New

Zealand, Australia, and elsewhere. But overseas trips are expensive, and few individuals with disabilities, their

family members, and traveling companions can afford them.

A few U.S. travel agents and tour operators have the disability community as their primary client base and

advertise in publications such as Paraplegia News, Mainstream Magazine, The Itinerary, Sports and Spokes,

Handicapped Travel Newsletter, and Accent on Living. One tour operator in Minnesota has been providing

accessible tours for over 20 years.1 Another in California runs an information network called Travel Industry and

Disabled Exchange (TIDE), publishes a newsletter, “Tide’s In,” and maintains a mailing list of more than 1,100

wheeled mobility aid users. 2 Most of the operators rely on traditional travel business to offset the expense of

the disability niche market.

OTA located 3 directories that list some 325 travel agencies and tour operators offering accessible travel

opportunities for persons with disabilities. Many arrange trips for clients with specific disabilities, such as visual

impairments, hearing impairments, or cognitive impairments. Some offer tours for individuals dependent on

dialysis or for persons with diabetes, while others specialize in travel for people using wheeled mobility aids. A

few handle tours accommodating the entire range of persons with disabilities. Only five tour operators/travel

agents appear on all three lists.3 One is the tour operator with the lift-equipped OTRB profiled in chapter 2, box

2-F.

A nonprofit organization in New York City, called the Society for the Advancement of Travel for the

Handicapped, operates a worldwide clearinghouse of information on accessible travel conditions for persons with

disabilities. It lists 35 travel agents in this country and 9 operating in Australia, Egypt, Greece, Israel, France, and

Hungary. 4 Twin Peaks Press in Vancouver, Washington has published a directory of 300 travel agencies in the

United States, 26 in Canada, and 46 abroad that arrange tours for individuals with disabilities. 5 The American

Association of Retired Persons (AARP), in its book Touring by Bus at Home and Abroad, devotes one chapter

to “The Traveler With Disabilities” and lists 10 travel agents in this country providing tour services for persons

with disabilities.6

The tour network for persons with disabilities is rudimentary and scattered. Participants are primarily small

businesses. In many cases, the involvement of a travel agent or tour operator in serving the disability community

depends on the interest of a single employee who may leave at any time. The American Society of Travel Agents,

representing some 12,000 approved travel agents, has established a 15-member Committee on Travel for the

Disabled to raise the level of awareness of front-line travel agents about the travel needs of persons with

disabilities. Several active participants in this informal tour network are members of the committee.

1 Barbara Jacobso~ owner, Flying Wheels Travel Service, Owatouria, MN, ~rsonal Communion, JUIY 15, 1992.

2 yVOm Nau, Nautilus lburs, he., ‘Ruzuq C& personal COWMllli@iO~ Jan. 28, 1992.

3 Evqqeennavel Service, Inc. of Lynnwood, W* Flying Wheels Travel &aviee Of oWatOm14 MN; NSUtiUS ~urs,

Inc. of ~ CA; New Directions, Inc. of Santa Barbara, CA and Wheelchair Wagon lburs of Kissimmee, FL. A sixth

Whole Person Tours of BayOMe, NJ, would probably have made all three lists but has been inactive

since late 1991.

4 Av~able~u@Smiew for tie~v~x of ‘1’mvel for & mcap~ 347 Fifth Avenue, New York NY

10016.

5 Av~able ~u@ the Disability Bookshop, P.O. BOX 129, ~COUVW, WA 98666-0129.
92 0ver-the-Road Bus Access

to enable persons with wheeled mobility aids to

use paratransit throughout the State, easing travel

to and from OTRB stations at both ends of the

journey. MCCD, meanwhile, has developed and

promoted use of accessible OTRBs within the

State. Some of these funds have gone toward a

statewide toll-free number that provides information about and reservations on accessible intercity

buses and the corresponding paratransit connections. Most Massachusetts carriers, however,

have done little beyond Yellow Pages advertisements to promote their accessible service.

The Canadian demonstration projects involved

extensive marketing, including meetings and

demonstrations with disability groups, media

advertising, free rides, and publicity efforts. The

free ride promotion was particularly effective. In

the United States, transit systems tend to market

OTRB accessibility as part of the information

they provide regarding the overall accessibility of

their systems. Denver RTD has a brochure

describing its system, and its timetables include

accessibility information. In California, the Golden

Gate Bridge Highway and Transportation District

has a user brochure discussing all of its accessible

vehicles, including OTRBs.

THE DIFFICULTIES OF PROJECTING

DEMAND

One of the issues regarding ADA accessibility

standards for OTRBs concerns demand versus

need. Disability groups make a strong case that a

significant portion of the population needs accessible OTRB service. On the other hand, bus

company owners fear making capital expenditures they might not be able to afford in order to

provide a service that maybe little used. Who is

right? It is possible that both groups are; a given

service might be needed by a particular segment

of society, while the demand might still be small

compared with the demand of the total population.

Need may seem relatively easy to quantify in

the case of individuals with disabilities. Although

a precise count of such persons does not exist—

and the accuracy of such a count would be

questionable because of the definitions used and

the exclusion of temporary disabilities-the surveys cited earlier in this chapter present an

approximate range. However, there is as yet no

way to specify the frequency of supply required to

fulfill this need. While the passage of the ADA

requires that persons with disabilities eventually

have universal access to OTRBs, previous studies

have found that actual use of a new transportation

mode by a given group seldom correlates with the

behavior predicted in advance.36

Demand is the actual use of a service. Estimation of demand for transportation services requires data from the observed behavior of similar

consumers making similar choices of services

with similar attributes. In the case of accessible

OTRB service, which has been offered only in a

handful of demonstration projects, extrapolation

becomes difficult, more abstract, and less reliable.

Need almost always exceeds demand, and therefore complicates projections.37

Demand Estimation Methodology

Because of the many problems with extrapolating demand estimates from current usage figures

for both freed-route and charter and tour accessible service, OTA devised an alternative method to

estimate the demand for accessible service, using

both OTRB travel data available for the general

population and the numbers of persons with

disabilities in the total population. First, “trip

rates’ are calculated for both fixed-route and

charter and tour services. A trip rate is the average

number of fixed-route or charter and tour trips

taken by one person in the United States. These

36 Ecosome~cs, kc., op. cit., footnote 16, pp. 1-48 to 1-49.

ST Ibid., p. 1-49.
Demand for Accessible Over-the-Road Bus Service I 93

trip rates are then applied to total population

estimates of persons with disabilities to obtain the

number of trips that these persons might take.

Estimating Trip Rates for OTRB Services

OTA estimated the fixed-route intercity per

capita trip rate by taking the best estimate of U.S.

fixed-route ridership and dividing it by the total

population. Interstate Commerce Commission

data from the largest fixed-route intercity carriers

estimates 28 million passenger-trips in 1990. To

account for ridership on the smaller carriers, an

additional 10 percent was added to this figure for

a total of slightly less than 31 million. This

number was then divided by 249 million (the U.S.

total population, as estimated by the U.S. Bureau

of the Census) to obtain a national fixed-route

intercity trip-making figure of 0.125 trips perperson annually .38

Estimating a trip rate for charter and tour

service is problematic, because the nationwide

data on charter and tour trips are incomplete. To

ensure the greatest level of statistical confidence

possible, the annual number of charter and tour

trips in the United States was estimated in three

ways.

39 First, the statistical summary, Transportation in America, reported that in 1990, OTRBs

carried 322 million passengers. Subtracting the

31 million freed-route passengers leaves 291

million passenger-trips on charter and tour OTRB

services. Second, the 1983 American Bus Association (ABA) Annual Report estimated that 209

million passengers used charter and tour services

in that year, Assuming an annual growth rate of 5

percent, there would have been 294 million

passengers in 1990. Finally, ABA surveyed the

3,500 charter and tour firms. Of the firms that

responded, the typical firm may carry between

82,000 and 92,000 passengers annually, resulting

Persons with disabilities have family members or

friends who might travel with them.

in 287 to 322 million trips nationwide. Choosing

291 million trips as the best estimate and dividing

by the total population of the United States gives

an average per capita trip rate of 1.17 trips.

Adjusting for Differences in Travel Patterns of

Persons With Disabilities

The 1977 UMTA study is the only national

travel survey thus far to attempt todetermine the

travel characteristics of persons with disabilities.40 This study interviewed a sample of persons

with permanent or temporary disabilities, including those in institutions. It found that these

38 one fipo~mt note ~OnCem tie ~Ossiblli~ of developing different per capi~ tip rates for ~erent age grOUpS and for ~b~ versus rlld

populations. While such a breakdown of the national trip rate might be ideal, it is not feasible with the incomplete data avaiIable.

39 Ecosome&rics, Inc., op. cit., footnote 16, pp. 3-14 tO 3-15.

w Grey Advertising, “Technical Report of the National Survey of Transportation for Handicapped People,” prepared for Urban Mass

Transportation Adrninistratioq October 1978.
94 0ver-the-Road Bus Access

persons took 35 percent fewer recreational trips

than persons without disabilities. Most fixedroute and charter and tour passengers traveled to

visit family or for other social or recreational

reasons.

41 In accounting for how many trips they

would have liked to take, the survey found that the

overall trip rate for persons with disabilities

would be 15 percent less than that of persons

without disabilities if all transportation modes

were accessible.

Although this study argues for a lower trip rate

for persons with disabilities, considerable debate

exists about the likely travel patterns of persons

with disabilities on OTRBs if all such services

were accessible. Some researchers suggest that

trip rates for persons with disabilities must be less

than those for the general populace due to the

subpopulation of persons with disabilities who

have overall lower mobility, or due to the low

economic status of many persons with disabilities

(i.e., they could not afford the trip).

However, other researchers cite the high correlation of disabilities with age, lack of access to

automobiles, and lower incomes as a reason

persons with disabilities might have higher than

average trip rates.42 At the same time, escorted

tour trip rates may be higher due to the convenience of having a tour operator “scout ahead” to

determine the accessibility of the tour route.43 In

particular, older persons with disabilities who

also have higher incomes might avail themselves

of accessible charter and tour service. What is not

known is whether trip rates for persons with

disabilities will most strongly reflect certain

demographic characteristics, or the extent to

which having a disability is a characteristic that

overrides other factors.

Because of the conflicting analyses cited above,

the following calculations include no adjustments

for differences in the travel patterns of persons

with disabilities. Nor does the trip rate account for

additional travel by persons without disabilities

who can now accompany friends and family who

have disabilities onto OTRBs, a factor with potential to increase the estimated number of trips.

Calculating the Number of OTRB Trips by

Persons With Disabilities

To reiterate the demographic data above:44

●

●

●

●

●

●

●

●

1.4 million people use wheelchairs.

1.7 million people use walkers.

3.0 million people use any mobility technology devices,45

Up to 14 million people have hearing impairments.

4.0 million people use hearing technology

devices.

5.0 million people have sight impairments

that make independent travel difficult.

1.1 million people are legally blind.

0.3 million people use vision technology

devices.

These figures and the trip rates developed above

are used to calculate the number of trips taken by

persons for freed-route and charter and tour

41 Frederic D. Fravel, “Intercity Bus Passenger Profde,” paper presented at the Annual Meeting of the Transportation Research Board,

Washington DC, January 1985; and Greyhound Lines, Inc., “Greyhound On-Board Passenger Profile Survey,” unpublished document

August 1991.

42 Because of the lack of accessible OTRBS, travelers with disabilities have had to rely on other modes of transportation. For those who ~ve

traveled via other modes, the question must be asked as to whether they would switch to OTRBS. Since many persons with disabilities do not

drive and thus more remote locations are difilcult for them to reach the large network of stops served by OTRBS compared with other modes

of transportation may be an invaluable service to many persons with disabilities. With fixed-route bus semice as a low-cost alternative, it is

possible that low-income persons with disabilities will see accessible OTRB service as their best travel option. Remarks at Office of ‘Ikchnology

Assessment Workshop, “Building an Accessible OTRB Systew” July 15, 1992.

43 Ibid.

44 ~ese soups my overlap, ~Wuse some ~rsom may use more than one type of aid or WY have more ~ one ~d of di~bW.

AS TMS nu~r ~Cludes persons using crutches, walkers, wheelchairs, scooters, and other mobility equipment, but not perso~ us~g leg

braces and/or canes and walking sticks.
Demand for Accessible Over-the Road Bus Service 95

Actual demand for accessible service is difficult to

predict.

services. For fixed-route intercity service, if all

OTRBs were accessible today, total trips made

annually by persons with sensory and/or mobility

impairments might include the following:46

●

●

●

●

180,000 trips by persons using wheelchairs.

210,000 trips by persons using walkers.

380,000 trips by persons using any mobility

devices. 47

Up to 1.8 million trips by persons with

hearing impairments.

●

●

●

●

500,000 trips by persons using hearing

technology devices.

630,000 trips by persons with sight impairments that make independent travel difficult.

140,000 trips by persons who are legally

blind.

33,000 trips by persons using vision technology devices.

Similarly, for charter and tour services, total trips

made annually by persons with sensory and/or

mobility impairments might include the following..48

l

●

●

●

●

●

●

●

●

1.7 million trips by persons using wheelchairs.

2.0 million trips by persons using walkers.

3.6 million trips by persons using any

mobility devices.49

Up to 16 million trips by persons with

hearing impairments.

4.7 million trips by persons using hearing

technology devices.

5.9 million trips by persons with sight

impairments that make independent travel

difficult.

1.3 million trips by persons who are legally

blind.

0.3 million trips by persons using vision

technology devices.

These numbers are only estimates. Estimating

travel demand figures is notoriously difficult for

services that have not yet been introduced. Travel

preferences are often unique to the individual and

only experience with a particular transportation

46 me follo~g numbers do not include persons using leg braces or persons using canes or walking StiCkS, who might dso r~uire assismce,

especially in the form of a lower first step, in boarding OTRBS. OTA calculates the number of fried-route trips made annually by persons using

leg braces as 110,000 and the number of freed-route trips by persons using canes or walking sticks as 550,000.

48 me fo~~o~g ~U~rs d. not ~cludepersons us~g leg braces or pe~o~ Using canes or Wtig sticks, who might alSO K@e aSSiStlU103,

especially in the form of a lower first step, in boarding OTRBS. OTA calculates the number of charter and tour trips made annually by persons

using leg braces as 1.0 million, and the number of freed-route trips by persons using canes and walking sticks as 5.1 million.

49 ~s nu~r irlcludes persons us~g crutches, walkers, wheelc~s, scooters, ~d o~er mobfi~ equipment, but not persons USirig leg

braces and/or canes and walking sticks.
96 Over-the-Road Bus Access

system can give credible estimates of future travel

on that system.50

However, compared with the total number of

OTRB passengers, there is no doubt that the

annual number of additional trips by persons with

disabilities is likely to be small. These riders may

increase usage of OTRB services. But if the

provision of accessible service requires bus companies to raise rates, certain passengers who are

price sensitive may choose to ride other forms of

public transportation, go by automobile, or not

travel at all. Combined with the actual ridership

of passengers with disabilities, this change in

ridership might result in either a net increase or

decrease. Indeed, since the ridership of OTRBs

experiences large fluctuations for other reasons

(due to changes in the general economy and

points served by OTRBs), it will probably be

impossible to discern if changes in ridership are

due to accessibility requirements, even retrospectively.

SO Dem~d forecm~ rely heavily on previous usage da~+ (JCs. con~ess, Office of ~hnoIogy fkssessmen~ Airport system Development,

I OTA-STI-231 (Washington, DC: U.S. Government Printing Office, August 1984), pp. 159-185.
Accessibility

Technologies for

Over-the-Road

Bus Service 4

FINDINGS

. Level-change devices can assist persons with mobility

impairments in boarding and disembarking from over-theroad buses (OTRBs). As of late 1992, a number of

vehicle-based lift technologies were available for OTRBs,

and several such technologies were in the research and

development phase. The capital costs for the available

vehicle-based lifts range from $7,000 to $17,000. However,

the Office of Technology Assessment (OTA) found only

one station-based lift technology under development that

appeared likely to meet Americans with Disabilities Act

(ADA) standards (the cost estimate for this lift is $4,500).

OTA found no ramp technology under development that

would meet ADA standards.

. Bus modifications are necessary in conjunction with levelchange devices to accommodate wheeled mobility aids

onboard the bus. Modifications include wheeled mobility

aid tie-down positions, folding seating units, movable arm

rests, and an accessible door (modification costs are

estimated at between $5,000 and $7,000).

. Currently several securement and restraint systems are

available for persons using wheeled mobility aids on

OTRBs. However, further review of the relevant movement

standards is needed. In addition, OTA has not found any

securement technology that prevents excessive movement

by the wheeled mobility aid while also allowing the user to

secure and release him or herself.

97
98 0ver-the-Road Bus Access

●

●

●

OTRB manufacturers have developed two

accessible restrooms, ranging in price from

$5,000 to $35,000. Both result in a loss of

seating capacity.

At present, several technologies are available to assist persons with sensory and

cognitive disabilities. The U.S. Department

of Transportation (DOT) has issued lighting

and contrast standards, but these do not fully

address the communication needs of persons

with sensory and cognitive disabilities. Most

OTRBs have signage and public address

systems; these and additional features could

be used to meet the needs of persons with

disabilities.

Employee training is crucial for accessible

OTRB service. While few programs are

aimed at training OTRB company employees in the area of accessible service, several

transit company training programs could be

adapted for this purpose.

TECHNOLOGIES TO ASSIST PERSONS WITH

MOBILITY IMPAIRMENTS

This chapter describes current and potential

technologies to make OTRB service accessible.

These technologies can be classified into two

categories: 1) those that assist persons with

mobility impairments, and 2) those that assist

individuals with sensory or cognitive impairments. While sensory and cognitive disabilities

are very different, some technologies designed for

those with sensory impairments also serve people

with cognitive impairments. The chapter also

describes how employee training might improve

intercity bus accessibility.

Persons with mobility impairments can encounter a number of difficulties when using

current intercity bus service. These diffiiculties

include getting on and off the bus and using

onboard restrooms and terminal facilities, including ticket counters, boarding areas, and restrooms. Several technologies are currently available or proposed to address these problems. In

addition to methods designed for persons who use

wheeled mobility aids, other technologies assist

people with different types of mobility impairments.

Carrying

Carrying is the primary method by which bus

companies now assist travelers who cannot otherwise board an OTRB. One or more bus company

employees hoist a person up the steps of an OTRB

and into a passenger seat. Some bus companies

use a boarding chair, a specially designed wheelchair narrow enough to be used onboard an

OTRB. Passengers with disabilities are transferred on the ground from their personal wheeled

mobility aids to a boarding chair, carried up the

OTRB’s steps in the boarding chair, wheeled

down the aisle, and transferred again to a bus seat.

The cost of a boarding chair is estimated at

between $550 and $650.1

Most individuals who use wheeled mobility

aids find that being lifted and carried for boarding

or seat transfer is objectionable for reasons of

safety, privacy, and dignity. Carrying might also

be painful for people with certain disabilities,

such as multiple sclerosis. In addition, there is

risk of injury during the carrying process; bus

employees might drop someone or strain themselves. Such accidents are likely to lead to

increased workmen’s compensation, litigation,

and insurance costs. Since passengers must be

separated from their wheeled mobility aids, there

is also the possibility of damage to a wheelchair

or scooter that is stowed. Indeed, some are so

large and heavy that it is unclear where they might

be kept.2 If stored in the OTRB’s baggage

compartments, they might displace baggage or

package express items.

1 Randy Isaac, Isaacs and Associates, Cottontowq TN, personal communication August 1992.

z Lu~age ~omp~ents appm~ately 3 Ifl feet high are necessary to tr~port wheelcti without foldfig or di=sembM hem,

Scooters might require more space. Most luggage compartments are 33 1/2 inches higlL or less than 3 feet.
Accessibility Technologies for Over-the-Road-Bus Service 99

Ramp s

Ramps provide a smooth, gradual surface for

travelers to get from the ground into an OTRB.

The Architectural and Transportation Barriers

Compliance Board (ATBCB) considers a ramp

accessible if it has a slope no greater than 1 to 12,

or 12 inches horizontal for every 1 inch vertical

rise (see app. 4-A, which details current ATBCB

guidelines). This ratio allows most individuals

who can operate their own wheeled mobility aids

to wheel themselves up the ramp, and reduces the

danger that they will roll backwards. With sufficient vertical clearance at the bus entrance and

adequate grab rails, the ramp can also be used by

individuals with all sorts of mobility impairments, not just those using wheeled mobility aids.

As there are no mechanical or motorized parts in

a ramp, reliability primarily depends on the

strength of initial construction. Maintenance requirements are negligible, consisting mainly of

periodic inspections to make certain that all parts

are secure.

Ramps can be grouped into two categories:

transferable and station-based ramps, Greyhound

Lines, working with Handi-Ramp, Inc., of Mundelein, Illinois, has developed a transferable ramp

(see photograph). The ramp has a slope of 1 to 8

(which does not meet current ADA standards) and

is designed in five sections that can be disassembled and stored in the baggage compartment. The

ramp parallels the side of the bus, and is 30-inches

wide—too narrow to accommodate many

wheeled mobility aids. A railing is provided on

the side away from the bus, and the bus itself

serves as a restraint on the inner side. At the door

of the bus, the ramp is level with the passenger

seating deck. A “bridge” platform spans the

stairwell area entering the bus.3 Ramp assembly

time for two experienced operators could be less

Greyhound tested this ramp to board persons with

disabilities. It does not meet current ADA standards.

than 5 minutes, though a single unpracticed

operator might require as much as 20 minutes.4

Cost estimates for the Greyhound ramp range

from $3,500 to $4,500.5 Since the ramp design

does not call for modifying the bus to accommodate wheeled mobility aids, a boarding chair is

necessary. Given the difficulties stated above and

the requirement of a boarding chair, persons who

use wheeled mobility aids might not readily

accept such a ramp as a means of accessible

service.6

Station-based ramps remain at the bus station.

