Note: The output shown below is from the 

Communication Access Realtime Translation 

(CART) system used in the On-Board Circulation 

and Seating Subcommittee meeting #6 and is 

generally unedited. The CART system was used to 

provide an accommodation to persons with 

hearing loss and persons who are deaf, and was 

streamed in real-time and available to the public 

on the internet during the meeting. 

UNITED STATES ACCESS BOARD

RAIL VEHICLES ACCESS ADVISORY COMMITTEE

ON-BOARD CIRCULATION AND SEATING 

SUBCOMMITTEE TELECONFERENCE

Thursday, June 12, 2014 -- 1:00 p.m.

Location: United States Access Board

1331 F Street, NW, Suite 1000

Washington, DC 20004

>> First is Melissa Shurland.

>> She is here from the Federal Railroad 

Administration.
>> Okay. That's good.

>> Robert Bob Reuter.

>> Access. Paralyzed Veterans.

>> operator boost. Bob Reuter.

>> Try that.

>> Testing one two three.

>> Sounds good. Gary Talbot.

>> Hi Gary Talbot Amtrak.

>> Marsha Mazz. Uh-oh Marsha is 

probably on mute.

>> Dennis Cannon.

>> Dennis.

>> Dennis Cannon one more time.

>> Dennis can none National Disability 

Rights Network.

>> Blair Slaughter.

>> Blair Slaughter Amtrak.

>> Steve -- I'm sorry Billy Altom.

>> The Association of programs for Rural 

Independent Living.

>> Steve Fuhrman.

>> (inaudible) with RailPlan I will just be 

listening.

>> Okay. Thank you. Steven Roman.
>> LTC.

>> Really good. Okay.

>> Ken Shiotani.

>> National disabilities right network.

>> Boost Ken Shiotani's line.

>> DRM better.

>> Ed Hoff. Ed Hoff, New Jersey Transit.

>> Sid Goldstein.

>> Sid Goldstein access transit report I will 

be participating.

>> Boost the line on Sid Goldstein.

>> His line is boosted.

>> Repeat your name please Sid.

>> Sid Goldstein access transit.

>> Christopher Hart?

>> And Michael Porter.

>> Amtrak.

>> in the room we have Melissa Anderson 

Molly Stoneman intern. Jim Pecht. Paul 

Beatty. Marsha Mazz. And Rose Marie 

Access Board and our CART reporter for the 

day is Beverly Early. We are still getting the 

site up and Paul is going to E-mail the site out 

to everybody. And I Lee it to Paul to actually 
say when he wants to started the meeting.

>> Well I don't have the new link.

>> Melissa you still on the line.

>> Hello.

>> I got an E-mail from frank.

>> Melissa Anderson.

>> I am on the line.

>> Oh, okay you were asking for people's 

names right?

>> No Rose was.

>> I'm sorry. Well, you didn't call my name 

here I am.

>> Oh, I'm sorry Frank . Okay.

 (LAUGHTER).

>> And Beverly is the line good? Frank 

Maldari I am trying to see if it pulls up. Who 

sent it to you. I forwarded it from her.

>> I am see the CART working just fine on 

my part. I removed the numbers after the 

Access Board to the previous posted one and 

it seems to be working just fine.

>> Well, maybe you could read the address 

to Paul he can type it into the E-mail.

>> I did what Frank said. So that gave me 
something that is working. 

>> The stream is good, okay.

>> Okay.

>> Ladies and gentlemen the stream is up. 

Paul?

>> and I have sent the E-mail so, we are 

ready to start. 

Good afternoon everybody this is Paul Beatty 

welcome to the 6th meeting of the on-board 

circulation and seating subcommittee. Your 

next meeting will be Thursday July 10. Just 

remind you that we -- I don't think we have a 

chat box function or if we do we don't want 

the CART operator focusing on that if you 

have questions if you are only using CART and 

you have any questions or desire to make any 

statements please use RVAAC-mail address at 

RVAAC @ access-board.gov you can send it to 

me and I will let the people running the 

meeting know that you have a question or 

desire to make a statement. We have no time 

on public comments scheduled for the call. 

The reason for that is anybody may participate 
in the call as if they were a committee 

member. Remember to give your name 

before speaking or immediately after speaking 

so that the CART reporter can record that. 