Prices for the several types of ramps proposed

range from $4,000 to $7,500, depending on the

construction materials. A problem with reliance

on station-based level-change devices is that

passengers with mobility impairments might be

unable to disembark at an unscheduled stop.

Although on-the-road breakdowns are not a

3 Econometrics, Inc., ‘ ‘Evaluation of Methods to Provide Accessibility to Over-the-Road Buses and Sewices,’ O’E4 contractor repo~ July

28, 1992, p. 58.

1 Isaacs, op. cit., footnote 1.

5 Randy Isaacs, director of State Government Affairs, Greyhound Lines Lnc., personal communication, Nov. 5, 1991.

b Remarks at OffIce of lkchnology Assessment Workshop, “Intercity Bus Access for Individuals With Disabilities,” Mar. 17, 1992.
100 0ver-the-Road Bus Access

regular occurrence, they are not uncommon. In an

emergency situation, if the OTRB were equipped

with a collapsible ramp and boarding chair, a

person with mobility impairments could more

easily and safely exit the bus or transfer to a

replacement OTRB.

Lift s

OTA workshop participants have indicated that

lifts in conjunction with bus modifications offer

the highest degree of user acceptance. Several

early generation lifts are currently used as boarding aids on intercity bus coaches. Lifts act as

either manual or powered level-change devices.

All lifts include a platform to raise and lower the

occupant, a barrier to prevent the wheeled mobility aid from falling off the platform, and some

form of side support for the user to grasp.

However, lifts vary in operating costs, maintenance needs, and the degree to which other

aspects of operation are automated (e.g., door

closing and opening, barrier operation, and stowage). Lifts mounted inside the bus occupy space

in the passenger area or the luggage compartment.

In order to maintain adequate headroom at the

door, some lifts displace overhead luggage space.

Depending on the coach configuration, lift users

may board the coach through separate entrances

located along the side or at the back of the coach.7

With appropriate vehicle modifications, lifts

allow individuals who use wheeled mobility aids

to board, ride, and disembark from coaches

without leaving their mobility aids. These bus

modifications include tie-down positions (discussed below), foldup seating units, and an

additional accessible door. Vehicle-mounted lifts,

because they affect the structural integrity of the

bus frame, can necessitate further structural

modifications. It is estimated that these elements

together constitute about $5,000 to $7,000 of the

cost involved in the installation of a lift. In some

cases, these bus modifications cause a loss of two

A passenger leaves an OTRB using an exterior-style

lift.

to four passenger seats when persons using the

tie-downs are onboard.

OTA has identified three types of lifts: vehiclebased, station-based, and transferable lifts. Vehiclebased lifts are the most common. OTA examined

six different vehicle-based lifts designed in the

United States and Canada and three from Europe.

Vehicle-based lifts are part of the bus and

therefore can be used at all stops. Some models

take up baggage space when stored, while others

reduce seating capacity. Electrical vehicle-based

lifts rely on power from the coach, allowing

operation only when the bus is running. However,

many models have emergency, manual pumps

that allow for independent operation. Cost estimates for powered vehicle-based lifts fall between $12,000 and $24,000, including vehicle

modifications.

Vehicle-based lifts have two basic styles,

“elevator” lifts and “exterior” lifts. Elevator

lifts operate within the bus; users access the lifts

T Transit bus lifts are usually at the front or middle entrances, so persons with wheeled mobility aids use the same doors as other passengers.

OTRB lifts often use separate entrances toward the rear of the bus.
Accessibility Technologies for Over-the-Road-Bus Service I 101

through side doors near the baggage compartments of the bus. Exterior lifts operate outside the

bus; users enter the lift outside the bus and are

raised to a door at the OTRB’s deck level.

Station-based lifts are located at passenger

terminals. OTA has found only one station-based

lift, and it is currently in the development stage.

Proposed by Adaptive Engineering Ltd. of Canada, the lift would be adapted from their Mobilift

Model 4P(291 lift currently used by Amtrak (see

photograph). The proposed lift is portable (although it currently cannot collapse to fit into a

baggage compartment); one person can roll it to

the side of the bus. It does not use either an

electric motor or hydraulic devices to raise the lift

platform, relying instead on a manual, handcranked cable lifting system. Maintenance requirements are minimal. Cost estimates for the

manually powered lift range from $4,000 to

$5,000, without bus modifications.8

Transferable lifts can be shifted from one bus

to another, In 1992, no transferable lifts were in

operation on OTRBs. The station-based lift discussed above could perhaps be adapted to fit in

the baggage bay of an OTRB, although it would

displace a considerable amount of baggage space.

To deal with this problem, Adaptive Engineering

has proposed a new type of transferable lift,

referred to as the ‘‘backpack” lift. The lift would

be housed on the back of the bus, above the bus’

rear bumper. When needed the backpack lift

would slide along rails to the accessible side door.

Before such a lift could be developed, however,

several design problems must be solved, including: a method for negotiating the lift around the

comer of the bus; a casing that protects the lift

from harsh road and weather conditions; and a

way to quickly and easily move the lift to allow

engine maintenance. Because transferable lifts

This station-based lift, while designed for use on rail

systems, may be adapted for OTRBs.

are still only a proposed technology, no reliable

cost estimates exist.

Some current lift designs pose problems for

persons who use aids such as canes and crutches.

Often, doorposts and other barriers are too low to

allow these travelers to stand while exiting the

lift, requiring them to crouch or duck in order to

avoid bumping their heads, Therefore, the doorway must be high enough to accommodate these

passengers. Some manufacturers have also added

features to their lifts that would allow users to sit,

rather than stand, during operation.

Data on the reliability of lifts is hard to come

by, primarily because the technology has been

employed in only 350 buses in the United States,

most of which use early generation lifts.9 However, some information is available from demon8 Endre Pataky, export manager, Adaptive Engineering Ltd., personaI communication, July 1992.

9 Experience with lifts indicate that they are becoming more reliable with each sueeessivc generation. Manufacturers are ironing out

problems, determining maintenance requirements, and standardizing the production process. In addition, bus drivers are learning better how

to operate the lifts.
102 0ver-the-Road Bus Access

stration projects in Canada and experience in the

United States (see ch. 3). Not surprisingly, different types of lifts have different reliability

records. In general, the simpler the design, the less

that goes wrong. Some lifts seem to be plagued by

high maintenance costs and extended downtime,

especially early generation elevator-style lifts.

Others simply require routine checking of fluid

levels. Reliability may be affected by exposure to

road and harsh weather conditions.

Driver inexperience in operating the lifts can

also lead to problems. The driver assumes several

responsibilities, including communicating with

individuals with a variety of impairments, operating the lift, and in some cases fastening the

securement and restraint system once the passenger is inside the coach. (Related training is

discussed later in this chapter). In some demonstration projects, drivers operated the lifts only a

few times each year. Because of their limited

experience with the lift, many drivers had difficulties recalling the correct procedures.

Securement, Restraint, and Other Issues

A requirement common to all accessible OTRBs

is the provision of adequate space for wheeled

mobility aids, and restraint of the mobility aid and

passenger, inside the bus. Securement systems

must restrain the wheeled mobility aid’s movement so that it does not break free or collapse and

injure someone or sustain damage itself. l0

Wheeled mobility aids that are not properly

secured during an accident or even normal driving

conditions (e.g., during fast turns or quick braking) pose serious risks to both the occupant and

other passengers. The ATBCB Americans With

Disabilities Act Accessibility Guidelines for

Transportation Vehicles call for securement sysDrivers must often assist passengers securing their

wheelchairs.

terns on vans and transit buses to limit the

movement of wheeled mobility aids to no more

than 2 inches in any direction under normal

vehicle operating conditions.11 However, because

intercity coaches often travel at faster speeds than

transit buses and vans, a stricter standard might be

necessary.

Securement system design is complicated because there are over 500 different types of

wheeled mobility aids.12 (For a drawing of a

typical wheelchair, see figure 4-l.) Common

issues facing designers include:

●

●

●

Wheeled mobility aids are not meant to take

stress from the directions that restraint systems might impose;

Three-wheeled scooters have different stability characteristics from conventional fourwheel designs;

Wheelchairs and scooters have a variety of

wheel designs with differing thickness, diameter, and spoke characteristics, making it

difficult to design a uniform wheel clamp;

10 Because ~hwl~ mobi~~ aids are not desi~~ to be used as intercity coach seats, they are susceptible to -ge dfig severe fivfig

conditions. Norman Littler, coordinator for Regulatory Relations, MCI, personal communication Aug. 19, 1992.

I I 56 Federa/ Regi~ter 4ss40 (Sept. 6, 191), ~c~t~~~ md Tr~po~tion Barrias cornplim~ Board, Americans With Disabilities

Act Accessibility Guidelines for Transportation Vehicles; Final Guidelines, 36 CFR Part 1192, Sub Part B, 1192.23 (5).

12 Ka~cMe H~tfl.~wo~S~, assls~t professor, Tr~po~tion ~titute, ~egon s~te Univers@, personal communication, Dtx. 14,

1991.
Accessibility Technologies for Over-the-Road-Bus Service I 103

Figure 4-l—Typical Wheelchair Dimensions

- ‘w\-

0

m

4

48” minimum (1 220 mm) 4

I

(measured at 2 in (50mm) I

above platform surface)

om

28 1/2” minimum (725 mm)

at platform

t

(measured at 2 in (50 mm) f

above platform surface

SOURCE: 56 Federal Register 45576 (Sept. 6,1991 ), Architectural and Transpiration Barriers Compliance Board, Americans With Disabilities Act

Accessibility Guidelines for Transportation Vehicles; Final Guidelines, 36 CFR Part 1192.

●

●

●

●

Opinion is split on whether the person

should be secured as well as the wheeled

mobility aid and whether they should be

secured together or separately;

The ideal securement system would allow

for quick entry and exit, preferably allowing

the user to operate the system without

assistance;

Some travelers with disabilities cannot secure themselves, regardless of system design; and,

Passengers and drivers are sensitive about

violations of their personal space, as might

occur when the driver must assist in the

securement procedure.

Thus, it is difficult to develop a securement

system that can adapt to all types of wheelchairs

and scooters and is acceptable to all users and

drivers. OTA has not found any securement

systems that both adequately limit wheeled mobility aid movement and enable the user to

restrain and release him or herself.

Currently, there are two main types of securement devices: the belt design and clamp design.

In 1992, urban transit service and accessible

OTRBs used both systems. Belt systems are

usable on the majority of wheelchairs and have

proven crashworthy. Crash tests conducted on the

Q-Straint belt design securement system have

shown that in crashes of up to 20gs, wheelchairs

moved less than 4 inches .13 However, drivers who

are not properly trained or do not use the system

routinely might require as much as 15 minutes to

secure a wheeled mobility aid and still might not

13 h addltio~ tie Q.straint system meets tie ATBCB re@rement that chairs not move more than2 inches under nOrm~ fiving conditio~.
.

104 0ver-the-Road Bus Access

secure it properly.

14 The Q-Straint belt securement system costs approximately $400 per unit.15

The clamp securement system uses a clamp

that locks onto the rear wheels of the mobility aid;

the front is fastened with straps. The advantage of

the clamp system is the ease of attachment,

allowing some persons with mobility impairments to secure themselves.l6 Clamp systems do

not work on all types of wheeled mobility aids,

however, because of the varied widths of wheels.

In addition, mobility aid wheels are not as strong

as the frames, and therefore run a higher risk of

collapsing during a crash.

One proposed solution to the problem of

diversity among wheeled mobility aids is the use

of a uniform attachment device. The device could

be fastened to a wheeled mobility aid in order to

make it compatible with a standard securement

device inside the bus,17 reducing the time needed

for securement.18 To maximiz e user acceptance,

any add-on feature should be inconspicuous,

simple, and inexpensive.l9

A separate but related issue is the securing of

the passenger. Many wheeled mobility aids do not

offer as much back, neck, or head support as

intercity bus seats, which are taller and provide

headrests. In an accident in which an individual’s

head is snapped backward, people seated in

wheeled mobility aids might be more likely to

sustain neck or head injuries. Furthermore, some

people with disabilities might not be able to use

their arms to protect themselves in a crash.20 All

securement systems examined by OTA provide

optional restraint devices, such as lap and shoulder belts, but no means of supporting the occupant’s head and neck.

Technologies for Persons Not Using

Wheeled Mobility Aides

There are several coach enhancements that can

improve the accessibility of OTRBs for persons

who have mobility impairments but do not use a

wheeled mobility aid. Many of these enhancements are already required by DOT.21 (For an

overview of current accessibility regulations, see

box 4-A.) These include slip resistance standards

for aisles, steps, and floors; knuckle clearances

for hand rails; lighting and contrast standards; and

minimum door widths. The 32-inch-wide door

allows a male at the 95th percentile in height

using two crutches to enter.22

Another necessary modification would be the

installation of foldup arm rests, allowing people

with mobility impairments who do not use

wheeled mobility aids easier access to OTRB

seats. Other modifications currently offered on

OTRBs include retractable first step and kneeling

features. A retractable first step reduces the step’s

14 WIMm Bauer, ~x=utlve director, Clevekd, Otio Services for Independent Living, personal communication, Aug. 18, 1992.

15 Dave Kessler, manager of Bus Bidding, Flxible Corp., personal communication% Aug. 18, 1992.

lb me ~divid~ cm back tie wheeled mobility aid into the clamp, which automatically locks, and then ftlsten the frOnt smps.

IT Ka~erine M. Hunter-~worsfi, Transportation btitute, oregon State university, “OSU Offers ‘Trailer-Hitch’ Approach to Solve

Securement Problems, ” Project ACTION Update, National Easter Seals Society, fall 1991, pp. 4-5.

18 A ~fom at~c~ent Ca ~ us~ ~ Conjmction wi~ bo~ he belt ad c]~p securement systems. The Services for Independent Living

in Cleveland is developing a clamp-style securement system that uses a universal attachment. The system has held a wheelchair to within 1

1/2 inches in a 20g test collision.

19 Wlfim Bauer, exwutive director, Services for Independent Living, Clevelmd, OH, ‘‘Project Develops Prototypes of Self-Securement

Systems, ” Project ACTION Update, National Easter Seals Society, fall 1991, p. 6.

ZO BaUer, op. cit., foOElote 1A.

21 S(j Federa/ Regisler 45771 (Sept. 6, 1991), Purt 38, Subp~ G, Sec. 151-157.

22 It is Motor Coach ~dusrnes Limited’s position tit a~ommo~ting tie 32-inch s~dmd co~d require moving the pdk behind the door

rearward, forcing the front axle rearward, displacing air conditioning equipmenc and forcing mcontlguration of the front third of the bus in

order to maintain proper axle loading, pavement wear, and other operating characteristics. Joseph M. Dabrowski, vice president for Engineering,

Transportation Manufacturing Corp., personal communication Mar. 17, 1992.
Accessibility Technologies for Over-the-Road-Bus Service I 105

Box 4-A-Current Bus Accessibility Regulations

In 1991, the U.S. Department of Transportation (DOT) issued rules under the Americans with Disabilities

Act (ADA) regulating accessibility standards for publicly owned and operated transit buses, privately owned and

operated over-the-road buses (OTRBs), and privately owned OTRBs operated under public contract.

The regulations governing transit buses cover:

● doors, steps, and thresholds,

● priority seating signs,

● interior circulatiion, handrails, and stanchions,

ž lighting,

● fare boxes,

. public information systems,

. stop requests, and

. destination and route signs.l

In addition, the regulations included a mobility aid accessibility section, mandating that transit buses provide

a‘ ‘level-change mechanism or boarding device. ” The regulations state:

All vehicles covered by the subpart shall provide a level-change mechanism or boarding device (e.g.,

lift or ramp) complying with paragraph (b) or (c) of this section and sufficient clearances to permit a

wheelchair or mobility aid user to reach a securement location. At least two securement locations and

devices, complying with paragraph (d) of this section, shall be provided on vehicles in excess of 22

feet in length.2

Regulations controlling privately owned and operated OTRBs took effect in 1991. These regulations

apply to doors, steps, and thresholds; interior passenger circulation, handrails, and stanchions; and lighting. 3 In

addition, they mandate that OTRB operators provide accessible service and arrange for a passenger with

disabilities to be carried aboard if no other type of boarding aid is available. OTRB operators may require up to

48 hours advance notice for providing boarding assistance.4 These regulations maybe augmented after DOT

review of this study. Regulations governing boarding aids have yet to be formulated. DOT will issue boarding

aid regulations after review of this study, and these regulations will take effect in 1996 for large bus companies

and 1997 for small bus companies.5

One exception to the regulations covering OTRBs applies to publicly owned OTRBs and privately owned

OTRBs under contract to a public entity. These OTRBs must comply not only with the regulations governing

privately owned and operated OTRBs, but also with the mobility aid accessibility rules regulating transit buses,

i.e. they must provide a boarding aid such as a vehicle-based lift or rarnp.6

156 FederaJRe@ter 45757-45760 (Sept. 6, 1991), U.S. Department of Tmnsportatiou T_~tionfor ~vid~

with Disabilities; Final Rule, Part 38, Subptul B.

2 ~id., SeC. 38.23, paragraph (a)”

356 F~era/Register 45771 (sept. G, 1991), u+s. Dep~~t of ~po~tio~ Transportation for Individual ~(h

Disabilities; Final Rule, Part 38, Subpart G.

456 Federa/Regisrer 4564045641 (Sept. 6, 1991), U.S. Department of Transportation, TmP~tion for ~~vidu~

with Disabilities; Final Rule, Part 37, Subpart G, Sec. 37.169.

5 Federa/ Regi~ter, ~p, Cit., footno~ 30 ~~esid~t cm delay @l~en@tion of -h @ of ftiN@dOflS fOr ~

year.

656 Fed~a/Register45626 (Sept. 6, 1991), U.S. ~p~ent of T~po~(io~ Tqrtation for Individuals fith

Disabilities; Final Rule, Part 37, Subpart A, Sec. 37.23, paragraph a; and 56 Federal Register 45625 (Sept. 6, 1991), U.S.

Departrrient of Transportation, Transportation for Individuals with Disabilities; Final Rule, Part 37, Subpart A, Sec. 37.7,

paragraph c.
106 0ver-the-Road Bus Access

height to approximately 8 inches, down from 16

or 17 inches.23 Kneeling options reduce the frost

step height by 3 to 5 inches. In addition, some

OTRBs carry a step box, which adds an additional

step. Without reductions in step height, many

persons who could otherwise climb steps cannot

board.

Aisle width is another possible obstacle. The

standard 14-inch aisle width accommodates only

certain boarding chairs and imposes severe restrictions on users of walkers, crutches, or canes.

Given exterior coach width limitations of 96 or

102 inches, however, increasing aisle widths

along the entire length of the coach would almost

certainly reduce seating capacity.

Accessible Restrooms

The authors of the ADA were uncertain about

the availability of accessible OTRB restrooms or

the feasibility of designing one without incurring

a significant loss of seating capacity. Restroom

access will be necessary if OTRB service is to be

truly accessible, and some manufacturers have

begun designing onboard accessible restrooms.

OTA has identified two accessible restroom

designs. One design is currently available as an

option on some Neoplan coaches.24 Like most

conventional restrooms, it is on the same level as

the passenger deck, in the back of the bus. The

Neoplan design differs from a conventional

restroom in that the dimensions are slightly

larger. The accessible restroom permanently displaces three seats and requires the narrowing of

one seat by 3 inches. The location of the lift

entrance is a few feet forward of the restroom, so

that persons who use wheeled mobility aids need

only back a short distance to the restroom

entrance. The Neoplan’s dimensions provide just

As of early 1993, all accessible OTRB restrooms

displace passenger seating.

enough clearance to allow a wheeled mobility aid

to enter, and use of the toilet requires a relatively

agile passenger. The estimated cost for Neoplan’s

accessible restroom is roughly $5,000, which can

be compared with the price of a nonaccessible

restroom at $3,300.25

The other accessible restroom is a prototype

developed by MCI and installed on its 45-foot

demonstration coach. Developed in conjunction

with MCI’s 4-Link lift, the restroom and the lift

are fully integrated. A movable partition separates the two so that the space needed for entering

the coach from the lift is borrowed from the

restroom as needed. The lift entrance is located

behind the rear axle. The restroom takes up the

entire width of the coach and is quite spacious

compared to the Neoplan design. Ample room,

handles, and grasps inside the restroom provide

for maximum maneuverability and a wide range

of agility. Seven seats are lost with the lift and

accessible restroom. A potential operational problem is that the toilet is mounted on the left side of

23 ~ ~s~huse~, Smte utii~ rqgdators orderexj the retractablefwst steps on State-assisted buses deactivated because the additional width

of the deployed step caused the bus width to exceed the State regulations. As of early 1993, it was unclear whether these regulations are still

were in effect for OTRBS.

U Neoplan is a German manufacturer of OTRBS, with facilities in Colorado.

~ ~temiew with &ey F. Diclq senior vice president of Operations, Neoplan USA Corp., NOV. 21, 1991, in fiosometrics, ~c., op. cit.,

footnote 3.
Accessibility Technologies for Over-the-Road-Bus Service I 107

the coach, rather than the right, as is customary.

Many dumping stations can accommodate only

the conventional right rear restroom location.26

MCI has estimated that a 45-foot coach with the

lift and restroom package would cost $50,000

more than a standard 40-foot coach,27

One problem with accessible restrooms is that

the person using the wheeled mobility aid must

release the tie-down restraints, either back up or

turn to gain entrance to the restroom, and open the

door. Undoing the restraints might be impossible

for the passenger, requiring the aid of the driver

or an attendant. If the driver is called on, the bus

must be stopped.

Reservation Systems

One approach to ensuring accessible service is

to have persons with special needs notify bus

companies in advance of their desire to travel.

Technologies that could be helpful include:28

●

●

●

●

24-hour telephone or modem lines for reservations and information;

automatic vehicle location systems to provide bus location information to fleet management;

electronic databases for geographical, scheduling, and fare information;

computerized methods for fleet routing and

dispatch; and

. two-way voice or data

tween vehicles and the

communications

dispatch center.

beAs of early 1993, few intercity bus companies had

reservation systems. In 1991, Greyhound began

the first stage of a computerized fleet allocation,

passenger reservation, and yield management

system.

29 The new system will allow customers to

call the 200 largest Greyhound stations to reserve

tickets for specific times and dates, and to receive

fare and schedule information for Greyhound and

all interlining carriers. In addition, customers will

be able to pick up tickets at non-Greyhound

locations, such as convenience stores, or receive

tickets through the mail.

Other intercity bus companies use less sophisticated reservation systems. Martz Trailways in

Pennsylvania, for instance, maintains a noncomputerized reservation system. Users telephone

one of six locations to reserve bus seats. Bus

employees record their name and bus seat on a

standardized form. Approximately 80 percent of

the company’s regular riders use the reservation

system .30

Reservation systems could be used by individuals with disabilities to alert bus companies that

accessible service will be necessary. However,

under the ADA, bus companies cannot require

26 Ibid., p, 145.

27 Ibid., p. 145.

28 pma~~sit operators and public and private transportation fleets already use many of these technologies, but tiey Mve not yet spread to

intercity bus service.

29 The fleet allocation portion of the system allowed Greyhound to more efficiently schedule its bus fleet through an increased use of ‘hubs

and spokes’ and the identification and elimination of unprofitable routes and schedules. Greyhound targeted the passenger reservation and yield

management portion of the system to be implemented by mid-1993. Greyhound Lines, Inc., Greyhound Company Newspaper,

January/February 1993. The yield management portion of the system should enable Greyhound to monitor reservation levels on a real-time

basis and, depending on those 1eveIs, increase or decrease the number of discount and fulI fares available on spectilc schedules in order to

maximize revenues, re-route passengers when seat availability is restricted, and generate logs that list inbound and outbound passengers by

name.

313 Fr~ Hew, p~sident, J%* Martz Coach Co., personal communication, June 1992.
108 I Over-t he-Road Bus Access

persons with disabilities to use a reservation

system if persons without disabilities are not also

required to do so31 (see ch. 1). In addition, if and

when reservation systems are widely used, fleet

personnel must be carefully trained to ensure

proper coordination of equipment and schedules,

particularly when more than one carrier is involved.

TECHNOLOGIES TO ASSIST PERSONS WITH

SENSORY AND COGNITIVE DISABILITIES

Technologies for people with sensory and

cognitive disabilities are aimed at delivering

information to people who otherwise might have

difficulty receiving it. People with vision or

hearing impairments might have trouble reading

signs or hearing instructions. People with cognitive impairments might have difficulty making

decisions about which bus to board or where to

get off. Several of these technologies serve

individuals from both groups.

OTA has found that relatively little technology

is being developed specifically to assist persons

with sensory and cognitive disabilities to use

OTRBs. A wide range of specialized equipment

is under development for urban transit operation,

and much of it could be applied to OTRBs.

However, urban and intercity bus service differ in

many ways, so all technologies might not apply

equally. Some advantages for intercity service are

that freed-route intercity bus tickets are always

bought from a ticket agent or driver rather than

through a machine, tickets are printed with

origins and destination, and these tickets are

collected and examined by the bus driver. These

This sign at the National Zoo in Washington, DC

combines large graphics, color-coding, and pictures

to direct visitors to the exhibit.

practices provide a check to ensure that individuals with sensory or cognitive impairments get on

the proper bus, and get off at their destination.32

Signage

DOT requires the use of accessible signage in

buildings and facilities, including bus stops and

terminals (see figure 4-2).33 Signage, both on the

bus and within stations, can help people with

sight, hearing, and cognitive impairments. Large

31 spec~ic~y, Section 302@)(I)A of tie ADA p~hibits deniat of full and equal enjoyment of goods, Sink% faci~ties md Privilege%

advantages, or accommodations. This section is made applicable to OTRB operations by Section 304(b)(2). In addition, Section (304)(b)(l)

prohibits a private entity that is primarily engaged in transporting people from discrimina ting, including establishing eligibility criteria that

screens out persons with disabilities from full enjoyment of the transportation service. Thus, if the reservation system is the sole means for a

disabled passenger obtaining transportatio~ it would not be permitted under the ADA.

32 EcOsOme~cs, Inc., op. cit., footnote 3, p. 33.

33 DOT re~atiom ~clude ties on c~cter Propofio% character hcigh~ rai~d and br~c charact~s ad pictorial Symboh signs, ftish

and contrast, mounting location and heigh~ and symbols of accessibility. 56 Federal Regisfer (Sept. 6, 1991), Department of Transportation

Transportation for Individuals With Disabilities; Final Rule, Appendix A to Part 37—Standards for Accessible Transportation Facilities, p.

53,4.30.04.30.7.
Accessibility Technologies for Over-the-Road-Bus Service I 109

and more extensive signs, high contrast signs, and

tactile maps (i.e., maps that can be read like

braille) can present information to people with

disabilities. Placement of braille signs in uniform

locations within stations might make it easier for

individuals with vision impairments to locate

them. Simplifying signs, and using pictures and

symbols where feasible, might specifically aid

people with cognitive disabilities.34 In addition,

color coding signs, maps, tickets, buses, and

stations might make it easier for all people, but

especially those with certain cognitive impairments, to follow instructions.

Public Address Systems

DOT requires that transit buses in excess of 22

feet be equipped with either a driver-operated

public address system or recorded or digitized

human speech messages, to announce stops and

provide other passenger information within the

vehicle. 35 People with vision and cognitive disabilities might benefit from this technology, as

well as individuals with limited hearing impairments. Public address systems could be used both

onboard the OTRB and within bus stations.

OTRBs generally include public address systems

as standard equipment, so a new requirement

would not necessarily result in increased costs.

An external speaker would require modifications,

but the costs would be minimal.36

Telecommunications Devices

for the Deaf (TDD)

TDDs serve as telephones for individuals with

hearing impairments by allowing users to send

and receive written messages. Presently, ATBCB

guidelines for new stations mandate that if bus

stations house interior pay phones, there must

Figure 4-2—Symbols of Accessibility y

Proportions for

International

symbol of

accessibility

Display

conditions

International

symbol of

accessibility

International

TDD symbol

International

symbol of

access for

hearing loss

KEY: TDD - telecommunication device for the deaf.

SOURCE: 56 FederalRegister45697 (Sept. 6, 1991), U.S. Department

of Transportation, Transportation for Individuals With Disabilities: Final

Rule, 49CFR Part 37, Appendix A to Part 37—Standards for Accessible

Transportation Facilities.

34 Shl (+]w, h~~ste~, Ivymount School, person~ cornrn~catio~ Aug. 5, 1W2.

3556 Federal Regl$(er 45760 (Sept. 6, 199 1), us, Dep~ent of Transpor~tion, Transpo~tion for Individuals with Disabilities; Find

Rule, Part 38, Sub Part B-Buses, Wns and Systems, Sec. 38.35, Public Information System.

36 Co5t estfiatc5 for ~ onbo~d publlC ad&ess system rmge from between $150 to $300, not ~cluding installation. M~ Fran Kelly,

executive specialist, Midwest Electronic Industries, Inc., personal communication, Aug. 28, 1992.
110 0ver-the-Road Bus Access

TDD equipment enables persons with hearing

impairments to use the telephone.

also be at least one interior public TDD. 37

Furthermore, the ADA requires telecommunications companies to provide telecommunications

relay services for persons with hearing and speech

impairments. 38 Individuals with hearing and

speech impairments will therefore be able to call

bus companies for information on services.

Crawling Messages and Video Monitors

Crawling messages-electronic signs that

scroll information across a screen-and video

monitors, similar to those currently used in

airports, might also display messages or scheduling information within bus terminals. ATBCB’s

guidelines mandate that if public address systems

are offered to convey information, a means of

conveying the same information to persons with

hearing impairments must be provided.39 This

provision could be satisfied at least partially

through employees who are trained to communicate with persons with disabilities.

Other Technologies

Closed circuit television (CCTV) and computer magnification systems enlarge printed information so that it can be read more easily. These

systems might be employed in bus stations to

magnify system maps or other schedule information. Cost estimates range for CCTV from $2,300

to $3500. Computer magnification systems, which

consist of hardware and software to magnify

information on computers, add approximately

$3,000 to the price of a personal computer.

However, in the use of computer magnification

systems, the user still must ask an agent for

information, wait while it is called up, and

remember it. As long as ticket agents are available

to provide this kind of verbal or written information, the advantages of CCTV/computer magnification appear limited.40

Assistive listening devices (ALDs) help individuals hear speech in group situations, where the

combination of background noise, distance, and

poor acoustics make it difficult to distinguish or

understand speech. ALDs consist of a transmitter

carried by the driver and a receiver carried by the

user. There are basically three types of ALDs:

induction loop systems, narrow-band FM sysJY 56 Federa/Register (Sept. b, 19$)1), U.S. Department of Transportation Transportation for Individuals With Disabilities; FM Rule, pm

37, Sec. 10.3 (12)(a).

J13 WIWommu~catiom relay semices are telephone transmission sewices that enable individuals with hearing or speech impairments to

communicate by wire or radio in a manner that is functionally equivalent to communications by an individual who does not have a hearing

or speech impairment. Public Law 101-336, Sec. (401)a.

3956Federa/Register (Sept. 6, 1991), U.S. Department of Transportation Transportation for Individuals With Disabilities; FiMI Rule, pm

37, Sec. 10.3 (14).

~ Ecosome~cs, Inc., op. Cit., footnote 3, p. 35.
Accessibility Technologies for Over-the-Road-Bus Service I 111

terns, and infrared.41 Cost estimates for ALDs

range from $300 to $5,000, depending on the type

of technology used and the number of receivers

carried on the bus. A potential operational problem involves issuing, retrieving, and electrically

charging the receivers.42

TRAINING TO FACILITATE ACCESSIBLE

SERVICE

Proper training of bus company employees is

an essential part of accessible service, and is

already required by DOT. Employees must be

able to interact with passengers and operate

accessibility equipment.

The OTRB industry thus far has directed little

effort toward creating accessibility training techniques or materials.43 It is quite possible, however, that the industry could adapt the experiences

and programs of the public transit industry in

developing their own accessibility training courses.44

Many urban transit systems use training programs

that include information on facilitating accessible

service. These programs instruct drivers and other

employees on ADA requirements, passenger

assistance methods, lift operation, and sensitivity

training. The Denver Rapid Transit District, for

example, has a full day of training on these issues,

as does Seattle Metro.

Plymouth & Brockton is one of the few private

OTRB firms with an accessibility training program, partly funded by the State government.

Plymouth & Brockton is a private firm located in

Plymouth, Massachusetts, operating intercity,

commuter, airport, and charter and tour services.

Their accessibility training program lasts 7 to 8

hours and is one component of a larger employee

training course that takes 40 to 60 hours. The

training includes classroom, video, role playing,

and hands-on instruction in operation of the

vehicle-based MCI lift and separate securement

system, as well as some sensitivity training. All

employees who might come into contact with

either lifts or persons with disabilities take the

course. It seldom takes more than 20 to 30

minutes to teach a bus driver how to operate a

given lift and securement system.45 In addition,

bus drivers carry their own resource manual, with

sections on lift trouble-shooting, operation of the

lift, lift load limits, emergency situations, safety,

and sensitivity.46

Although it falls on the transit authorities and

bus companies to develop their courses,47 most

lift manufacturers supply operating instructions

in the form of written or video materials to bus

companies, and some lift manufacturers train bus

company mechanics. For example, Lift-U conducts 8-hour training sessions to teach bus

company mechanics lift terminology theory o f

lift operation, and how to use the manual.48

Sensitivity training teaches operators to help

individuals with disabilities in a way that affirms

the dignity of the person being assisted.49 TrainZI I The o~y ~own im~]latlonofm assistivc listening device onboard an OTRB was by MCI. In 1986, MCI installed aFM system pmhsed

from Telex Communications, Inc., on two MCI MC 102A3 coaches for Charterways, Inc. MCI found that the technology worked

well.

42 Econometrics, Inc., op. cit., footnote 3, pp. 38-41.

43 Ibid., p. 161.

4-4 However, Spwlal attention mu5t be paid to the differences between transit and OTRB company employee respomibdities. ~vate Om

employees perform many of the inforrnatiou ticket-selling, and personal assistance functions. Therefore, unlike its counterpart in the transit

industry, OTRB employee training must reflect these added responsibilities.

45 R1c~d Sumers, Division A, Soutiem Califofia Rapid Transit Dis~c~ person~ communication, Aug. 21, 1992.

46 Jo~ Greeq plymou~ & Brockto~ personal communication, Aug. 20, 1992

w Joe pine, customer service representative, Lift-U, personal comrnunicationi Aug. 21, 1992.

48 Ibid.

49 Econometrics, Inc., op. cit., footnote 3, P. 166.
112 0ver-the-Road Bus Access

ing programs begin with information on different

disabilities and their effects on the individual’s

ability to use bus service. The programs aim to

develop bus drivers’ understanding of individual

needs. These programs are often run for transportation operators by disability groups, to familiarize bus employees with people with disabilities.

Some programs help drivers experience situations

like those a passenger with a disability might face.

For example, trainees in Denver are taken downtown, blindfolded, and given the task of locating

a certain bus and getting to a destination. Other

programs place trainees in a wheelchair and

assign them a particular bus trip, While these

experiences do not replicate those of persons with

disabilities, they increase sensitivity.

For OTRB service to be accessible, tour guides,

station staff, ticket clerks, commission agents,

telephone information staff, and dispatchers must

be trained in ADA requirements and company

policy for meeting those requirements.50 Charter

and tour operators will require especially rigorous

training. The bus operator, in addition to having

to deal with the level-change and securement

systems, might be called on to assist people

moving around at the destination and at rest stops.

In addition, charter and tour drivers will most

likely deal with persons with disabilities for

longer periods of time, and might need to assist

several individuals simultaneously.51

One problem identified in OTRB accessibility

demonstration projects is that drivers who infrequently use accessibility technologies forget their

training and have difficulty recalling procedures.

Periodic refresher courses could alleviate this

problem. Most current transit programs require

refresher training of at least 6 hours once every 3

years, to cover changes in requirements and

technologies. 52 Another approach is to have

drivers regularly operate the lifts. This prevents

operators from forgetting how to use technology

and ensures the technology is functioning properly. 53

Another aspect of accessibility training is user

training. Persons with restricted mobility might

be more comfortable trying bus travel if they

know what to expect. A number of user training

programs have been developed and implemented

by urban transit systems, several under Project

ACTION.54 These programs are often run with a

local Center for Independent Living, rehabilitation center, or other local disability group.55 For

example, Plymouth & Brockton has conducted

some user training in conjunction with the Massachusetts Coalition for Citizens With Disabilities.

Training included informing participants as to

how drivers are trained, demonstrating how the

lift functions, and explaining the lift’s safety

features. 56 Alternative training strategies might

be considered for OTRB service, including video

or individual onsite training for persons who have

expressed an interest in using the bus. However,

user training could not under any circumstances

be a prerequisite for travel on an OTRB.

5° Ibid., p. 168.

51 Ibid., p. 164.

5

2 Ibid., p. 167.

53 Job Wfiti, dir~tor, MaSSa~huSetts c~~tion of cit~e~ Witi Dimbdities, perso~ COmmu13iMtiOq Aug. 6, 1992.

54 ~ojwt A~ON ~tmd5 for A~essible CoIUIUUU@J Transportation In Our Nation. The project, f~ded by tie Feder~ T~sit

Administration and managed by the National Easter Seals, was created to enhance relations between tmnsit providers and individuals with

disabilities.

55 Ecosome~cs, hlc., op. cit., footnote 3.

56 Beverly Stew- s~e~ supervisor, Plymouth and Brockto~ personal communication, Aug. 21, 1992.
Appendix 4-A:

T

he U.S. Department of Transportation (DOT),

in the Americans With Disabilities Act Accessibility Guidelines for Transportation Vehicles,

reserves decisions on the standards for mobility aid accessibility pending the outcome of this OTA

study. However, DOT regulations require that over-theroad buses purchased by public transit entities or

operated under contract to public transit entities (under

certain circumstances) comply with mobility aid

accessibility requirements for transit buses. This appendix summarizes the regulations governing vehiclebased lifts, vehicle-based ramps, and onboard securement systems.

Requirements for

Vehicle-Based Lifts,

Ramps, and

Securement Systems

Vehicle-Based Lifts

●

●

●

●

The lift shall be designed to support a load of at

least 600 pounds.

The lift platform shall be equipped with barriers

to prevent a mobility aid from rolling off, and the

platform shall not bend more than 3 degrees when

loaded with 600 pounds.

No part of the platform shall move at a rate

exceeding 6 inches per second while lowering or

lifting an occupant, and shall not exceed 12 inches

per second while deploying or stowing (even if

the power or equipment fails).

Platforms on lifts shall be equipped with handrails

on two sides, and the platform surface shall be

slip-resistant.

●

●

●

●

●

Lifts shall accommodate persons using walkers,

crutches, canes, or braces, or who otherwise have

difficulty using steps.

The lift shall permit both inboard and outboard

facing of the occupant.

The controls shall be interlocked with the vehicle

systems, to ensure that the vehicle cannot be

moved when the lifts are not stowed and that the

lift cannot be deployed unless the interlocks or

systems are engaged.

The lift shall deploy to all levels normally

encountered in the operating environment.

The lift shall incorporate an emergency method of

deploying, raising, and stowing if electrical

power fails,

Vehicle-Based Ramps

Ramps 30 inches or longer shall support a

minimum load of 600 pounds.

The ramp surface shall be continuous and slip

resistant and shall be at least 30 inches wide.

Each side of the ramp shall have a barrier at least

2 inches high.

If the height of the vehicle floor from which the

ramp is deployed is greater than 9 inches above a

6-inch curb, a slope of 1 to 12 shall be achieved.

Stowed ramps must not impinge on a passenger’s

mobility aid or pose any hazard to passengers in

the event of a sudden stop or maneuver.

113
114 I Over-the-Road Bus Access

Securement Systems

Securement systems shall restrain a force in the

forward direction of up to 2,000 pounds per

securement leg or clamping mechanism, and a

minimum of 5,000 pounds for each mobility aid.

The securement system shall limit the movement

of an occupied wheelchair or mobility aid to no

more than 2 inches in any direction under normal

vehicle operating conditions.

The securement systems shall secure common

wheelchairs and mobility aids and shall either be

automatic or easily attached by a person familiar

with the system and mobility aid and having

average dexterity.

For each securement device provided, a passenger

seat belt and shoulder harness shall also be

provided for use by wheelchair or mobility aid

occupants.

●

●

●

●

The securement system shall be placed as near to

the accessible entrance as practicable and shall

have a floor area of 30 inches by 48 inches.

In a vehicle in excess of 22 feet in length, at least

one securement device shall secure the wheelchair or mobility aid facing toward the front of the

vehicle.

When not being used for securement, the system

shall not interfere with passenger movement,

shall not present any hazardous condition, shall

be reasonably protected from vandalism, and

shall be readily accessed when needed for use.

For each securement device provided, a passenger

seat belt and shoulder harness, complying with all

applicable provisions of 49 CFR part 571, shall

also be provided for use by the wheeled mobility

aid occupant.

SOURCE: 56 Fedeml f7e@ter4556045562 (Sept. 6, 1991), Architectural and Transportation Barriers Compliance Boar~ Americans With Disabilities Act

Accessibility Guidelines for Transportation Vehicles; Finrd Gui&lines, 36 CFR Part 1192, SubPat B.
Appendix A:

Reasonable Cost

Estimates for Implementing

Accessible Over-the-Road

Bus Service

The congressional debate on accessibility requirements for over-the-road buses (OTRBs) under the

Americans with Disabilities Act (ADA) included

conflicting cost estimates for implementing accessible

OTRB service. Indeed, it was in large part the

confusion over cost figures and the availability of

accessibility technologies for OTRBs that prompted

Congress to instruct the Office of Technology Assessment (OTA) to conduct this study. 1

This appendix discusses the costs of implementing

accessible OTRB service. OTA develops cost estimates first for equipping a single bus or station and

then for an entire OTRB fleet (including allowances

for the operator to choose which type of level-change

device to implement, i.e., vehicle-based or stationbased). Finally, the issues of borrowing funds and

appropriate discounting over time are discussed. All

cost estimates are based on 1992 data.

Costs of Implementing Accessibility Technologies for One OTRB

OTA classifies the costs of equipping one OTRB

into three categories:

1.

2.

3.

Capital costs (including the cost of the levelchange device, any major repairs involving

replacement parts that may be needed as the

device ages, and modifications to the OTRB);

Maintenance (including routine cycling of the lift

and maintenance checks); and

Lost revenue (possibly resulting from lost seating or baggage and package storage capacity).