One comment that I want to make, some talk 

has been about the drawings sent in, it's 

important to note that when people send us 

drawings there is an added hoop that we have 

to go through besides the accessibility we 

have to make sure that they are not copy 

writed meaning that the person who owns the 

drawings will give us permission to use it. 

We have to place everything on the website 

which means the drawings will then be 

available to the public. So that's an ADA 

thing to go through besides convert the 

drawings into an accessible format which can 

take time. Particularly when they are in PDF 

since I have to go through a colleague who 

has a complete acrobat suite. So, that ends 

my opening statements I will turn it over to 

Melissa.

>> MELISSA ANDERSON: I want to thank 

everybody for participating today your 
patience I will turn it directly over to Blair 

because he is our chairperson go ahead Blair 

it's all yours.

>> Thank you Melissa. And Paul, let me ask 

you a question quickly, what format do you 

need to get things in? Because obviously I 

have been taking these things and converting 

them into PDFs but I can just as easily export 

them out as something more manageable like 

a PNG or something like that if you like.

>> PAUL BEATTY: For my capabilities if you 

send me a PowerPoint, I can convert that real 

simple. Because I have that software. So, if 

you cut and paste the slides into our 

PowerPoint, I know there are -- another 

option is Melissa and I were talking about 

when you send us something in PDF we can 

cut and paste the PDF pictures into a Word 

document and then all we have to do is put 

the ALT text description which is general in 

nature. So, it's more complicated if in the 

PDF document you have a lot of text, like you 

imbed several paragraphs to describe what is 

going on. If it's in an image format I can't 
easy cut and paste I have to go in and type it.

>> Well, I will do this, I will send you sample 

files because I think you may find that if I just 

give them to you as PNG it would be a 

seamless clean file going into Word or 

PowerPoint. Why don't we -- we will try that 

see and what works best I will export them 

accordingly.

>> PAUL BEATTY: Right. This is Paul 

Beatty jpg's is fine particularly the stuff that 

you want to use Blair we have to go through 

the issue about copyright obviously Amtrak 

stuff we don't have a problem with you are 

with Amtrak we got permission from 

New Jersey Transit to use their stuff but I 

haven't been able to get or gotten permissions 

for the other material.

>> This is Bob Reuter. I didn't send you 

anything that I wasn't public document.

>> PAUL BEATTY: This is Paul Beatty 

speaking. We would need the evidence to 

that effect. Either a statement from them and 

we can't just pull things off the web for 

purposes of federal government stuff.
>> Bob: Some of these companies are out 

of business now which could be interesting.

>> PAUL BEATTY: I will ask that question to 

your attorneys whether we have any problems 

we have to worry about if they are out of 

business. I will check on that.

>> Blair: Okay. As I look at our list of 

things that we need to nail down, it seems to 

me that if we obviously all have a lot of 

conversation that we would like to have about 

things and work through and put something 

down very firmly. But I think maybe another 

way to go at this is if we can go through 

the -- we are still working on the old agenda 

in item 5, if we can work through item 5 and 

put some numbers against those things sort 

of fill in the blanks, and then go away as a 

matter of homework write up our notes and 

comments to that and then come back to it 

maybe that would help our efficiency in 

getting through everything as a first pass and 

then really chewing on things. I think if we 

can see everything with something against it, 

then it lets us begin to really see how some of 
these things may overlap and one dimension 

or one space affect another or another aspect 

of the overall RVAAC work one of the other 

subcommittees. So, with that in mind, I am 

going to try to pick back up with where we left 

off, which I think was with the wheelchair 

space item 5.1.5 from the last meeting.

I hoped that we would have access to the 

drawing information and what we have done 

for those of you that are familiar, we have 

gathered a lot of floor plans and site 

elevations of existing vehicles of all sorts of 

modes, and combined them. So that rather 

than you know me getting stuck in the long 

distance or the inter-city rail world and other 

folks on the call thinking in terms of light rail 

and subways and things like that, we can all 

sort of mesh everything together because I 

will talk about things without meaning to 

strictly in inter-city and then sort of forget 

wow the things that we are doing affects 

everyone. Anyway, that's my suggestion. 

Does anyone have a thought on that as far as 

going through trying to plug some numbers 
into these various points and then coming 

back around and really hashing them out?

>> It sounds like a great idea.