OTA created a spreadsheet model in which these costs

were calculated for a single OTRB (whether equipped

for use with vehicle-based or station-based levelchange devices). In this section, each of these costs will

be discussed, as well as those not encompassed by the

model. A range of values for the component costs is

then presented, and total costs compiled for one

OTRB.

Capital Costs

Level-change devices fall into two categories: 1)

station-based level-change devices that serve multiple

buses at one station, and 2) vehicle-based level-change

devices that travel with the OTRB, generally in the

luggage compartment or on the passenger deck.

Retrofitting, the adaptation of an existing OTRB to

1 The Committee report for the Americans with Disabilities Act states: “During its hearings on the legislation the Committee heard

conflicting testimony on the cost and reliability of wheeled mobility aid lifts or other boarding assistance devices with regard to their use on

over-the-road buses. Therefore, before mandating these or any other boarding options in the Act, a thorough study of the access needs of

individuals with disabilities to these buses and the cost-effectiveness of different methods of providing such access is required by the Act. ’

U.S. Congress, House Committee on Education and Labor, Lezgislative History of PubIic Law 101-336, The American with Disabilities Act,

Committee Print, Serial No. 102-A, December 1990, p. 249.

115
116 0ver-the-Road

make it accessible, is

Bus Access

not required by the ADA, so

throughout the cost modeling it is assumed that buses

will be made accessible when they are purchased or

leased (see ch. 1).2

For several reasons, ramps are not modeled as the

primary level-change devices. First, in late 1992, the

only ramp in production or development was designed

prior to the passage of the ADA, by Greyhound, and is

not likely to meet current ADA standards unless

redesigned. Second, it is often difficult to install and

use a station-based ramp, given the close proximity of

OTRBs parked at stations; thus, the use of ramps may

often be infeasible.

In addition to routine maintenance (discussed below),

some lifts require overhauls that involve extensive

replacement of parts. Such overhauls are much like the

major repairs that many automobiles require halfway

through their overall lifetimes (e.g., replacing major

engine components). OTA considers these overhauls

to be capital costs.

Associated with traveler-ready OTRBs (i.e., accessible OTRBs equipped for use with station-based

level-change devices) is the use of ramps and boarding

chairs in case of emergency. Although on-the-road

OTRB breakdowns are not a regular occurrence, they

are not uncommon. In this event, the U.S. Department

of Transportation (DOT) may require that travelerready OTRBs carry a collapsible ramp and boarding

chair in order to take persons with mobility impairments off the OTRB or to transfer them to a

replacement OTRB. This ramp would not necessarily

have to meet ADA requirements for ramps used as

routine level-change devices, but it must be safe,

reliable, and easy to use. Costs of such an emergency

ramp were included in calculations where appropriate.

Whatever the level-change device, an OTRB itself

must be fully accessible. These bus accessibility

features include two wheeled mobility aid tie-downs

(with folding seats for use when the tie-downs are not

occupied), an additional door (or a wider main door

with additional structural support), the means to

communicate with people who have sensory and

cognitive impairments, and movable arm rests. Some

of the analyses also included accessible restrooms,

which were considered an additional bus modification.

Maintenance

As with any mechanical device, station- and vehiclebased lifts require regular service and maintenance. In

addition to repairs, this service includes cycling of the

lift in order to keep it working properly and to keep

operators familiar with its use. Because regular maintenance costs increase over time due to wear and tear on

the equipment, OTA assumes that these costs will rise

at a predictable rate.

The time required to cycle lifts poses a cost of lost

time for drivers/lift operators. The calculations capture

this cost through estimates of the time required to cycle

the lift and hourly driver wages.

Forgone Revenue

The costs of forgone revenues fall into two categories: those from lost baggage capacity and those from

lost seating. If a vehicle-based level-change device or

an emergency ramp is carried in the baggage compartment, there will be a loss of baggage space. In some

instances, this loss of baggage space could force the

OTRB carrier to turn away potential package express

customers (posing a cost of forgone revenue) or to

make arrangements for baggage left behind, If a

level-change device is carried on the passenger deck,

or when the use of a wheeled mobility aid tie-down

displaces seats, seating capacity is reduced. This

reduction may lead to loss of revenue.

A technology under development would allow the

vehicle-based lift to ride on the outside of the bus (see

ch. 4). If this technology becomes available to OTRB

operators, it will result in no loss of revenue due to lift

storage.

Because station-based lifts incur no forgone revenue

from displaced baggage and seating capacity, only the

revenues gained or lost from tie-down usage bear

consideration. While at first glance it may appear that

station-based lifts are inappropriate for specific stations, OTRB operators might wish to project the costs

of forgone revenue on the affected routes when

developing their implementation strategy.

Package and Baggage Capacity-Some debate

exists over the financial impact of lost baggage and

package space. Most bus companies offer a range of

package express services at various prices, from

“next-bus-out” (literally the package goes out on the

2 The model also does not include the costs of implementing accessibility technologies when a vehicle is remanufactured.
Reasonable Cost Estimates for Implementing Accessible Over-the-Road Bus Service I 117

next bus to the destination-this is the most expensive

service), to overnight delivery, to regular package

delivery. Thus, among the package express services,

there is some flexibility to accommodate full baggage

compartments. Only with next-bus-out delivery would

there be a problem with a full baggage compartment,

and then only if there were no packages in the

compartment that could be taken out (e.g., regular

delivery packages) to make room for the next-bus-out

package. In addition, it is common for bus companies

to make arrangements for baggage that must be left

behind when baggage compartments fill up, Thus,

additional charges for baggage left behind due to the

displacement of baggage capacity by a lift arise if the

baggage left behind was only that displaced by the

accessibility equipment. Otherwise, this baggage would

simply be added to the rest of the baggage held over for

transport by other means, presumably at a small

incremental cost.

Seating Capacity-Seating loss occurs in two

ways: 1) when wheeled mobility aid tie-downs are

occupied (in early 1993, the only tie-down technologies available required that up to four standard seats be

flipped up-and thus rendered unusable—when a

wheeled mobility aid tie-down is occupied); and 2)

when seats are permanently displaced by a lift stored

on the passenger deck. However, there are questions as

to how much the lost seating capacity actually

translates into a loss of revenue for OTRB operators.

The losses are not proportional. For example, there is

no revenue loss at all unless an OTRB is nearly full and

prospective passengers are denied seating. Even then

the revenue from these prospective passengers might

not be lost to the system, for they may opt to wait for

the next bus. Other mitigating factors include:

● The behavior of OTRB travelers—in particular,

the choice by a traveler, when faced with a full

bus, whether to travel on another transportation

mode (e.g., by train or airplane), to ride at all, or

to wait for the next OTRB. Most passengers

choose OTRB travel for economic reasons, not

for reasons of convenience or comfort (see ch, 2),

and it is unlikely that they would choose to travel

by another transportation mode. However, it is

difficult to quantify how many people may wish

to cancel a trip; it is expected that at least some

●

individuals will wait for the next bus, with no loss

in revenue to the OTRB operator. Indeed, some

may have no choice if they are at a connecting

station or awaiting a trip home. If a reservation

system were in place, travelers would know in

advance when to show up and, as with airline

travel, would make accommodations for OTRB

schedules. Therefore, taking into account the

potential behavior of OTRB travelers reduces the

impact of lost seating due to accessibility technologies.

The provision by the bus company of a second

OTRB. Several bus companies claim that if a bus

fills up and many people still wish to travel, at that

time a second bus will pull up. Thus, if the

accessibility features of an OTRB cause the loss

of two to eight seats, but more than that number

were denied access to the first OTRB, a second

bus would be needed to accommodate them all in

any case.

Therefore, without knowledge of the frequency of a

“full bus,’ the number of passengers turned away, and

how many of these potential passengers choose to go

home or to travel on another transportation mode rather

than wait for the next bus, it is virtually impossible to

calculate accurately the loss of revenue due to lost

seating capacity.3

However, under most conditions, wheeled mobility

aid tie-downs increase the revenue of OTRB operators.

Tie-downs serve passengers previously unable to use

the OTRB system, and every time the tie-down is used

it generates passenger revenue. (When a tie-down is

not in use, it displaces no seats and thus no revenue is

lost). Only when the bus is full will the displaced

seating result in lost revenue. For example, if the

tie-down is used 10 times in a year, it will generate 10

fares, Assuming that the bus is full to capacity 10

percent of the time, lost seating will occur on average

during only 1 of the 10 tie-down uses. In that case, up

to 4 fares will be displaced, leaving at least 6 fares

gained by the 10 uses of the tie-down.

Additional Factors-Several additional observations can be made about package and seating displacement:

. On routes where OTRBs travel frequently, it is

more likely that the next bus will be able to

accommodate much of the spillover from a full

3 OTA attempted to gather such information from several bus companies, but it was not available.
118 0ver-the-Road Bus Access

bus, in baggage, package, and seating capacity,

Under these conditions, OTRB operators may

develop methods to cope with the problems raised

by a full bus.

. On routes where OTRBs travel infrequently, it is

much less likely that the bus will be full, due to

low ridership at these stations. However, if the

bus is full, it will be more difficult for OTRB

operators to encourage passengers to use the next

bus, or to accommodate baggage and packages

that must be left behind,

Therefore, on routes that are served by a number of

buses, OTRB operators may minimize forgone revenue costs through additional planning and operational

methods. However, OTRB operators on routes with a

small number of buses traveling in a given day may

have less of a chance of those buses being full; if they

are, these carriers may have less flexibility to accommodate for lost baggage and package space and lost

seating capacity.

Costs Not Included in the Model

This analysis excludes many costs of implementing

accessibility technologies on OTRBs. They include

training costs; additional fuel charges; costs due to

changes in travel times to accommodate lift uses;

insurance costs; and loss of passengers sensitive to

price, time, and/or crowding.

Training of company personnel is an important

feature in the implementation of any accessibility

technology. However, private entities operating fixedroute service with any type of vehicle are currently

required by the ADA to train personnel to proficiency

in how to treat individuals with disabilities with

dignity, respecting differences among such persons.

These firms will incur training costs irrespective of any

changes in the implementation of accessibility technologies, so this analysis includes no training costs. In

fact, in the future, when level-change devices are

provided for every OTRB, training need no longer

consider in such great detail how to carry persons with

disabilities up and down OTRB stairs and into seats.

Therefore, once DOT regulations are fully implemented, it may be less expensive to train company

personnel.

Because level-change devices weigh up to 600

pounds, they decrease the fuel efficiency of an OTRB.

In addition, increased idling time to operate a vehiclebased lift may contribute to higher fuel expenditures.

OTA found additional fuel costs impossible to quantify, but expects them to be negligible over the lifetime

of the OTRB when compared with other costs included

in the model.

Scheduling changes or extra time maybe necessary

to allow deployment of level-change devices at stations, as well as to add stops at accessible restrooms.

While the costs of minor extensions of route times are

not expected to be large, they are unquantifiable, and

will remain so even as accessibility technologies are

introduced.

The costs of insurance rate adjustments will become

known as accessibility technologies are introduced,

but they are impossible to predict. The implementation

of technologies to assist persons with sensory, cognitive, and mobility impairments that do not require the

use of a wheeled mobility aid are expected to affect

insurance rates very little. Indeed, since most insurance

claims are due to falls down the front steps, a lower

initial step and additional handrails could decrease the

likelihood of claims.

The implementation of technologies for persons

who need assistance while boarding an OTRB may

affect insurance rates more significantly. However,

since carrying is most certainly more dangerous to all

parties involved than is the operation of a lift or ramp,

it could be reasoned that the introduction of lifts and

ramps should not affect rates dramatically.4 Nevertheless, because it is likely that more persons with

disabilities will be riding OTRBs as they become more

accessible and because the safety and effectiveness of

new technologies must be gauged, insurers may

increase their rates for some time until there is more

experience with new technologies (see ch. 2). Until

then, it is impossible to forecast accurately the

additional insurance costs for accessible OTRBs.

Therefore, OTA does not include these costs in its

d Carrying has been the primary method for persons with severe mobility impairments to board an OTRB. Since OTRB ridership by persons

who use wheeled mobility aids is not expected to increase until the introduction of level-change devices and securement positions, the passage

of the ADA and the interim regulations for OTRB accessibility have not yet caused a fluctuation in the insurance rates for OTRBS. Jack Burkert,

senior vice presiden~ Lancer Insurance Co., Arlingto~ VA, personal communication% May 1992.
Reasonable Cost Estimates for Implementing Accessible Over-the-Road Bus Service 119

analyses, but notes that they may be significant for

some companies, especially in the short term.

OTRB service, especially intercity service, is a

low-cost option for public transportation, and OTRB

passengers are in general very sensitive to price

increases. If the cost of accessibility technologies

results in higher fares, then overall ridership might be

affected. In particular, while there may be an increase

in ridership by passengers with disabilities, there may

also be a decrease in the present cohort of riders if

passengers decide not to take the bus due to increasing

fares. It is difficult to judge how these two factors will

affect overall ridership, since the estimates of the

number of passengers with disabilities are only ballpark figures, and the potential for price increases at

various levels and the effect of such increases on

ridership are unknown.5 At the end of this appendix,

this effect is discussed further.

Finally, as persons with disabilities ride on more

OTRBs, some OTRBs may be more crowded, and

boarding times may increase. A result of the increased

load factor and the possible lengthening of some trips

could be that some passengers would view the OTRB

system as a less desirable form of transport and choose

other forms of transportation. While OTA recognizes

that this is a potential effect of increased accessibility,

this effect is impossible to quantify with available data

and OTA does not include it in its analysis.

Cost Data for Fixed-Route Service

Discussed below are each of the items of data in the

cost model, their source(s), and, where appropriate, the

reason they are incorporated in the model. The figures

stated represent 1992 cost values and, in a few cases,

a range of values is presented. (For more discussion of

the specific technologies mentioned below, see ch. 4.)6

For some of the variables, no data exist and OTA had

to estimate values based on reasonable assumptions.

●

●

●

Capital costs of a vehicle-based lift. The Ricon

Mirage lift, used in OTRBs in Great Britain, is

available in the United States for $7,000. More

expensive lifts cost up to $17,000 (e.g., the Lift-U

III or the MCI 4-Link lift). An intermediatepriced lift is the Stewart and Stevenson Powerlift,

costing $8,500 to $12,500. All lifts evaluated by

OTA vary in the number of seats and amount of

baggage space displaced.7

Although all vehicle-based lifts evaluated by

OTA could potentially meet ADA standards, it is

conceivable that an OTRB buyer would prefer to

purchase one of the more costly lifts for reasons

not of function, but as a result of placing a

different weight on operational or other factors.

Thus, OTA does not always assume that OTRB

buyers would choose the least expensive lift

option.

Capital costs of a station-based lift. Adaptive

Engineering, Inc., estimates the cost of a stationbased lift at $4,500. Adaptive Engineering makes

a station-based lift for use with trains and is

modifying that lift for use with OTRBs.8 It was

assumed that no maintenance overhaul on the lift

is necessary.9

Incremental cost for outfitting a bus with

nonlift accessibility features. OTA assumed the

cost of purchasing a bus with two wheeled

mobility aid tie-downs, an additional door (or a

wider main door, wide enough to accommodate a

person using a wheelchair, scooter, walker, or

crutches), the means to communicate with persons who have sensory and cognitive impairments, and movable arm rests, at $5,000 to $7,000

5 OTA has found two studies that estimated the demand elasticity in OTRB travel: Don H. Pickrell, “AppendixB, Models of Intercity Travel

Demand,” Deregulation and the Future oflntercity Passenger Travel, John R. Meyer and Clinton V. Oster, Jr. (eds.) (Cambridge, MA: MIT

Press, 1987), pp. 257-9; and Michael W. Babcock and H. Wade Ge- “A Model of the Demand Elasticity for Intercity Bus Travel,”

Proceedings-Twenty-Fifth Annual Meeting of the Transportation Research Forum, Transportation Research Board (cd.), vol. 25, No. 1, 1984,

pp. 187-193. However, both studies were based on data from the rnid-1980s, and circumstances in the OTRB intercity industry have changed

since that time, especially with respect to numbers of points and passengers served and price structures.

6 All cost data, unless explicitly stated otherwise, are from Econometrics, Inc., “Evaluation of Methods to Provide Accessibility to

Over-the-Road Buses and Services, ’ OZ4 contractor report, July 31, 1992.

7 As of early 1993, NeopIan offered an OTRB with a vehicle-based lift as a standard feature. As ADA regulations go into effecg more

companies might include lifts as standard features.

8 As of late 1992, this is the only station-based lift to come to the attention of OTA.

9 Adaptive Engineering, Inc., claims that no overhauls will be necessary for the lift over its lifetime.
120 0ver-the-Road Bus Access

●

●

●

●

(above that of a conventional OTRB). As discussed above, this cost is not for retrofitting an

OTRB, but rather the additional cost to purchase

a new bus that is accessible, with either stationbased or vehicle-based level-change devices.10

Incremental cost for a vehicle-based lift stored

externally. In late 1992, a device to externally

store a vehicle-based lift was in the preliminary

stages of development by Adaptive Engineering,

Inc. The best estimate of the incremental cost to

house the lift on the exterior of the bus was

$1,000. The use of an external lift storage device

would eliminate baggage or seat loss generated by

stowage of the lift. However, several problems

are yet to be addressed by this proposed technology, including protection of the lift from extremes

of heat and cold, and from dirt and dust accumulation. Such protection might increase the cost of

the housing, but no estimates are available.

Cost of a vehicle-based emergency ramp and

boarding chair. As discussed above, DOT may

require all OTRBs without a vehicle-based lift to

carry an emergency ramp. Best Diversified Products sells its ramp for $750 and a boarding chair

for $550.

Cost of an accessible restroom. In late 1992, two

accessible restrooms were in production or development: one produced by Neoplan that costs

$2,000 in additional bus modifications and permanently displaces three seats; and a prototype

made by MCI for a 45-foot coach that is estimated

to cost $30,000 in additional bus modifications

and permanently displaces seven seats (note that

no additional seats are lost due to tie-down

occupancy with the MCI restroom). These costs

are in addition to lift costs and the costs of other

vehicle modifications.

Rate of maintenance cost increases per annum.

As lift equipment ages, it is assumed that

maintenance costs will rise due to parts wearing

out and so forth. From industry and government

estimates, OTA derived a rate of 2 percent.ll

Maintenance costs for a bus-based lift in the

first year of its operation. This figure provides

the basis from which annual repair costs are

calculated. Estimates were derived from pilot

project, government, and industry data.12 The

model assumes that the less expensive lifts (e.g.,

the Stewart and Stevenson and the Ricon Mirage

lifts) have $100 first-year repair costs, However,

it is assumed that the expensive lift, costing

$17,000, has first-year repair costs of $150.

Repair costs for a station-based lift in the first

year of its operation. This figure is the analog to

the associated figure for vehicle-based lifts. The

model assumes a $85 first-year repair cost for the

$4,500 lift.

Life of lifts until an overhaul is needed. As

discussed above, it is expected that some lifts will

have to undergo an extensive overhaul in order to

extend their operating life. The model assumes

that the lift can be overhauled once before it must

be permanently retired and that the overhaul takes

place halfway through the expected lifetime of the

equipment. It is further assumed that annual

maintenance costs follow the same pattern after

the overhaul as they do following the purchase of

a new lift. For the manual Stewart and Stevenson

lift, available information indicates that no overhauls are necessary. However, for the other

vehicle-based lifts, overhaul costs were incorporated into the model.

Overhaul costs for station-based and vehiclebased lifts. The model assumes overhaul costs,

when existent, to be one-half of the current cost

of a lift excluding vehicle modifications. Due to

technological improvement (at 1.5 percent per

year above inflation, from historical lift prices),

the price of the lifts will fall overtime. Therefore,

the cost to overhaul one lift will be less than

one-half of its purchase price 10 years earlier.

Cost of OTRB shipping of packages. This

figure provides the basis for calculating the cost

of lost revenues due to displaced baggage and

10 me ~oS~ of ~e~ofl~~g ~ ~fist~g OTRB are q~te s~ar, howev~o Bi~ Hodgson, sales repre~ntative, Stewart and Stevenson power,

Inc., Commerce City, CO, personal cornmunicatio~ August 1992.

11 Bfim Gu~e, p~er, Science ~d ~c~olog Divisio~ ~c~~g Corp., Ottawa, on~o, CaMda, persontd communicatio~ Sept. 10,

1992.

12 For exmple, the Denver Re@o~ Transit District reports that its Stewart and Stevenson hfts have eachrequired leSS ti$100 ~ ~U~

maintenance since they have been in operation.
Reasonable Cost Estimates for Implementing Accessible Over-the-Road Bus Service I 121

packages. From available bus parcel industry

data, OTA derives a cost per-mile per-100-

pounds shipped of 7.5 cents. The model assumes

that a vehicle-based lift is comparable to a

package of 500 pounds and that the emergency

ramp and boarding chair are a package of 200

pounds. The Ricon Mirage and Lift-U III lifts are

stored in the baggage compartment and thus may

displace luggage and packages. However, the

Stewart and Stevenson lift is stowed on the

passenger deck and therefore does not occupy

baggage space, although it will permanently

displace two passenger seats. In addition, a

probability estimate was added to the calculations, representing the frequency of an overcapacity baggage compartment.

. Frequency of an overcapacity y baggage compartment. No data are available on how frequently

baggage compartments are full. Assuming that, if

baggage compartments are filled, arrangements

are made to transport excess baggage, OTA

hypothesizes that the frequency of a full baggage

compartment where such arrangements are not

already being made is roughly 1 percent.13

. Cost of a passenger ticket (no advance purchase). This figure provides the basis for estimating the cost of forgone revenue from lost seating

when a wheeled mobility aid tie-down is occupied or when seats are permanently displaced.

From industry passenger ticket information, the

cost per-mile per seat is $0.085. The model

assumed a joint probability estimate of when a

wheeled mobility aid tie-down will be used and

the bus is full. Only then may a passenger have to

be turned away and the cost of forgone revenue be

incurred.

. Frequency of a full OTRB. Assuming full

capacity on Friday nights, Sundays, and close to

holidays, OTA estimated the frequency of a full

OTRB at 10 percent.

● Frequency of a wheeled mobility aid tie-down

being occupied. OTA assumes the frequency of

a tie-down being occupied is 5 percent. This

figure is derived from estimates of the rate at

which persons using wheeled mobility aids will

ride OTRBs (0.5 percent, see ch. 3) and of the

average occupancy of an OTRB (10 to 15 people).

● Frequency that a passenger will decide to

cancel an OTRB trip when faced with a full

bus. As discussed above, there are few data with

which to address this point. OTA assumes that

one-third of the passengers will decide to cancel

their trips rather than wait for the next bus.

. Time per week to cycle lift. It is suggested by

manufacturers that the lifts be cycled on a regular

schedule, on average, once per week. Under

normal conditions, it takes 10 minutes to cycle a

lift. The time spent by drivers/operators cycling

the lift represents a cost to the industry.

. Hourly wage for bus drivers. This figure is used

to calculate the implicit cost of cycling lifts.

Based on estimates by industry experts, the

average hourly wage for drivers is $14.00.

. Life of OTRBs. Based on industry experience

and forecasts, OTRB manufacturers predict that

new OTRBs will operate for 20 or more years.

Although OTRB operators may sell their equipment earlier, it is expected that they will recoup

the current value of the level-change device in the

sale. While OTA recognizes that the resale market

may not value the lift at its full worth, it is

impossible to predict the value that will be placed

on it. In addition, some purchasers of used

OTRBs, such as charter and tour companies, will

require level-change devices.

. Life of station-based and vehicle-based lifts.

From industry experience and forecasts, the

expected lifetime for various lifts is 20 or more

years.

. Number of miles traveled by an OTRB pe r

year. Most OTRBs are expected to travel at least

1.5 million miles during their lifetimes. Over 20

years, this translates into 75,000 miles per year.

Results for OTRBs in Fixed-Route Service

The model took into account all of the data

discussed above and calculated the total cost over the

next 20 years of one accessible OTRB. Several

scenarios were used. (See table A-1 for a summary of

the results.) One scenario assumed a lift similar to the

13 Bawage also Ca ~stored in UIc pa5Senger comp~ent, providing further flexibility 10 OTRB carriers in de~@ ~~ a f~l baggage

compartment.

330-069 0 - 93 - 5 QL:3
122 0ver-the-Road Bus Access

Table A-l—Reasonable Estimates of Cost Outlays for Implementing Various

Accessibility Devices and Accessible Restroom Options on an OTRB a

Low-cost Medium-cost Traveler- Low-cost High-cost

traveler- traveler- complete OTRB High-cost accessible accessible

complete complete with externally traveler-corn- Traveler-ready rest room restroom

OTRB OTRB mounted lift plete OTRB OTRB and liftb with lift with Iift

Lift $7,000 $10,000 $11,000 $17,000 $6,700 $7,000 $10,000

Vehicle 5,000 5,000 5,000 5,000 5,000 7,000 35,000

modifications

Overhaul 3,000 0 0 7,300 0 3,000 0

Maintenance 4,600 4,900 4,900 5,700 2,700 4,600 4,900

Forgone 5,600 0 0 5,600 2,200 5,600 0

revenue due to

lost baggage

Revenue lessor (5,500) 3,000 (5,500) (5,500) (5,500) 7,200 24,000

(gain) due to

seating changes

Total $19,700 $22,900 $15,400 $35,100 $11,100 $34,400 $73,900

Cents per mile 1.3 1.5 1.0 2.3 0.73 2.3 4.9

NOTE: This table does not include the cost of an emergency ramp unless noted otherwise.

a See text.

b ~is figure represents 1.2 of the price of a station-based lift (see text) and the cost of an emer9en~ ramP and ~~r.

SOURCE: Office of Technology Assessment, 1993.

Ricon Mirage vehicle-based lift with a $7,000 capital

cost, $5,000 bus modification cost, $100 first-year

maintenance cost, overhaul costs, and some baggage

displacement (no seats are displaced by the lift itself).

All other figures were assumed to be the values

presented above. The additional capital and operating

costs of this OTRB are on average $20,000 more over

20 years, which translates to 1.3 cents per bus-mile. As

with all of the scenarios, if the bus modification costs

were $7,000, the cost per mile would increase by 0.13

cents. (Note that none of the figures quoted in this

section are discounted. Discounting is discussed below.)

A second scenario assumed a lift similar to the

Stewart and Stevenson lift, which requires $10,000 in

initial capital costs, $5,000 in bus modification costs,

$100 first-year maintenance costs, no overhaul costs,

and two permanently displaced seats. It costs on

average $23,000 more over 20 years for the additional

capital and operating costs for this OTRB, which

translates to 1.5 cents per bus-mile.

A third scenario assumed an intermediate price lift

that is mounted externally, which incurs a $10,000

initial capital cost for the lift, plus $1,000 to mount the

lift externally, $100 first-year maintenance costs, no

overhaul costs, and no seats permanently displaced. It

costs on average $15,000 more over 20 years for the

additional capital and operating costs for this OTRB,

which translates to 1.0 cents per bus-mile.

A fourth scenario assumed an expensive vehiclebased lift requiring $17,000 in initial capital costs,

$150 first-year maintenance costs, overhaul costs, and

baggage displacement. It costs on average $35,000

more over 20 years for the additional capital and

operating costs for this OTRB, which translates to 2.3

cents per bus-mile.

A fifth scenario assumed an inexpensive, $4,500

station-based lift with $85 first-year maintenance costs

and no overhaul costs. Since it is recommended in

chapter 1 that DOT require OTRB operators to employ

traveler-ready OTRBs only when all route stops are

equipped with station-based level-change devices,

OTA has calculated the average number of stations that

must be equipped with station-based level-change

devices per bus in OTRB fixed-route service. Assuming 5,000 buses in the total pool of vehicles used to

provide fixed-route service and 6,000 freed-route
Reasonable Cost Estimates for Implementing Accessible Over-the-Road Bus Service I 123

stops, the average number of stations that must be

equipped per bus is 1.2. (Scenarios with both stationbased and vehicle-based level-change devices are

discussed below in the presentation of the systemwide

calculation s.) It costs on average $11,100 moreover 20

years to operate this OTRB, which translates to 0.7

cents per bus-mile. An emergency ramp is included in

the price (which accounts for an overall cost per

bus-mile of 0.1 cents) .14

A sixth scenario assumed the installation of an

accessible restroom similar to the Neoplan restroom

($2,000, three seats displaced) with a lift similar to the

Ricon Mirage Mt. It costs on average $34,000 more

over 20 years to operate this OTRB, which translates

to 2.3 cents per bus-mile. These figures can be

compared to those for the Ricon Mirage lift alone at 1.3

cents per mile.

A seventh scenario assumed the installation of an

accessible restroom similar to the MCI restroom

($30,000, seven seats displaced) with a lift similar to

the Stewart and Stevenson lift.15 It costs on average

$74,000 more over 20 years to operate this OTRB,

which translates to 4.9 cents per bus-mile. These

figures cart be compared to those for the Stewart and

Stevenson lift alone at 1.5 cents per mile.

Thus, in summary, the additional costs to purchase

and operate a traveler-complete OTRB (i.e., an accessible OTRB with a vehicle-based lift) are generally 1.3

to 2.3 cents per bus-mile (and might go down to 1.0

cents per mile if the externally mounted lift becomes

available), while additional costs for a traveler-ready

OTRB and a proportional number of station-based lifts

(with emergency ramps) are 0.6 cents per bus-mile,

Accessible restrooms increase the costs by 1.0 to 3.4

cents per bus-mile.

Results for OTRBs in Charter and Tour Service

For charter and tour service, the demand for

accessible service determines the number of accessible

OTRBs required. However, even with the demand

figures for accessible charter and tour service derived

in chapter 3, the resulting requirements for OTRB

purchases are impossible to gauge since the impacts on

a specific company are dependent on local demand. In

addition, very little operational data exist for charter

and tour companies.

If a charter and tour company purchases a new bus

with a vehicle-based lift and an accessible Neoplan

restroom, the additional cost over the 20 year lifetime

of the bus might run $17,000 for capital expenditures,

and $4,600 for maintenance costs. Since this bus can

be expected to run an average of 1.5 million miles over

its 20 year lifetime, the cost per bus-mile would be 1.4

cents per mile.

However, this figure does not include costs due to

forgone revenue. Due to the complexity of charter and

tour pricing schemes, OTA is unable to place a value

on lost seating and baggage capacity. Thus, it is

impossible to calculate the costs due to revenue losses.

However, they are expected to be greater per bus than

for fixed-route companies, since charter and tour

companies operate OTRBs at capacity for a higher

percentage of the time than do freed-route operators.

Sensitivity y Analysis

In order to determine the sensitivity of these costs to

changes in the model variables, a sensitivity analysis

was performed. This procedure consisted of changing

each variable over a range of values and examining the

effect on total costs. From two base models (the first

and fifth scenarios above, i.e., the Ricon Mirage lift

and the low-cost station-based lift), only one variable

was changed at a time; all other variables were held

constant. The range for each variable was determined

on a case-by-case basis. No attempt was made to rank

the variables in order of the effect on the total cost

calculations of varying each one. Rather, variable

ranges were chosen to illustrate the potential effects on

total cost of changing the input variables, The results

are summarized in table A-2.

14 ~ofier Sc.~o ~SS~ed ~ exwmive, $7,)()() station.b~ed lift wi~ $120 f~st.ye~ ~te~ce COStS, md overkuud COStS of one-half

the current price. (Note that no such station-based level-change device is currently in development.) The ratio of stations to OTRBS is assumed

to be the same as above. Thus, it costs on average $14,000 (undiscounted, see below) moreover 20 yean to operate this OTRB, which translates

to 0.9 cents per bus-mile. AgairL an emergency ramp adds $1,300 to the price in the fwst year, which increases the per bus-mile cost by 0.1

cents.

15 MCI plans to produce its 45.foot a~essible coach with an accessible restroom and an option for a Stewart ~d Stevenson Pow~M.

Norman Littler, coordinator, Regulatory Relations, MCI, Ltd., Winnipeg, Manitoba, CanadA personal commun.icatiorL August 1992.
124 0ver-the-Road Bus Access

Table A-2—Sensitivity Analysisa

Variable Range of variable Variation In total costs

Cost of a bus-based lift

Frequency of a package encountering a full baggage compartment

Cost of a passenger ticket (no advance purchase)

Incremental cost for outfitting bus with non lift accessibility features

Time per week to cycle lift

Cost of a station-based lift

Maintenance cost for a station-based lift in the first year of its operation

Cost of package shipping

Frequency of a tie-down being occupied and potential passengers

being turned away

Rate of maintenance cost for a bus-based lift in the first year of

its operation

$7,000-17,000

0.5-2.0 percent

$0.06-0.11

$5,000-7,000

5-15 minutes

$4,500-7,000

$50-120

$0.05-0.10 per-mile

per 100 pounds

0.1-0.2 percent

$100-150

Up to 70 percent

Up to 50 percent

15-50 percent

10-40 percent

14-35 percent

Up to 30 percent

Up to 23 percent

Up to 20 percent

2-11 percent

Up to 5 percent

a See text for a d~cription of the sensitivity analySk.

SOURCE: Office of Technology Assessment, 1993.

Costs of Implementing Accessibility Technologies for a Fixed= Route OTRB Fleet

The results presented above for one accessible bus

can be used to infer the implementation costs of a

completely accessible OTRB fleet. OTRB operators

will purchase accessible OTRBs when the need arises

and funds are available. Thus, buses will be phased in

over time as other buses are retired. Before the fleet is

fully accessible, the additional cost per bus-mile for the

entire fleet of buses will be less than that for one

accessible bus. As more of the fleet becomes accessible, the additional cost per bus-mile for the entire fleet

will approach the figures cited above.

However, under the proposed accessibility requirements presented in chapter 1, OTRB operators can

choose to purchase traveler-ready or traveler-complete

OTRBs (or some combination). Their choice will

depend on the nature of their OTRB system. For

example, operators in urbanized areas with many

express buses (such as in the Northeast Corridor) will

benefit more from station-based technologies than will

operators in rural areas with many small stops. To

model the effect of this choice, OTA performed case

studies of two States and one U.S. region: 1) the rural

State of Montana; 2) the both urban and rural State of

Alabama; and 3) the largely urban region of Connecticut, Massachusetts, and Rhode Island. OTA examined

the implementation of accessibility at a statewide

level, because data on individual companies are scarce.

However, analysis using statewide data illustrates the

important factors that individual bus company owners

must consider when complying with future OTRB

regulations.

As a result of the freedom of OTRB operators to

design their own implementation schemes, countless

scenarios could develop. However, OTRB owners will

attempt to minimize their overall costs. As a result,

station-based lifts will most likely be placed in stations

with frequent stops by many OTRBs, and vehiclebased lifts will be carried on OTRBs that make many

stops at places with limited service. In order to keep the

size of the model manageable, OTA selected three

potential schemes for analysis:

1.

2,

3.

Use of station-based lifts at all stations and no

vehicle-based lifts. OTA recognizes that this

scheme is unrealistic because not every stop can

be outfitted with a station-based lift. However, it

was included as a reference point for judging

other schemes.

Use of vehicle-based lifts on all OTRBs and no

station-based lifts.

Use of station-based lifts in stations with 10 or

more OTRB stops daily (large stations), and

vehicle-based lifts on OTRBs that make at least
Reasonable Cost Estimates for Implementing Accessible Over-the-Road Bus Service ! 125

one stop at a smaller station. Clearly, the fulcrum

of the choice, here 10 stops daily, is a decision

that will be made by providers based on prices

and individual preferences.

When the specific results of the model are discussed,

these three schemes are referred to as “all travelerready OTRBs, ’ ‘‘ all traveler-complete OTRBs,” and

‘‘mixed.

Three additional factors must be added to the

calculations to model the phase-in of accessible service

for the case study areas. First, although OTA recognizes that industry replacement patterns vary, for the

purposes of these calculations OTA assumes that

OTRBs are purchased on a regular schedule, i.e., the

same number of buses per year. For example, if the

case study area uses 100 OTRBs, 5 will be purchased

each year for 20 years (and thereafter).

Second, as with any product involving research and

development (R&D) in its production, OTRB lifts will

presumably fall in price as production increases (and

R&D costs are recouped) and the technology becomes

more efficient. Some technology development has

already occurred, especially in response to public

sector demand. From an analysis of historical lift

prices (adjusted for inflation) during transit lift development, OTA assumes a conservative 1.5 percent rate

of technological improvement.

Finally, these calculations assume that operators

purchase accessibility technologies without borrowing

funds and that profit in any given year is either

reinvested in the firm (through capital expenditure),

paid out as dividends to stockholders, or used to reduce

financial liabilities. In other words, profits are not

invested in interest-bearing holdings. Below, this

assumption is revisited. Furthermore, since the cost

model spans more than 20 years, and several schemes

are investigated, it is necessary to include discount

costs in order to form a basis of comparison. At this

point, however, the discount rate is ignored, and only

cash outlays are investigated.

Results of the Case Studies

Within the State of Montana, in late 1991, an

estimated 39 OTRBs traveled daily among 109 stations. Only three of these stations had over 10 stops

daily-at Billings, Butte, and Missoula. No OTRBs

traveled among these stations exclusively.

The results of two runs of the cost model are

presented here for the Montana case study. The first

presents a lower bound on costs for implementing

accessible service, and it includes Ricon Mirage lifts as

the vehicle-based lift option with $4,500 station-based

lifts. (No emergency ramps were assumed and all

figures are not discounted.) The costs for this run are

$760,000 over the first 20 years for the all travelerready OTRB scheme, $540,000 for the mixed scheme,

and $520,000 for the all traveler-complete OTRB

scheme.

The second run presents an upper bound on costs,

and it includes the expensive vehicle-based lift option

(which displaces baggage capacity), with $7,000

station-based lifts and with emergency ramps required.

The all traveler-ready OTRB scheme totals $1.2

million over the first 20 years, the mixed scheme

amounts to $990,000, and the traveler-complete OTRB

scheme totals $970,000.

Within the State of Alabama, in late 1991, approximately 105 OTRBs traveled daily among 124 stations.

Twenty-four of these stations had at least 10 stops

daily; they included stops at the cities of Birmingham,

Montgomery, and Mobile, but also stops in smaller

towns with high fixed-route ridership or that served as

transfer locations. Thirty-one OTRBs traveled only

among the large stations, and 74 of the OTRBs made

at least one stop daily at a smaller station.

As with the Montana case study, two runs are

presented. The first lower bound scenario results in

costs for the all traveler-ready OTRB scheme for the

entire State of Alabama over 20 years of $1.0 million.

The mixed scheme amounts to $1.4 million, and the

entirely traveler-complete OTRB scheme totals $1.6

million over 20 years.

The second run presents an upper bound on costs.

The all traveler-ready OTRB scheme totals $1.8

million over 20 years, the mixed scheme amounts to

slightly less than $2.5 million, and the travelercomplete OTRB scheme totals $2.7 million.

Within the tri-State area of Connecticut, Rhode

Island, and Massachusetts, in late 1991, approximately

419 OTRBs traveled daily among 170 stations. Of

these stations, 117 had at least 10 stops daily; 331

OTRBs traveled only among these stations, and 88 of

the OTRBs made at least one stop daily at a smaller

station.

As with the two previous case studies, two scenarios

were developed using the cost model. The first, less

expensive scenario results in costs of the all travelerready OTRB scheme for the entire tri-State area over
126 Over-the-Road Bus Access

20 years of $2.1 million, the mixed scenario amounts

to $2.9 million, and the entirely traveler-complete

OTRB scenario totals $6.3 million over 20 years.

The second run presents an upper bound on costs,

and it includes the expensive vehicle-based lift option

(which displaces baggage capacity), with $7,000

station-based lifts and with emergency ramps required.

The all traveler-ready OTRB scheme totals $4.3

million for the entire tri-State area over 20 years, the

mixed scheme amounts to $5.7 million, and the

traveler-complete scheme totals $12 million.

Thus, OTA finds that operator choice in where to

place traveler-ready and traveler-complete vehicles

is an important factor in minimizing costs. By

analyzing their route structure to determine which

scenario is most cost-effective, operators can lessen

their total costs.

Although the all traveler-ready OTRB scheme was

least costly in some of the above calculations, there are

significant disadvantages to the all traveler-ready

OTRB scheme relative to the other two. Most notably,

some stations (e.g., Moose’s Sport Shop in Camden,

Alabama) may lack the facilities to house station-based

lifts; where lift housing is possible, OTRB providers

may have to pay ‘‘rent’ to the station property owner.

In addition, some station-based lifts are costly to

remove from a station in the event that an OTRB stop

is to be dropped from the system or to be converted into

a stop that is served by OTRBs with vehicle-based lifts.

Conversely, a vehicle-based lift is a variable cost since

it can be transported from station to station. These

costs of flexibility are difficult to quantify and

therefore are not included in the model. However,

OTA feels that these costs are significant and should be

considered when interpreting the results. Indeed, OTA

finds it will often be impossible to outfit all stations

with station-based accessibility technologies, due to

space and other considerations. Thus, in some

cases, although outfitting all stations with stationbased lifts or ramps may be the least costly on

paper, it may not be feasible or preferable.

Restrooms

If an OTRB is not equipped with an accessible

restroom that can be used by all persons aboard the bus

without any aid that is not normally used in their daily

lives, then the OTRB may make frequent stops (e.g.,

every 1 1/2 to 2 hours) to allow persons with

disabilities aboard the bus to use accessible restroom

facilities. Although it is impossible to compare the

costs of providing an accessible restroom to adding

stops along a route, some data from the case studies

may be useful to explore the issue of restroom

accessibility.

In Alabama, among all the routes that are run in a

given day, an estimated 59 intervals between stops are

longer than 1 1/2 hours, 49 are longer than 2 hours,

only 3 are longer than 3 hours, and none are longer than

4 hours. In all cases, additional stops could be made at

stations that are already used by the bus company. As

of September 1991, slightly under 800 stops were

made daily in Alabama. For comparison, at most 50

buses must be equipped with accessible restrooms to

ensure that all routes with intervals longer than 1 1/2

hours between stops provide accessible restroom

service en route, and at most 40 buses must be

equipped to ensure that all routes with stops longer

than 2 hours apart provide accessible restroom service

en route.

Similarly for the other two case study areas:

. Daily in the State of Montana, at most 8 buses (out

of 39) travel more than 1 1/2 hours between stops;

8 additional stops at existing stations would be

necessary to fill the gaps. At most five buses

travel longer than 2 hours between stops; five

additional stops at existing stations would be

needed to fill the gaps.

. In the tri-State region, at most 159 buses (out of

419) travel daily between two stops longer than 1

1/2 hours apart; 201 additional stops at existing

stations would be needed to fill the gaps. (On

Sundays, two more buses travel between stops

that are longer than 1 1/2 hours apart; two

additional stops would be required to shorten the

length between the stops.) For an interval of 2

hours, at most 96 buses travel between stations

and would require a total of 96 additional stops (at

existing stations) to fill the gap.