>> This is Dennis Cannon does everybody 

have the agenda on the website for example? 

It's going to lead you through something and 

see if it works. If you are on the website, the 

agenda on the website the far right that's 

update guidelines for buses and vans. If you 

click on that, and then go down to the first 

bullet "proposed update" from that you go 

down to "chapter T4" -- there it is. 

Wheelchair spaces and securement systems. 

Click on T4 you get the actual technical 

provisions that are in the proposed bus 

section -- I don't know if the board decided to 

separate these things or not but initially the 

rail vehicle stuff is going to be inside this 

larger rule. But at any rate there is a size 

requirement it talks about -- we are going to 

change that because we are going to increase 

the dimensions but as long as we get the 

concepts down -- there is diagrams too. But 

it talks about things like front and -- this is 
what Ed Steinfeld said about the alcove 

provision if you enter from the side or the 

front or the back it is convinced on three 

spaces you have to add extra space. Basically 

there is the basic format of in this case it's the 

old 30 by 48 which we are going to change 

and if you go into an alcove in some way you 

have to add additional spaces to additional 6 

inches of length for example. If you have to 

move in from the side. So, what I think the 

issue here is except for the numbers like the 

length and width we are proposing to change 

this is already covered. We don't need to 

reinvent the wheel, we can basically say, 

this -- complying with this section is done 

and let the board do the --

>> MELISSA ANDERSON: This is Melissa.

>> Crossing the I's and dotting the T's as it 

were to get the reference for this specific 

thing does that make sense everybody? 

Because there is no point discussing a lot of 

stuff if we already got it.

>> MELISSA ANDERSON: This is Melissa 

Anderson, and the reference -- there is a lot 
of benefit to looking at the pictures and 

diagrams and understanding the concepts of 

what Dennis just walked you through. That 

was a proposed rule there have been 

significant changes we don't want to use that 

or assume we can reference -- reference a 

proposed rule. We need to kind of start 

from -- I mean the concepts are good so 

everybody understands the concepts of the 

alcove and maneuvering space we need to 

look what is necessary in the rail car 

separately.

>> Dennis: I wasn't saying we should pick 

these up because there have been changes. I

am suggesting if the concept works then what 

we need to do is discuss the rule number that 

is we are going to plug into that and let the 

board do the massaging about how you 

actually reference or fit it in there. The 

question is that, do we need to discuss at 

great length some of the things that are 

already contained in the concept. If the 

concept works, then all we need to do is worry 

about the specific numbers we are going to 
put in there rather than try to deal with how to 

get the alcove and all of this stuff.

>> That's a good point.

>> Frank: I think that's a great idea. 

Having an outline is -- helps you like Blair 

said at the beginning once you have an 

outline down you can argue about the points. 

But I think this is a great approach.

>> Blair: I am curious, where is -- with the 

proposed rule in process right now? I

assume some of the numbers and things are 

being massaged where does that stand?

>> MELISSA ANDERSON: This is Melissa 

Anderson we had written the final text we are 

working on the preamble it should be 

submitted to the board at the July meeting. 

Yeah, and then it goes through the office of 

management and budget before it gets 

posted.

>> In other words, about four years.

 (LAUGHTER).

>> I can't get the retirement in that time. 

Okay. Well, --

>> Well, I think looking at the information 
from the report that we used last meeting 

provides us with a lot of good information too 

Ed Steinfeld's office and the dimensions he 

gave us.

>> Yes, his dimensions is great.

>> Dennis Cannon: I like the thing Ed put. 

The only thing I recommend changing is he 

has got I think point number 1 is that the 

space must be immediately adjacent to the 

entrance or something like that. And it 

probably needs to say something like as close 

as practicable because in the inner-city car 

the entrance is in the vestibule you want to go 

into the compartment for the space itself. 

So, you don't want the spaces to be "quote" in 

the vestibule. You want to say as close as 

practicable to and make sure there is an 

accessible route to it. That's the only thing I 

saw from Ed's piece that I think needs to be 

changed.

>> Thanks Dennis. So, if we are looking 

down at item 5.1.5 on the list, I think 

that -- if I am reading Ed's information right, 

the wheelchair space would be 32 by 54 am I 
seeing that correctly?

>> Yes.