Including the Cost of Money and Discount

Rates

The term “the cost of money” is used to refer to the

monetary value placed on resources expended or

forgone when borrowing/lending money. Specifically,

this discussion will investigate factors affecting the

real cost (including opportunity costs) to OTRB
Reasonable Cost Estimates for Implementing Accessible Over-the-Road Bus Service 127

operators in creating an accessible OTRB system as

directed by DOT regulations stemming from the ADA.

It is necessary to make several explicit assumptions

before beginning theoretical and practical analysis of

the cost of money. Although some of these assumptions are clearly not founded in reality, they will be

employed for the time being and then relaxed later in

the discussion,

●

❵

●

●

●

Transaction costs, particularly of borrowing, are

negligible.

Capital markets are perfect, i.e., borrowing and

lending occur at the same rate. For the time being,

a (risk-free) rate of 10 percent is assumed.

Therefore, discounting will occur at a rate of 10

percent,

The tax burden is the same regardless of the

financial method(s) used to purchase the accessibility technologies.

There exists no return to capital (for the OTRB

operator) on the purchased accessibility technologies.

All methods of raising funds---g.,., bonds, bank

borrowing, equity-result in the same ends for

the OTRB operator (the borrower). For ease of

discussion, it is assumed that coupon bonds are

the method used.

Borrowing v. Funds On Hand

In previous cost estimates, it was assumed that

OTRB operators have the financial ability to purchase

accessibility devices as they are needed-that no

borrowing is necessary. Now the scenario is investigated where OTRB operators have only enough funds

to pay for operating expenses on the new accessibility

devices. All funds needed for capital expenses (accessibility technology purchase and overhaul) must be

obtained with 10-year debt in the form of coupon

bonds.

Regardless of the method used to finance the

purchase of a good (in this case, a capital good), the

true cost to the firm is the same. The word “true” is

highlighted in order to emphasize the inclusion of

opportunity costs in this analysis. In any economic

analysis, it is necessary to include all implicit costs of

forgone earnings-referred to as opportunity costs. In

addition, the term “firm” is emphasized since this

analysis looks only at costs to the firm, therefore

ignoring social costs and implications beyond the

immediate impacts on the firm. For example, the

discussion disregards the facts that: 1) borrowing by

the firm (the OTRB operator) may crowd out other

firms from the borrowing market (a cost incurred

outside of the firm); and 2) borrowing may increase the

return demanded by the market for additional borrowing by the firm.

Under the above assumptions, the true cost of a good

is the same regardless of the method used to purchase

it. For example, suppose that DOT has mandated an

OTRB operator to purchase a level-change device, a

capital good. This hypothetical level-change device

costs $100, earns no return to capital, and depreciates

fully in 1 year. The OTRB operator can borrow funds

for 1 year at a rate of 10 percent. Through the concept

of opportunity cost, the true cost to the OTRB operator

of purchasing this accessibility technology is the

potential value of the funds used for the purchase-i. e.,

what the funds could have been worth if invested in the

most profitable option available.l6

Assume first that, as in the earlier analysis, the

OTRB operator has sufficient funds on hand for

purchasing accessibility technologies. If the firm

invested the $100, in 1 year the funds would be worth

$110 in nominal terms, or $100 when discounted. If the

accessibility technologies were purchased, the OTRB

operator would have zero funds and assets at the end

of the year, since the accessibility technology depreciates fully in value in 1 year. The difference between

these two figures is the opportunity cost of the

accessibility technology-$1 10 in nominal terms (actual expenditures), or $100 when discounted. Now,

assume the OTRB operator out of financial necessity

borrows funds to purchase the accessibility technology. It will spend $110 ($100 on principal plus $10 in

interest) at the end of the year to pay off its lender. On

the other hand, if the firm borrowed nothing and

purchased nothing, it would have zero dollars at the

16 b this discussion, the terms ‘‘invest’ or ‘‘investment’ refer to internal (intra-company) investment, such as buses or buildings, not

external invcstmen~ such as stocks or bonds.
128 0ver-the-Road Bus Access

end of the year. 17 The difference between these two

figures is the opportunity cost-$110 in nominal

terms, or $100 when discounted. This cost is the same

as the earlier case in which the firm had sufficient

funds on hand. Therefore, OTA concludes that the

true cost of purchasing an accessibility technology

is the same regardless of the financing method used.

Moreover, it is apparent that the real value of the

money spent when borrowing is simply equal to the

nominal value of the outlays in purchasing the

accessibility technology (both are $100). As a result,

the cost figures calculated previously represent the true

(opportunity cost included) cost of purchasing an

accessibility technology.

Imperfect Capital Markets

Earlier, it was assumed that capital markets are

perfect-that borrowing and lending occur at the same

(risk adjusted) rate. However, in some real markets,

there is an interest rate spread between borrowing and

lending rates.

If there exists an interest rate differential in which

borrowing rates are greater than (comparable-risk)

lending rates, the discount rate will be less than the rate

of interest on borrowing. Therefore the above theories

will not hold that: 1) a good will cost more when

purchased with borrowed funds; and 2) the real value

of money spent will be greater than the nominal value

of outlays. The amount that these costs are greater will

be proportional to the interest rate spread. However,

determining g the size of this spread can be difficult.

Due to the vague interpretation of the concept of risk

adjustment, one can justify the use of several “riskadjusted’ rates of borrowing. In December 1992, the

only traded bond of an OTRB operator carried a

Standard and Poors’ B rating and a current nominal

yield of 10.5 percent. Yields on U.S. Treasury notes

(T-notes) are generally regarded as a conservative

estimate of the market risk-adjusted lending rate. In

late 1992, T-notes with comparable maturity to the

OTRB operator’s bond carried a nominal yield of

approximately 7.0 percent. Therefore, if the 10.5

percent yield on the OTRB corporate bond is regarded

by the borrower (the OTRB operator) as being a

risk-adjusted rate,18 the borrower will see a 3.5 percent

difference in borrowing and lending rates.

However, if the OTRB operator views default on the

bond as possible, the risk-adjusted borrowing rate (in

the eyes of the OTRB operator) will fall proportional

to the probability of default. Therefore, if default is

likely, the risk-adjusted rate on borrowing will be close

to the risk-adjusted rate on lending and the rate

differential will be small.

Similarly, several positions can be taken in determining an empirical estimate of the risk-adjusted

lending rate. It is safe to assume that the rate on

Treasury notes and bonds represents the market value

on risk-free lending. Therefore, we can assume this rate

to be the risk-adjusted rate that OTRB operators could

receive on investments. This methodology corresponds to that outlined by the Office of Management

and Budget (OMB).19 In late 1992, the 10-year

nominal yield was approximately 7.0 percent.

In economic analysis, the discount rate (proxied by

a lending rate, in this case) theoretically represents the

return that an investor could earn on alternative

investments. Therefore, for OTA’s purposes, the

discount rate should represent the risk-adjusted rate of

return that OTRB operators can earn on internal

investments. This rate of return should be equal to (if

not greater than) the rate at which OTRB operators

borrow money.

20 Referring to the numbers quoted

above, since OTRB operators are willing to borrow at

10,5 percent, one can infer that internal investments

earn, at a minimum, 10.5 percent return.21 Following

17 lt may ~ppew, at fi~~ ~t ~~ ()~ operator does not redly have tie option of ~ves~g we $1(X) (as h tie fwst case) Or OpdIlg tO bOITOW

nothing and spend nothing (as in the second case) since the purchase of the accessibility technology is mandated. However, the operator does

have, for example, the option of selling assets in order to raise the necessary funds.

18 ~s Position Cm be justitied by ass urning that the OTRB operator views the bond as a contractual obligation that takes priority over all

other debt, equity, or investments.

19 Offlce of M~g~ent and Budget (OMB), Circular No. A-94, revised Oct. 29, 1992.

20 Ag~, M5 a55me5 tit @e operator sees little chance Of default on tie bon~o~.

21 It wo~d & ~atio~ t. bo~ow a( a ~gher rate ~ one expects to r~eive (risk.~justed) on me capi~ pwchased Witi dle bOmOWed

funds.
Reasonable Cost Estimates for Implementing Accessible Over-the-Road Bus Service 129

Table A-3-Comparison of Borrowing and Funds On-Hand, Including Discounting

Low-cost Medium-cost Traveler- Low-cost High-cost

traveler- traveler- complete OTRB High-cost accessible accessible

complete complete with externally traveler-com- Traveler-ready restroom restroom

OTRB OTRB mounted lift plete OTRB OTRB and liftb with lift with lift

Funds on-hand

cents per mile

$20,000

1.3

$23,000

1.5

$15,000

1.0

15,000

1.0

27,030

1.8

20,000

$35,000

2.3

31,000

2.1

56,000

3.7

39,000

$11,000

0.73

$34,000 $74,000

2.3 4.9

Funds on-hand

discounted

cents per mile

18,000 21,000 11,000

0.73

29,000 66,000

1.2 1.4 1.9 4.4

Borrowed

capital funds

cents per mile

30,000 33,000 19,000 49,000 110,000

2.0 2.2 1.3 3.3 7.3

Borrowed

capital funds

discounted

cents per mile

22,000 25,000 15,000 34,000 81,000

1.5 1.6 1.3 2.6 1.0 2.3 5.4

NOTE: This table does not include the cost of an emergency ramp unless noted otherwise.

a See text.

b This figure represents 1.2 of the price of a station-based lift (see text) and the cost of an emergency ramp and chair.

SOURCE: Office of Technology Assessment, 1993.

this argument, borrowing and lending rates should be

equal, and thus the rate differential will be zero.22

In all, it is uncertain whether or not there exists a

significant interest rate spread. For the sake of finding

an upper bound on costs, the results discussed below

and presented in table A-3 follow the assumption that

risk-adjusted rates are 10.5 percent for borrowing and

7.0 percent for lending, thus, allowing for the greatest

interest rate differential.

Other Factors

Throughout the discussion, it has been assumed that

there is no return to capital for mandated accessibility

devices. However, it is fairly clear that the existence of

accessibility devices will attract some number of new

OTRB passengers who were either unable or unwilling

to use OTRBs before, The additional revenues from

these new passengers will decrease the net costs of

accessibility devices, regardless of the financing method(s) used. These revenues are captured explicitly

(i.e., through revenue estimates rather than through

rate of return) in all outlay and cost estimates. In

addition, the access of more persons to OTRB transportation represents a return for society as a whole.

However, since this discussion is intended to focus

only on OTRB operators, this social return is ignored.

It has also been assumed that the OTRB operator

will raise funds through the sale of coupon bonds.

Although this need not be the case, any other method

of raising funds will have the same results. Other

possible schemes for raising funds are: bank loans,

term bonds (similar to a bank loan in that principal is

paid off progressively rather than at the bond’s

maturity), and equity. The theory of arbitrage provides

a solid justification as to why all methods are

comparable, provided that capital markets operate

freely and efficiently. If there exists a financial

advantage in one debt system over another, there will
130 0ver-the-Road Bus Access

exist arbitrage, which will be quickly eliminated by an

efficiently operating market mechanism.

Transaction costs of borrowing have been assumed

to be negligible throughout this discussion, and there

is no reason to believe them to be otherwise. Relative

to the incremental costs of outfitting an OTRB with

accessibility devices (upward of $40,000), the fees

charged by brokers and the costs to the operator of

issuing bonds and accounting for payments are nominal.23

Discussion of Methodology and Results

Cost estimates for accessibility devices, presented

earlier in this appendix, all assume that OTRB

operators have sufficient funds on-hand to pay capital

and operating costs of accessibility technologies when

the costs arise. In addition, although the figures are

adjusted to represent 1992 dollars, they are not

discounted for time preference or opportunity cost,

Therefore, the earlier cost estimates should be regarded

as estimates of real dollar outlays, not real costs. The

following discussion outlines: 1) the methodology

used to convert these outlays to approximate cost

figures; and 2) assumptions and methodology for

estimating outlays and costs under the premise that the

OTRB operator has sufficient funds on-hand for

operating expenses only, and not for capital expenses

(i.e., the OTRB operator must borrow in order to

purchase and overhaul accessibility devices).

The theoretical purpose of discounting real figures,

as discussed above, is to place a monetary value on

opportunity cost. A driving force behind the concept of

opportunity cost is the preference of investors and

businesses to acquire goods and capital sooner rather

than later. As applied to costs (rather than revenues and

acquisitions), the process of discounting attempts to

place a monetary value on the fact that businesses

prefer to postpone costs so that money can be either

invested or kept liquid in case a more important cost

arises. As a result, the process of discounting expenditures makes an expenditure incurred in the future cost

less (in discounted terms) than an expenditure incurred

today.

As discussed above, the yield on 10-year Treasury

notes is to be used as the lending rate, and therefore the

discount rate. However, since the previous cost estimates are quoted in real 1992 dollars, a real discount

rate is needed to convert these figures to present

discounted value. The 7.0 percent yield cited above is

a nominal yield (i.e., including inflation). To convert

this to a real yield, inflation must be subtracted.

Following the methodology outlined in OMB Circular

A-94, the real yield on 10-year Treasury notes is 3.6

percent. 24 As a result, this 3.6 percent rate was used to

discount the “real outlays” figures to find a present

discounted value estimate for “real costs” as presented in table A-3.

In order to estimate real outlays and costs if the

OTRB operator were to borrow all capital (presumably

due to financial necessity), OTA explicitly calculated

the yearly principal and interest payments that would

be incurred by an OTRB operator. As in the discussion

above, it was assumed that the borrowing would be in

the form of a 10-year coupon bond with a 10.5-percent

coupon rate. Using the same methodology as for the

discount rate, a real coupon rate of 7.07 percent was

calculated. This figure was then used to estimate real

(1992 dollar) incremental outlays to be borne by an

OTRB operator when purchasing one bus under the

assumption of borrowing, as presented in table A-3.

In the manner discussed above used to convert real

outlays to real costs in the case that the OTRB operator

has sufficient funds on-hand, OTA estimated the real

costs to the OTRB operator if all capital expenses were

financed with borrowed funds. As before, a real

discount rate of 3.6 percent was used, yielding the

estimates presented in table A-3.

23 S. far, it tEIS ~en assumed that tax policy treats all methods of financing capitrd investment equally. However, if OTRB operators were

to be given tax credits or allowed to take deductions for interest payments on loans/bonds used to fiice capital, the cost of capital using

borrowed fimds will become less expensive relative to the cost of using out-of-pocket funds. Whether this occurrence would make it absolutely

less expensive for OTRB operators to borrow funds instead of using funds on-hand is unclear, since it depends on other assumptions about

interest rates and the like. Nonetheless, a tax credit or deduction for interest payments will surely make borrowing less expensive relative to

the case in which no tax deduction is permitted.

~ Office of M~gement and Budge~ op. cit., footnote 19, states that inflation forecasts should be derived horn the GrOSS mme5tiC Product

price deflator estimates as cited in the fiscal year 1993 Federal budget. The long-term (greater than 5-year) estimate of inflation is 3.2 percent.

OTA recognizes that there is considerable debate about discount rate values and that OMB’S estimates are only one attempt to determine

appropriate rates.
—

Reasonable Cost Estimates for Implementing Accessible Over-the-Road Bus Service 131

The Effect of Potential Price Increases

on Overall Ridership

As discussed above, OTRB companies may choose

to pass the costs of accessibility technologies on to

passengers in the form of price increases. The number

of passengers choosing not to travel on OTRBs due to

these price increases can be estimated. However, the

estimates rely on data that are sketchy at best, so the

effect of increased prices was not included in the

model. A hypothetical calculation of the effect of price

increases can nevertheless help to illustrate the issue.

Useful data that are available include: 1) there were

roughly 31 million passengers who used fixed-route

OTRB service in 1990; and 2) the operating costs per

mile for fixed-route OTRBs total approximately $2.00.

Above, it is also estimated that providing accessible

OTRBs may cost about 2-cents per mile, or an increase

of 1 percent over previous operating costs.

Data that are not well-known include the way that a

change in the price of a ticket will affect demand. In

general, however, since the population of OTRB

passengers is disproportionately poor compared with

the rest of the population, it is safe to hypothesize that

a price increase could result in a decrease in overall

ridership. For example, if we assume that a l-percent

increase in the price of a ticket will reduce demand by

1 percent, then a l-percent change in the price of a

ticket due to the cost of providing accessible service

will decrease ridership by roughly 310,000 trips (or 1

percent of 31 million trips).

Thus, if OTRB companies pass the costs of accessibility onto passengers in the form of fare increases,

then significant numbers of passengers may choose not

to ride OTRBs in fixed-route intercity service. Since

most OTRB passengers have low incomes, increases in

OTRB fixed-route fares due to the implementation

costs of accessibility could disproportionately affect

those Americans who are poor.
Appendix B:

Federal and State

Oversight of

Over-the-Road

Bus Service

Federal Oversight

The private over-the-road bus (OTRB) industry is

supervised by a complicated array of Federal and State

agencies, no one of which devotes specific attention to

OTRBs (see figure B-l). For some purposes of Federal

oversight, OTRBs are treated as trucks, with regulatory

control divided among the Federal Highway Administration (FHWA), the National Highway Traffic Safety

Administration (NHTSA), and the Interstate Commerce Commission (ICC).l For other purposes, because OTRBs carry passengers, they are subject to

other regulations that do not affect the trucking

industry. In addition, private OTRB operators must

deal with various State economic and safety regulations.

Federal oversight functions fall into three categories: 1) manufacturing and operational standards; 2)

economic and environmental regulation; and 3) coordination and compliance. Few agencies deal specifically with issues of accessibility in transportation. The

Federal Transit Administration (FTA) has regulations

governing publicly assisted vehicles, and the Architectural and Transportation Barriers Compliance Board

(ATBCB) has developed guidelines for accessibility

technologies. Under the Americans with Disabilities

Act (ADA), the U.S. Department of Justice (DOJ)

participates in issues of discrimination, including an y

that might involve the OTRB industry.

Manufacturing and Operational Standards

National Highway Traffic Safety Administration—NHTSA is charged with developing manufacturing standards for OTRBs; buses are subject to the

same requirements as all other vehicles with a gross

vehicle weight over 10,000 pounds. NHTSA has

established more than 50 standards for such vehicles,

most of which apply to OTRBSs These standards are

organized into three series: crash avoidance, crashworthiness, and fire protection.2

Although its role has yet to be clearly defined,

NHTSA may evaluate accessibility technologies, This

could involve developing manufacturing standards for

boarding designs and vehicle modifications aimed at

facilitating accessibility.

Office of Motor Carriers—FHWA’s Office of

Motor Carriers (OMC) is responsible for the safe

operation of motor carriers, defined as those vehicles

weighing over 10,000 pounds that are designed to

carry more than 15 passengers or transport placardable

hazardous materials. OMC issues and enforces the

Federal Motor Carrier Safety Regulations-the laws

governing the safe operation and maintenance of

trucks and buses. The four main components of the

I InadditioL the Food and Drug A&mm“ “stration issues regulations governing OTRB galley service, restroom sanitation, and waste disposal.

249 cm Part 571.100131, 200-222.

132
Figure B-l—Federal Government Framework for Over-the-Road Buses (OTRBs)

1

Architectural and I

Transportation Barriers ~

Compliance Board I

Already developed

general standards for

boarding devices

■

1

Department of Justice

I

~

izE@

~E‘Env’ronmenta’regu’at’on

I Investigates violations

May issue standards of the Americans with

for vehicle alteration to Disabilities Act

achieve accessibility

r

‘T

Office of the Secretary j

~

r

.—

Federal Highway“T

Administration ~

1 1

Federal Transit 

-- -~

!

. -

-

Administration I k

I Office of Motor Carriers

■ Sponsors assistance

programs for rural intercity

■ Issues and enforces bus service

the Federal Motor Carrier

Safety Regulations ■ May test accessibility

technologies on publicly

■ Provides monies to States finance d

-OTRBs -

to inspect buses

including possibly NOTE: Only operators

accessibility technologies receiving Federa/ funds

are regulated by FTA

Issued preliminary

rules governing OTRB

accessibility

WiII formulate final regulations for operation of

accessible OTRB service

Could potentially designate

which agencies within

DOT would have

regulatory authority

over OTRB accessibility

■

■

Develops manufacturing

standards for OTRBs

Plays a role in

evaluating the manufacture of accessibility

technologies

r

Interstate Commerce

Commission

n Commercial regulation

■ Insurance requirements

■ Certificatlon of fitness

——.

I

Research and Special

Programs Administration

■ Regulation of the

transport of hazardous

materials (e. g., batteries

for wheelchairs)

o

SOURCE: Office of Technology Assessment, 1993.
134 0ver-the-Road Bus Access

safety regulations are: driver qualifications, driver

hours of service, vehicle maintenance, and accident

reporting. OMC will play a small role in developing

standards for the safe operation and maintenance of

accessibility technology on OTRBs. Regulations might

cover proper use of wheeled mobility aid tie-downs,

and the routine maintenance and safe operation of

accessibility technologies.

OMC safety investigators in each State review the

performance of interstate motor carriers to ensure

compliance with safety regulations; OMC’s Motor

Carrier Safety Assistance Program provides funds to

States to inspect buses and trucks at roadside inspection stations and to conduct facility audits. OMC could

include examinations of the operation of accessibility

devices in standard roadside inspections.3

Federal Transit Agency—FTA has been enforcing

accessibility requirements for public transit operators

for a number of years. Private operators receiving

Federal funds are subject to government regulations

applying to public transit agencies, and to those

provisions of the ADA dealing with public operators.

Consequently, ADA provisions and subsequent regulations applying to the OTRB industry, particularly

those involving Federal financial assistance, may

require 1711A oversight.

FTA is the only Federal agency that sponsors

assistance programs for intercity bus service. Under

Section 18 of the Surface Transportation Act of 1978,

some States have funded promotion of privately

operated fixed-route service in rural areas. (See ch. 2

for a discussion of Section 18 and other sources of

Federal assistance.)

Existing FTA regulations permit, but do not require,

public transit agencies to lease their equipment to

private operators for charter service if the private

operator is unable to provide equipment accessible to

individuals with disabilities.4 Because most transit

agencies with accessible OTRBs use them for commuter service, these vehicles are seldom available for

private use except during nonrush-hour periods and on

weekends.

FTA plays a limited role in Federal safety oversight.

Created in 1989 and funded by FTA, the Altoona Bus

Testing Center (Altoona, PA) tests all new model

buses purchased with Federal assistance. FTA determines specific design changes or retrofits to be tested,

and usually requires the manufacturer to arrange

testing with the center, which subsequently prepares a

report on the results. The Altoona Bus Testing Center

will probably play a similar role for bus-based

accessibility technologies.5 FTA pays 80 percent of the

cost of testing the vehicle to the Pennsylvania Transportation Institute, the operator of the facility; the

vehicle manufacturer pays the remainder.6

Research and Special Programs Administration,

Office of Hazardous Materials—Transportation of

wet storage batteries of the type used to power wheeled

mobility aids are subject to hazardous materials

regulations administered by the Research and Special

Programs Administration (RSPA). The general rule

requires that this type of battery either be securely

fastened in an upright position and protected against

short circuits and leakage, or be removed and packaged

separately. However, transportation of wheeled mobility aids equipped with wet storage batteries on

passenger vehicles such as OTRBs are not subject to

these requirements,7 RSPA also regulates the transport

of other hazardous materials carried on commercial

passenger vehicles, such as explosive, poisonous, and

radioactive materials.8

The Architectural and Transportation Barriers

Compliance Board—ATBCB was established under

the Rehabilitation Act of 1973 as an independent

agency of the Federal Government. The Board’s

responsibilities involve creating an accessible environment, and include investigating andexamining alternative approaches to the architectural and transportationrelated barriers confronting individuals with disabilities. ATBCB investigates citizen complaints about

3 Susan Petty, chief, State Programs Divisionj OffIce of Motor Carriers, personat communication Dec. 13, 1991.

4 Charter service is defined as “. . . transportation using buses or vans or facilities . . . for a group of persons who pursuant to a common

purpose have acquired exclusive use of a vehicle or service to travel together. . . “ (49 CFR Part 604.5e).

5 Bob Reifstec~ facility manager, Altoona Bus lksting Center, personal communication Sept. 14, 1992.

b 57 Federal Register 8954 (Mar. 13, 1992). This financial assistance does not cover the costs of the vehicle or persomel.

T 49 CFR Part 173.222 (Dec. 31, 1991), p, 497. Transportation of wheeled mobility aids equipped with such batteries on passenger aircraft,

however, are subject to spdf”c requirements. Transportation of @ cell batteries is not regulated,

8

49 CFR Part 177.870 (Dec. 31, 1991), pp. 743-44.
Federal and State Oversight of Over-the-Road-Bus Service 135

these barriers and helps government agencies formulate general accessibility standards.

ATBCB has developed standards for boarding

devices. These include manufacturing specifications

and accommodations for persons with differing mobility impairments. ATBCB may release standards regarding the design, manufacture, and alteration of

vehicles to achieve accessibility, but does not get

involved in vehicle or boarding device operation.

Economic and Environmental Regulation

The Interstate Commerce Commission—ICC was

one of the first Federal agencies to deal with transportation regulation, including the economic regulation of

the intercity bus industry. However, the Bus Regulatory Reform Act of 1982 (BRRA) almost completely

deregulated the industry, so ICC’s role with respect to

OTRBs is now very limited. ICC will probably play no

role in overseeing OTRB accessibility.

ICC examines applications from carriers for “fitness’ to operate fixed-route or charter service.9

Additionally, freed-route carriers must demonstrate to

ICC that their service is in the public interest. If a State

regulatory authority rules that a carrier cannot abandon

a route, the operator may appeal directly to ICC. The

burden then falls on those favoring continuation of the

route to prove that discontinuance is not in the public

interest and that continuation would not harm interstate commerce. 10

ICC can preempt any State regulation of interstate

bus service and can overrule State decisions regarding

fare increases and exit of carriers. Some States, such as

Massachusetts, have protested ICC’s role by automatically refusing any request to raise fares, forcing

operators to appeal to ICC each time they want a fare

increase. ICC almost invariably grants the request.ll

ICC now requires only Class I carriers, whose

operating revenues total more than $5 million, to file

annual and quarterly reports. Other bus companies,

formerly designated Class II and Class III carriers, are

no longer subject to reporting requirements (see ch. 2).

Furthermore, Class I carrier reports are not as detailed

as those required before deregulation. Consequently,

far less information about the OTRB industry is

available now than before enactment of the BRRA.12

Environmental Protection Agency—The Environmental Protection Agency (EPA) handles most

environmental issues affecting OTRBs. Most important for the industry are EPA regulations on air

emissions standards.13 The Clean Air Act of 1990

significantly tightened Federal emissions standards for

all motor vehicles, including OTRBs, but allowed

States to establish standards higher than those promulgated by EPA. As a result, OTRBs that do not conform

to the highest standards will not be able to operate in

all States. Other EPA regulations of significance to

OTRBs deal with noise pollution, bus storage facilities, and waste disposal.

ADA Coordination and Compliance

office of the Secretary of Transportation (OST)—

OST issued preliminary rules in September 1991

governing the accessibility of OTRBs and will formulate the final regulations based on the findings of this

OTA study. Those regulations will address the types of

boarding assistance required, as well as such operational issues as advance notice requirements. OST also

may designate which agencies within the U.S. Department of Transportation will have regulatory authority

over OTRB accessibility.

Department of Justice—DOJ will investigate violations of the ADA by all entities providing public

transportation services. DOJ could order violators to

alter their services in order to make them accessible.

While an individual challenging the accessibility of a

facility or service in court cannot be awarded punitive

9 Fitness consists of safety certification from the U.S. Department of Transportation and insurance coverage for vehicles and their operation.

10 Job Due et ~,, TranSporta~’on Senlce t. Sma// C~mmUnitie~: Eflects of Deregulation (Ames, w: Iowa Smte utiversl~ preSS, 1990),

p. 82,

1 ] Jeremy Kahn, “Stopping by the Bus Terminal on a Dark and Stormy Night: The U.S. Bus Industry Seven Years After Deregulation”

Transportation Law Journal, vol. 18, No. 2, 1990, p. 259.

12 Econometrics, Inc., ‘ ‘Background Paper on Accessibility for the Disabled and the Intercity Bus Industry,” OTA contractor report, Mar.

31, 1991, p. 60.

13 ~exmple of ~ operatlo~ rwuirement in EPA rewlatiom Pumwt to tie Clean Air Act wi~ direct implications for accessibility

devices is that many lift technologies require the bus to run 10 to 15 minutes during a boarding cycle, while EPA regulations forbid bus idling

for more than 3 minutes.
136 0ver-the-Road Bus Access

damages, a court can fine up to $50,000 for the first

violation found by DOJ and up to $100,000 for each

subsequent violation.14

State Oversight

States play a prominent role in both the economic

and safety regulation of OTRBs, but most States have

not yet determined their roles in overseeing the bus

industry’s compliance with accessibility regulations.

As with the Federal Government, State oversight of

private operators of OTRBs is spread among a number

of agencies.

California is the only State that, by fall of 1992, had

a regulatory program aimed at accessibility technologies. The California Highway Patrol is the main

regulatory body in California for wheelchair lifts.

California Code of Regulations Title 13 contains

specifications regarding lift operating features, design,

and testing requirements. These regulations were the

model for Federal standards governing accessibility

technologies. The California Department of Transportation and Department of Motor Vehicles have smaller

roles in regulating the use of wheelchair lifts.

Safety

As is the case at the Federal level, regulation of bus

safety has a relatively low profile in State governments. Only a few States have programs aimed at

regulating the safety of OTRBs. OTRB inspections are

now eligible for funding under the Motor Carrier

Safety Assistance Program, and some States take

advantage of this provision. These inspections could

include examination of accessibility technologies.

Michigan’s program is one of the most complete.

The State conducts two types of inspections: an annual

examination on the property of the bus company, and

random inspections, usually carried out at major

attractions such as sports stadiums or tourist facilities.

Based on these inspections, companies receive permits

for operation within the State. Because the State

Department of Transportation contends that its bus

inspection practices are more rigorous than those in

other parts of the country, Michigan has limited

reciprocity. Only buses with stickers from Michigan,

Pennsylvania, New York and the Province of Ontario

are considered acceptable to operate on Michigan

roadways without further State inspection.15

Other States concentrate on random roadside inspections of buses. California aims these inspections at

the “fly-by-night” companies that often operate tour

buses to and from gambling facilities in Nevada. These

companies’ buses frequently have safety violations,

often involving drivers’ hours of service.l6

In an attempt to standardize inspection practices, the

Commercial Vehicle Safety Alliance (CVSA), an

organization made up of almost all States and Canadian Provinces, has proposed uniform bus inspections

guidelines. These proposed standards are due to be

released early in 1993.17 CVSA has worked closely

with FHWA in the past, developing safety and

inspection guidelines for other motor carriers.18

Economic

State economic regulatory authority has greatly

diminished since passage of the BRRA. Most States

play a limited role in economic oversight of routes that

operate completely within State borders. While carriers can appeal State decisions to ICC, where they are

frequently overturned, many States continue such

regulation to delay rural service abandonments while

alternatives are sought.

Bus operators often face multi-State registration and

fuel tax problems. Presently, buses can be required to

register and pay a fuel tax in each State in which they

operate. However, Title IV of the Intermodal Surface

Transportation Efficiency Act (ISTEA) sought to

eliminate this requirement. By September 1996, States

must join the International Registration Plan and the

Intenational Fuel Tax Agreement, which require

operators to register and pay fuel tax only in their State

of origin, ISTEA also requires that a system be

14 Paul Stephen Dempsey, “The Civil Rights of the Handicapped in Transportatioru The Americans with Disabilities Act and Related

Legislation,” Transportation Law Journal, vol. 19, No. 2, 1991, p. 329.

IS Jeq Rudnic~ Michigan Dep~ent of Transportation@ personal communicatio~ Dee. 5, 1991.

16 U.S. con~ss, Offlce of ~c~oIo= Assessment Gea~”ng up for Safev: Motor Carrier sufety in a Competitive Environment,

OTA-SET-382 (Washington, DC: U.S. Government Printing Office, September 1988), p. 72.

17 Larry Stem Commercial Vehicle Safety Alliance, personal communicatio~ Jan. 12, 1992.

18 Offlce of lkchQoIo~ Assessment, op. cit., footnote 16, p. 72.
Federal and State Oversight of Over-the-Road-Bus Service I 137

implemented to allow motor carrier operators to

register their ICC operating authority and proof of

liability insurance with one State. This State will then

distribute the registration fees to other States in which

the bus operator provides service.19 Some States,

including Connecticut, Florida, Kentucky, and New

York, have adopted tax laws that require all companies

operating within their boundaries to pay a ‘‘corporate

tax, ’ ‘ even if they are based outside the State.20

A number of States go beyond economic regulation

and offer operating and capital assistance to intercity

operators (see ch. 2). Michigan, Massachusetts, Pennsylvania, and California have the most extensive

programs and have additional regulations governing

bus operations, as well, Both Michigan and Massachusetts, which support capital purchasing programs,

restrict the operation of publicly funded coaches. In

Massachusetts, 80 percent of the routes covered by

OTRBs purchased with State assistance must be within

the State. Because these buses are intended for

fixed-route operation, no more than 15 percent of the

bus-miles can be used in charter service, nor can these

buses provide charter service during commuter peak

hours.21 Michigan requires that OTRBs purchased

with State funds be used for fixed-route service only

and return to the State within 24 hours of leaving. The

State has further restrictions on purchasing OTRBs

manufactured outside the United States.

19 U.S. Dep~ent of Transportation Federal Hi@way~‘ “stratiou OffIce of Policy Developmen~ A Summury.” Infermodal Suq4ace

Transportation Efficiency Act of 1991, FHWA-PL-92-008 (Washington DC: U.S. Government Printing Office, 1992), p. 27.

20 )71a& wade, Gove~ent Aff~s, America BUS Association personal cornmtication, Apr. 29t 1992.

‘2] ~osome~cs, IrX., “Overviewof Experience of Operators of Accessible Over-the-Road Coaches,’ OTA contractor report, Jan. 28, 1992,

pp. 70-72.
Appendix C:

List of Boxes,

Figures,

and Tables

Boxes

Chapter 1 Page

l-A—Accessibility for OTRBs: The Americans with Disabilities Act .. .,., . . . . . . . . . . . . . . . . . . . . . 6

l-B—An OTRB Operator Views the Future of Intercity Bus Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

l-C—Raymond Smith and Janet Smith v. Greyhound Lines, Inc., 1982 . . . . . . . . . . . . . . . . . . . . . . . . . . 14

l-D-Transportation Needs of a Senior Citizen . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

l-E-Accessible OTRB Service in One Transit Setting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

l-F—Four Hypothetical Implementation Scenarios for Accessible Over-the-Road Bus

(OTRB) Service ... .....$ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

l-G-Concepts in Search of Development Funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

Chapter 2

2-A—What Is an OTRB? . . . . . . . . . . . . . . . . . . .,, ., .,, .,. ,,, ..,.., . . . . . . . . . . . . . . . . . . .+. ....,.. 43

2-B—Use of ICC Data in This Study... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

2-C—How Over-the-Road Buses Are Insured . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

2-D-Profile of a Fixed-Route Carrier . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

2-E-Profile of a Carrier Providing Mixed Services.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

2-F—Profile of a Medium-Size Tour Bus Operator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

2-G—Inaccessible Tour Bus: Evergreen Travel Service, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71

Chapter 3

3-A—Profile of a Traveler Who Uses a Wheelchair . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77

3-B—Profile of a Traveler Who Is Blind . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79

3-C—The Aging of America. ..,.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84

3-D-The Canadian Experience . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87

3-E-Charter and Tour Marketing for Individuals With Disabilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91

Chapter 4

4-A-Current Bus Accessibility Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ................105

138
Appendix C: List of Boxes, Figures, and Tables I 139

Figures

Chapter 1 Page

l-1—Intercity Bus Ridership: Class I Carriers, Regular Route Service, 1971 -91 . . . . . . . . . . . . . . . . . . 10

l-2—Intercity Bus Industry: Class I Carriers, Operating Ratios, 1971 -91 . . . . . . . . . . . . . . . . . . . . . . . . 11

1-3—Populations With Disabilities in the United States . . . . . . . . . . . . . . . . . . . . ... , . . . . . . . . . . . . . . . . 15

14-Projected Growth of Older Population as Percentage of Total Population . . . . . . . . . . . . . . . . . . . 16

1-5—Percentage of Assessable Boarding Opportunities, 1996-2016: Two Scenarios . . . . . . . . . . . . . . . 28

Chapter 2

2-1—Intercity Bus Ridership: Class I Carriers, Regular Route Service, 1971-91 . . . . . . . . . . . . . . . . . . 47

2-2—Points Served by Regularly Scheduled Intercity Bus Service, 1968-91 . . . . . . . . . . . . . . . . . . . . . . 47

2-3—Intercity Bus Industry: Class I Carriers, Operating Ratios, 1971-91 . . . . . . . . . . . . . . . . . . . . . . . . 49

24--Average Allocation of Funds by the Typical Bus Company.,.. . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

2-5—Intercity Passenger Travel by Family Income and Transportation Mode, 1977 .,..... . . . . . . . 54

2-6-Intercity Passenger Travel, by Age of Traveler and Transportation Mode, 1977.....,.. . . . . . . 55

2-7—Intercity Passenger Travel, by Travelers’ Area of Residence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

2-8—North Dakota Fixed-Route Service,1979and 1990 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

2-9—Fixed-Route Service From Columbus to Grand Island, Nebraska . . . . . . . . . . . . . . . . . . . . . . . . . . 61

2-10-Fixed-Route Service in Illinois and the Interstate Highway System . . . . . . . . . . . . . . . . . . . . . . . 62

Chapter 3

3-1—Intercity Passenger Travel by Age of Traveler and Mode of Transportation, 1977 . . . . . . . . . . . 81

3-2—Intercity Passenger Travel by Family Income and Transportation Mode, 1977 . . . . . . . . . . . . . . 82

3-3-Growth of Population, Ages 65 and Over, Actual and Projected . . . . . . . . . . . . . . . . . . . . . . . . . . . 83

Chapter 4

4-l—Typical Wheelchair Dimensions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ......................103

4-2—Symbols of Accessibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .....................,.....109

Appendix B

B-l—Federal Government Framework for Over-the-Road Buses . . . . . . . . . . . .....................133

Tables

Chapter l

l-l—Accessible OTRB Terminology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

1-2—Reasonable Cost Estimates for Implementing Accessibility Technologies (excluding

accessible restrooms) on OTRBs, Over the Lifetime of an OTRB . . . . . . . . . . . . . . . . . . . . . . . . . 31

Chapter 2

2-l--Characteristics of Greyhound Riders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

2-2—Selected Characteristics of Metropolitan and Nonmetropolitan Populations . . . . . . . . . . . . . . . . . 60

Chapter 3

3-l—Disability Statistics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76

Appendix A

A-l—Reasonable Estimates of Cost Outlays for Implementing Various Accessibility

Devices and Accessible Restroom Options on an OTRB .. ................................122

A-2-Sensitivity Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ................124

A-3-Comparison of Borrowing and Funds On-Hand, Including Discounting . . . . . . . .............129
Appendix D:

List of

Acronyms

ABA

ACAA

ADA

ALD

ATBCB

BRRA

CCTV

CTAA

CVSA

DOJ

DOT

DPU

EOTC

EPA

FHWA

FTA

FTA

GAO

GLIH

IBCAP

ICC

ISTEA

IQ

American Association of Retired Persons

American Bus Association

Air Carrier Access Act

Americans with Disabilities Act

assistive listening device

Architectural and Transportation Barriers

Compliance Board

Bus Regulatory Reform Act

closed circuit television

Community Transportation Association

of America

Commercial Vehicle Safety Alliance

U.S. Department of Justice

U.S. Department of Transportation

Department of Public Utilities

Equal Opportunity Transportation

Commission

Environmental Protection Agency

Federal Highway Administration

Federal Transit Act

Federal Transit Administration

U.S. General Accounting Office

GLI Holding Co.

Intercity Bus Capital Assistance Program

Interstate Commerce Commission

Inter-modal Surface Transportation

Efficiency Act

Intelligence Quotient

MCCD

MSA

NBTA

NHIS

NTBS

NHTSA

OMB

OMC

OST

OTRB

PUC

R&D

RCP

RSPA

RTD

SDW

SIPP

STA

TDD

TIDE

UMTA

UPS

140

Massachusetts Coalition of Citizens with

Disabilities

Metropolitan Statistical Area

National Bus Traffic Association

National Health Information Survey

National Trailways Bus System

National Highway Traffic Safety

Administration

Office of Management and Budget

Office of Motor Carriers

Office of the Secretary of Transportation

over-the-road bus

Public Utility Commission

research and development

Rural Connector Program

Research and Special Programs

Administration

Regional Transit District

Survey of Disability and Work

Survey of Income and Program

Participation

Surface Transportation Act

telecommunications device for the deaf

Travel Industry and Disabled Exchange

Urban Mass Transportation

Administration

United Parcel Service
Appendix E:

Contractor Reports

Prepared for

This Assessment

Copies of the following contractor reports done for this study are available through the National Technical

Information Service (NTIS), either by mail (U.S. Department of Commerce, National Technical Information

Service, Springfield, VA 22161) or by calling NTIS directly at (703) 487-4650.

Econometrics, Inc., “Background Paper on Accessibility for the Disabled and the Intercity Bus

Industry,” PB 93-163855.

Econometrics, Inc., ‘‘Evaluation of Methods to Provide Accessibility to Over-the-Road Buses and

Services,” PB 93-163830.

Econometrics, Inc., “Potential Demand for Over-the-Road Bus Services by Individuals with

Disabilities,” PB 93-163848.

141
Appendix F:

Workshop

Participants and

Reviewers and

Contributors

Workshop on Intercity Bus Access for Individuals With Disabilities, March 17, 1992

Ralf, Hotchkiss, Chairperson*

San Francisco State University

B.L. Bentzen

Boston College

Richard V. Burkhauser*

Syracuse University

Joseph Dabrowski*

Transportation Manufacturing Corp.

John Greene

Plymouth & Brockton Street Railway Co.

Brian Guthrie

Hickling Corp.

Mary Guthrie

Resident, Paul Springs Retirement Community

Frank M. Henry*

Frank Martz Coach Co.

Bill Hodgson

Stewart and Stevenson Power, Inc.

Jack Hoffman

Evergreen Travel Service, Inc.

Randy Isaacs

Isaacs & Associates

Brian Marshall

Transportation Development Centre

Jack Michaels*

Technology Access Consultant

Steve Miller

California Department of Transportation

Ronald R. Moore*

Burlington Trailways

Lyle S. Peterson

New Jersey Transit

Steven Reger

The Cleveland Clinic Foundation

Robert Reuter

Access Systems

Ken Sislak

Progressive Casualty Insurance Co.

142
Appendix F: Workshop Participants and Reviewers and Contributors 143

Donald R. Smith

Lift-U

Patricia Weaver*

Kansas University Transportation Center

Jim Smith

Greyhound Lines, Inc.

Charles Wheeler*

Wheeler Medical Laboratories

‘Advisory Panel Members

Workshop on Building an Accessible System for Intercity Bus Access

for Individuals With Disabilities, July 15, 1992

Frank M. Henry, Chairperson*

Frank Martz Coach Co,

A.J. Achabal

Boise-Winnemuca Stages, Inc.

Mary Kihl

Iowa State University

Greg Bosley

Eyre Bus Service, Inc.

Theodore Knappen*

Government Affairs Management Associates

Klaus May

Independent Consultant

Richard Burkhauser*

Syracuse University

S. Burkett Milner

Capital Tours, Inc.

Kenneth Campbell*

Ohio Developmental Disabilities

Ronald R. Moore*

Burlington Trailways

Mary Martha Churchman

U.S. Department of Transportation

Latonya Reeves

Atlantis Community Center for Independent Living

Joseph Dabrowski*

Transportation Manufacturing Corp.

Wendy Roth

Author

Joyce Driben

Social Worker

Jerry Rudnick

Michigan Department of Transportation

Dan Hartman

U.S. Department of Transportation

Willard Shorter

Senior Center for the Hearing Impaired

Shiloh Baptist Church

Barry Hecht

New York Department of Transportation

Ralf Hotchkiss*

San Francisco State University Jim Smith

Greyhound Lines, Inc.

Randy Isaacs

Isaacs & Associates Walter Spencer*

Day & Zimmerman, Inc.

Barbara Jacobson

Flying Wheels Thomas Taylor

Jefferson Lines, Inc.

Fred Kaiser*

Kerrville Bus Lines Michael Tompane

Author
144 0ver-the-Road Bus Access

Charles Wheeler, Jr.* John Winske

Wheeler Medical Laboratories Massachusetts Coalition of Citizens With Disabilities

* Advisory Panel Members

Access to Over-the-Road to Buses for Persons with Disabilities

Reviewers and Contributors

George Anzouni

Plymouth & Brockton Street Railway Co.

Martha Baer

U.S. Department of Agriculture

Joe Barthmeyer

Keeshin Charter Service, Inc.

William Bauer

Services for Independent Living

Sara Brandt

U.S. General Accounting Office

Sara Bruster

National Easter Seals Society

Jack Burket

Lancer Insurance Co.

Dennis Cannon

Architectural and Transportation Barriers

Compliance Board

David Capozzi

Architectural and Transportation Barriers

Compliance Board

Dale Carson

Complete Coach Works

James Carter

Antelope Wiley Bus, Inc.

Daryl Chubin

Office of Technology Assessment

Janice Clarke

Transport Canada

Robert Clark

National Highway Traffic Safety Administration

U.S. Department of Transportation

Harvey F. Dick

Neoplan USA Corp.

Kennely Diggs

Rehabilitation Engineering Center

University of Virginia

Kevin Dopart

Office of Technology Assessment

John Drawe

Bluebird Wonderlodge

Jerry Duskin

National Organization on Disabilities

Frederic Fravel

Econometrics, Inc.

Tracy Fredin

Wilderness Inquiry

John Fusco

Lift-U

Shari Gelman

Ivymount School

Duane Gerstenberger

National Federation for the Blind

Charles Gover

North Carolina Department of Transportation

Beth Hamby

Econometrics, Inc.

Judy Harkins

Gallaudet College

William Hinze

Ricon Corp.
William C. Hughes

Southeastern Stages, Inc.

Katherine Hunter-Zaworski

Transportation Institute

Oregon State University

Appendix F: Workshop Participants and Reviewers and Contributors I 145

George Izume

Urban Mass Transportation Administration

U.S. Department of Transportation

Stephen M. Johnson

National Tour Association

Nancy Jones

Congressional Research Service

Jared Jordan

Econometrics, Inc.

Steven L. Kehs

Department of Planning and Development

County of Cumberland, New Jersey

Mary Fran Kelly

Midwest Electronic Industries, Inc.

Dave Kessler

Q-Straint

Sue F. Knapp

Econometrics, Inc.

Martin Kramer

Southeastern Trailways, Inc.

Bill Kula

Greyhound Lines, Inc.

Norman Lederman

Oval Window Audio

Alan Leinbach

Dames and Moore, Inc.

Susan Liss

Federal Highway Administration

U.S. Department of Transportation

Charles Norman Littler

Motorcoach Industrial Engineering Center

Katie Maslow

Office of Technology Assessment

Jim Misek

Denver RTD Training Department

Denny Moore

Oregon Department of Transportation

Allen Morrow

Deputy Insurance Commissioner

State of Washington

Abigail Moss

National Center for Health Statistics

Yvonne Nau

Nautilus Tours, Inc.

Joe Pane

Lift-U

Endre Pataky

Adaptive Engineering, Ltd.

Susan Perry

American Bus Association

Susan Petty

Office of Motor Carriers

U.S. Department of Transportation

Edward Rastatter

U.S. Department of Transportation

David Raphael

Community Transportation Association of America

Mice Ramsey

Interstate Commerce Commission

Paul Reichmeith

Lift-U

Bob Reifsteck

Altoona Bus Testing Center

Dorene Reilly

American Travel Agency, Ltd.

Catherine Rice

Seattle Metro

Linda Roberts

Office of Technology Assessment
146 0ver-the-Road Bus Access

Gamble Rudd

Greyhound Lines, Inc.

Randy Rutta

National Easter Seals Society

James Santini

National Tour Association

Donna Shaunesey

JAUNT, Inc.

Peter Shaw-Lawrence

Society for the Advancement of Travel

for the Handicapped

Rosalyn Simon

National Easter Seals Society

Theresa Spivak

U.S. General Accounting Office

Steve Sprague

United Bus Owners of America

Larry Stem

Commercial Vehicle Safety Alliance

Beverly Stewart

Plymouth & Brockton

Street Railway Co.

Eileen Stommes

U.S. Department of Agriculture

Richard Summers

Southern California Rapid Transit District

Roger Tate

Urban Mass Transportation Administration

U.S. Department of Transportation

Irene X. Tzamaras

Econometrics, Inc.

Maryanke Van Den Berger

Maryanke Tours, Inc.

Diane Vanasse

National Transportation Agency of Canada

Elaine Wade

American Bus Association

John Walsh

New York City Transit Authority

Jeff Webster

Fresno Rural Transit

Bruce Wright

American Seating Co.

Pat Wright

Disability Rights Education and Defense Fund

Mark Young

Office of Technology Assessment

NOTE: OTA appreciates and is grateful for the valuable assistance and thoughtful critiques provided by the reviewers and contributors. The reviewers

and contributors do not, however, necessarily approve, disapprove, or endorse this report. OTA assumes full responsibility for the report and the

accuracy of its contents.
ABA. See American Bus Association

Accessibility Guidelines for Transportation Vehicles, 102,

113-114

Accessible service. See also Demand for accessible service

background, 74

costs, 3, 4, 26-31. See also specific technologies

current regulations, 105

current status, 13, 69-70

employee training, 98, 102, 111-112

experience with, 82-92

findings, 73-74

implementing, 2-3, 26-31, 33-34

passenger training, 112

pre-ADA milestones, 68-69

programs and projects, 83-89

terminology, 27

ADA. See Americans with Disabilities Act

Advance notice for boarding assistance, 70-72, 107

Age of travelers, 81, 82

Aging populations, 16,84

Air travel, 44,45

Aisle width, 106

Amalgamated Transit Union, 46

American Bus Association, 1983 Annual Report, 93

Americans with Disabilities Act

coordination and compliance, 135-136

“disability” definition, 74-75

implications and impacts, 14, 35-36

overview, 5-8

Section 305, 8,74

Amtrak, 101

Architectural and Transportation Barriers Compliance Board,

8,99, 134-135

Arm rests, moveable, 23

Assistive devices and technologies

boarding chairs, 21,98

Index to

Access to

OTRBS for

Persons With

Disabilities

carrying passengers as method of assistance, 20-21, 71,

98

closed circuit television, 110

computer magnification systems, 110

crawling messages and video monitors, 110

hearing technology devices, 94,95

lifts, 100-102, 106-107, 113, 115-116, 119, 120, 121

listening devices, 110-111

public address systems, 109

ramps, 22, 97, 98-100, 113, 116, 120

reservation systems, 2-3, 29-30, 107-108

restrooms, 2, 24-25, 32, 98, 106-107, 120, 122, 126

securement and restraint, 22-23, 97, 102-104, 113

signage, 108-109

storage, 71, 98

telecommunications devices, 109-110

use, 75, 94-95

vision technology devices, 94, 95

Assistive listening devices, 110-111

ATBCB. See Architectural and Transportation Barriers

Compliance Board

Auditory impairments, 78,94,95

Autism, 79-80

Backpack lift, 101

Baggage. See Package and baggage capacity

Blind persons. See Visual impairments

Boarding assistance, 70-72

Boarding chairs, 21,98

Braille signs, 109

Brockton Area Transit Authority, 85

Bus Regulatory Reform Act of 1982, 10,45,60-62

BUS stops, 62, 108-109

Canada, 86-88,92

Canadian National Rail, 86-87

147
148 0ver-the-Road Bus Access

Canes, walking sticks, and walkers, 23,75,94,95

Capital costs. See Cost of accessible service

Carrying passengers, 20-21,71,98

Charter and tour service

accessibility, 70

ADA standards, 2, 3

charter tours, 11, 55

charter transportation, 11, 55

comparison to fixed-route service, 56-58

costs, 34-35, 123

demand experiences, 89-90

demographics, 41, 82

deregulation effects, 54-55

description, 11-13,54-56

implementation strategies, 30-31

marketing, 91

profiles, 57, 71

retail tours, 11, 55

ridership, 58-59, 82

service mix, 54-56

trip rates, 92-93, 94

types of service, 55-56

Classifications, 43-44

Closed circuit television, 110

Coach enhancements, 97, 101, 104, 106

Cognitive impairments, 23-24,78-80,98, 108-111

Commercial Vehicle Safety Alliance, 136

Community dependence on rural service, 63-65

Community Transportation Association of America, 67

Competition

charter and tour services, 58

other travel modes, 41, 44-45

‘‘universal service’ and, 44 Computer magnification

systems, 110

Cost of accessible service,31 -32. See also specific technologies

additional costs, 118-119

borrowing and discount rate cost, 126-130

capital costs, 31-32, 115-116

case studies, 125-126

charter and tour service, 34-35, 123

freed-route, 32, 119-123

foregone revenue, 116-118

implementation costs per fleet, 124-126

implementation costs per vehicle, 115-123

maintenance, 31, 116, 120

new technology development, 4, 37-38

sensitivity analysis and, 123

Crawling messages and video monitors, 110

Deaf Persons. See Auditory impairments

Demand for accessible service, 13-20

adjusting for differences in travel patterns, 93-94

background, 74-75

charter and tour service, 89-90

demand estimation methodology, 92-93

estimating ridership, 18-20, 90

estimating trip rates, 93

projection difficulties, 92-94

Demand-responsive charter and tour service. See Charter

and tour service

Demographics

charter and tour service, 41, 82, 94-95

fixed-route service, 41, 81-82,94-95

individuals with disabilities, 19, 80-82, 94-95

projections, 82

revenues, 42-43

rural service, 59-60

Denver Regional Transportation District, 17,69,88-89,92,

111, 112

Deregulation

Bus Regulatory Reform Act of 1982,45

charter authority and, 54-55

effects on rural service, 60-62

Disabilities

ADA definition, 74-75

types, 75-80 Disney World, 70

Doorways, 22,23,97, 101

Elderly. See Senior citizens

Elevator lifts, 100-101

Emotional illness, 78-80

Employee training, 24,98, 102, 111-112, 118

Exterior lifts, 100-101

Federal government, financial assistance, 38-39,66-68

Federal Transit Act, 4

Section 18 funding, 66,67

Section 18(i) funding, 38, 39,67

Federal Transit Agency, 134

Financial assistance, 4, 36-39,42,66-68

Fixed-route service. See also Rural service

ADA standards, 2, 3

carrier differences, 49-50

carrier profile, 52

comparison to charter and tour service, 56-58

cost data, 119-123

decline of, 46-50

demographics, 41,81-82

description, 9-11,4546

expenditures, 49

implementation strategies, 27-30

interlining, 45-46

operating ratio, 11, 49

pooling, 30-31,46

ridership, 53, 81-82

service mix, 54-56

service points decline, 46-47

terminals and stations, 50-52

trip rates, 92-93,94

Flag stops. See Rural service, bus stops

FTA. See Federal Transit Act; Federal Transit Agency

Fuel costs, 118
Index to Access to OTRBs for Persons with Disabilities I 149

GAO. See U.S. General Accounting Office

Gender and racial characteristics of travelers, 81,82

GLI Holding Co., 46

Golden Gate Bridge, Highway and Transportation District

of San Rafael, California, 69, 92

Greater Attleboro Regional Transit Authority, 85

Greyhound Lines

court case, 14

marketing, 90

operating statistics, 9, 43,45, 46, 49, 51, 58

passenger surveys, 53

ramp technologies, 99

reservation system, 107

ridership, 81

rural service, 67, 68

terminals and stations, 51-52

Handrails, 104

Hearing technology devices, 94, 95

ICC. See Interstate Commerce Commission

Implementation, 2-3, 26-31, 33-34. See also Cost of

accessible service; specific technologies

Income of travelers, 81-82

Individuals with disabilities

demographics, 19, 80-82,94-95

findings, 73-74

marketing to, 90-92

travel characteristics, 80-82

Injury risk, 98

Insurance, 50, 118

Interlining, definition, 45-46

Intermodal Surface Transportation Efficiency Act of 1991,

67, 136-137

Interstate Commerce Commission

classifications, 43-44

registration requirements, 44

regulatory actions, 135

use of data, 48, 93

Interstate Highway System, 44, 60

Jefferson Lines, 58

Learning disabilities, 78-80

Leg braces, 75

Legislation, pre-ADA milestones, 68-69

Level-change devices, 2,22, 28,97. See also Lift technologies

Lift technologies, 100-102

availability, 69-70

costs, 115-116, 119, 120

integrated restroom/lift, 106-107

life of operation, 121

regulations, 113

Lift-U, 111

Listening devices, 110-111

Maintenance, 31, 116, 120

Marketing, 90-92

Martz Trailways, reservation system, 107

Massachusetts accessible service program, 83-86,92

Massachusetts Coalition of Citizens with Disabilities, 83,

86,91

passenger training, 112

Massachusetts Equal Opportunity Transportation Commission, 86, 90, 91

Massachusetts Intercity Bus Capital Assistance Program, 85

Massachusetts Port Authority, 85

MCI, restroom design, 32, 106

Mental impairments, 78-80

Mobility aids and assistive devices. See Assistive devices

and technologies; specific devices

Mobility impairments, 20-23,75-76,94-95,98-108

Motor Carrier Act of 1935,44

National Bus Traffic Association, 46

National Health Information Survey, 14-15,75,76,80

National Highway Traffic Safety Administration, 132

National Tour Association, Inc., 58

National Trailways Bus System, 44

NBTA. See National Bus Traffic Association

Need for accessible service. See Demand for accessible

service

Neoplan, restroom design, 32, 34, 106

Newfoundland Demonstration Project, 86-88

NHIS. See National Health Information Survey

NHTSA. See National Highway Traffic Safety Administration 1992 Motorcoach Marketer, 70

Nonprofit organizations, assistance for rural transportation,

66

NTBS. See National Trailways Bus System

Occupancy, 117-118, 121

Occupant crash protection, 104

Office of Motor Carriers, 132, 134

Office of Technology Assessment, ADA directives, 7-8

OTA. See Office of Technology Assessment

OTRBs. See Over-the-road-buses

Over-the-road-bus industry

abandonment of service points, 10, 45, 46-47, 63-65

ADA coordination and compliance, 135-136

characteristics, 42-45

economic and environmental regulation, 135

Federal oversight, 42, 132-136

findings, 41-42

future of, 12

history of, 44-45

implications and impacts of the ADA, 1-4, 35-36

ISTEA and, 67

manufacturing and operational standards, 132-135

pre-ADA accessibility services, 42

size and scope, 8-13

State oversight, 136-137

subsidies, 4

Over-the-road-buses
150 0ver-the-Road Bus Access

accessibility time frame, 27

coach enhancements, 97, 101, 104, 106

current accessibility regulations, 105

definitions, 2, 25,43

insurance, 50

life of operation, 121

miles traveled, 121

‘‘traveler-complete,’ 27, 28, 29

‘‘traveler-ready,” 27, 28, 29

Package and baggage capacity, 98, 116-117, 118, 121

Package service, 65, 120-121

Passenger service, 63-65. See also Ridership

Passenger surveys, 53

Passenger training, 112

Peter Pan Bus Lines, 85, 86

Plymouth & Brockton, 85,86, 111, 112

Pooling arrangements, 30-31,46

Privately operated service, 69-70

Public address systems, 109

Rail travel, 44-45

Ramps, 22,97,98-100, 113, 120

Regulation. See also specific regulations

arguments for government assistance, 4

current regulations, 105

economic and environmental, 135

effective dates, 8

Federal oversight, 42, 132-136

impacts of, 3

implementation of, 2-3

manufacturing and operational standards, 132-135

private entity requirements, 70-72

securement system, 113

State oversight, 136-137

State registration requirements, 44

State regulation, 44

vehicle-based lift, 113

vehicle-based ramp, 113

Rehabilitation Act, 68

Research and development funding, 4,37,38,39

Research and Special Programs Administration, 134

Reservation systems, 2-3,29-30, 107-108

Restrooms, 24-25, 106-107

costs, 98, 120, 126

design and development, 32

technology issues, 2

Retrofitting, 2,26,69, 115

Revenues, 42-43,57-58, 116-118

Ridership. See also Passenger service

charter and tour service, 58-59, 82

Denver Regional Transportation District, 88-89

estimating to indicate demand, 18-20, 90

findings, 73-74

freed-route service, 53,81-82

fluctuations, 96

loss of, 118, 119, 121

Massachusetts accessibility program, 85

Newfoundland Demonstration Project, 88

passenger training, 112

potential price increases on, 130-131

rural connector programs and, 68

Rural Connector Program, 67-68

Rural service

abandonment, 10

bus stops, 51,57,62

community dependence on, 63

demographics, 59-60

deregulation effects, 60-62

effects of ADA compliance on, 3

individual dependence on, 63-65

ISTEA and, 67

package service, 65

passenger service, 63-65

rural connector programs, 67-68

Scooters, securement and restraint, 102-104

Seating capacity, 117-118, 121

Seattle Metro, employee training, 111

Securement and restraint

availability, 97

design requirements, 102-104

of passengers in wheeled mobility aids, 104

system regulations, 113

testing and evaluation, 22-23

Senior citizens, 16,84

Sensitivity training for employees, 111-112

Sensory impairments, 23-24,76,78,94-95,98, 108-111

Service categories. See Charter and tour service; Fixed-route

service; Rural service

Signage, 108-109

Smith, Raymond and Janet, Greyhound court case, 14

State governments

financial assistance, 38,66-68

industry oversight, 136-137

Station-based lift technology, 22,97, 101, 119

Station-based ramps, 99-100

Steps, 23, 104, 106

Stewart and Stevenson Power, Inc., 88

Storage of mobility aids, 71,98

Stroke, loss of function from, 79

Surface Transportation Assistance Act of 1978, Section

16(b)2 funding, 66

Surface Transportation Assistance Act of 1982,69

Survey of Disability and Work (1978),76

Survey of Income and Program Participation, 76,80

Tactile maps, 109

Tariff filing, 44

Taunton Regional Transit Authority, 85

TDD. See Telecommunications devices for the deaf

Technology issues

Denver Regional Transit District, 88-89

findings, 97-98

implementation, 2-3, 4

implementation costs per fleet, 124-126
Index to Access to OTRBs for Persons with Disabilities 1151

implementation costs per vehicle, 115-123

Massachusetts accessibility program, 85

for mobility impairments, 20-23,98-108

new technology development, 38

Newfoundland Demonstration Project, 86-88

for persons without wheeled mobility aids, 23, 104, 106

reservation systems, 107-108

Telecommunications devices for the deaf, 109-110

Terminals and stations, 50-52,62, 108-109

Tour service. See Charter and tour service

Trailways Lines, Inc., 46, 51-52

Transferable ramps, 99

Transport Canada, 86-88

Transportation in America, 93

Travel agents and tour operators, 70

Travel patterns and characteristics, 93-94

Travel times, 117-118, 126

Trip rates, 92-93

calculating, 94-96

UMTA. See Urban Mass Transportation Administration

Urban Mass Transportation Administration, 68-69, 80,93

Urban Mass Transportation Assistance Act, 13, 68

U.S. Bureau of Census, 93

U.S. Department of Health, Education, and Welfare, 69

U.S. Department of Health and Human Services, 66

U.S. Department of Justice, 135-136

U.S. Department of Transportation. See also specific

agencies

Office of the Secretary, 135

regulations, 1-4, 113

U.S. General Accounting Office, 10,67

Vehicle-based lifts. See Lift technologies

Video monitors, 110

Vision technology devices, 94, 95

Visual impairments, 76, 78,94,95

Walkers and walking sticks. See Canes, walking sticks, and

walkers

Wheelchairs

profile of traveler who uses, 77

securement and restraint, 102-104

storage, 71

use, 94, 95

GFO : 1993 0 - 330–069 QL:3

ISBN 0-16 -041734-1