>> Blair: Well, I would say that if everyone 

is okay with that for the moment, as a starting 

point something to throw some darts at why 

don't we leave it there at 32 by 54 that's my 

recommendation at least. And then move 

to -- move through the path. And then I 

think part of what we should do and then I 

am -- since we are gathering all of this 

drawing information is to take that footprint 

and drop it in and see shall--what it impacts 

obviously in the world of inches inside of 

fixed dimension rail cars, those begin to affect 

the things around them. So, would someone 

like to make that official for the moment that 

we go with the 32 by 54.

>> So moved.

>> This is Linda. I hate to throw a wrench 

in the thing but I believe the -- the bi-level 

304 is 32 by 59. You could check that but I 

believe that's the case. I mean -- I am not 

saying that it can't be different but --

>> This is Melissa Shurman that's correct it 
is 32 by 59. 

I spoke to some of the folks at the IDeA 

Center months ago and I was told that the rest 

of that (inaudible) that's the Claire the 

wheeled device. Just not to include basic

>> Dennis Cannon: That's where the 

alcove stuff comes in from the proposed rule. 

It says basically when you have confined 

spaces you have to add more spaces and the 

54 would be a minimum not a set number, in 

other words, you could -- you could have 

more than that. 59 would comply. And it 

may be bigger than that if you need to 

maneuver into an alcove situation in which 

you need to add some additional room.

>> This is Frank. I think we agreed on the 

32 by 54 I thought the stumbling area which 

to me is still a stumbling area is is defining 

how to quality an accessible path. That's 

when we were talking about using boxes and 

models and we got into a long lengthy 

discussion about how to do it. I am not sure 

that what is proposed for the buses is all that 

clear either. But you know, the dimensions of 
the overall ought line of the wheelchair 32 by 

58 makes good sense based on the research 

that was done. That's a good starting point.

>> I am not suggesting it be changed I 

wanted to point it out.

>> Blair: Maybe Melissa Shurland can help 

me out here the PRIIA information, was 

that -- was that left as a recommendation or 

was that firmly placed in the --

>> Melissa Shurland: That is part of the 

bi-level specification requirements it's not a 

recommendation it's actually going to be 

incorporated into the California cars shortly.

>> That's just in the RFP right? That's not 

across the board it's just that particular order.

>> Melissa: It's in the prefix in used would 

have to meet the 32 by 59 requirement.

>> Okay.

>> That's the bi-level -- it's still --

>> Yeah, we are developing to assess 

additional feet tours so that's 

recommendations have not been presented to 

the executive board for final approval as yet. 

But I suspect the 32 by 59 will be just to keep 
the equipment consistent.

>> Blair: The thing that concerns me is 

where I have laid in the PRIIA dimensions, just 

using existing equipment because that's what 

we have to work with, the impact can be 

pretty big. And one of the things that I am 

curious about is right now we look at a 30 by 

48 rectangle that's 30 inches tall. And still 

looking at the 32 by 59 by I assume 30 

defining a cubic space or if that 59 as 

extremity going to be -- have a step overlap 

allowance or is it going to be a sheer vertical 

dimension.

>> Blair, this is Linda Martin, we -- we 

were discussing this Cal Trans on the 

procurement, yes, there is some allowance for 

under table space, for instance, it's the same. 

I mean that hasn't changed in terms of how 

much under table -- how much under 

something space can be included in the 32 by 

59. And, also, some space of the accessible 

route can be included in the 32 by 59. Just 

like it is currently. Only it's 30 by 48.

>> Right right.
>> Dennis Cannon: In the building 

guidelines basically you say that a certain 

amount of that space like of the 48 inches, 

maximum of 6 inches of the 48 can go under 

something that has a minute misdemeanor of 

9 inches of vertical clearance. I think because 

I recall from Ed's comment the other day he 

thinks the 9 is too small. So, I don't know 

what he wants it to be. So, he would allow a 

certain amount of say 6 inches of that space 

to go under something that has a vertical 

clearance of I don't know 10 or 12 inches. 

And then you could have up to I think in the 

building it's like 17 inches can go under a 

table that has a minimum of 29 clear inches. 

So, you get -- you get these issues of being 

able to stick part of that space under

something else so it doesn't have to take up 

the entire floor space.

>> Some of it can be shared between 

spaces.

>> Right. And it can share the -- the 

current requirement is generally that the 

wheelchair space has to ajoin or overlap part 
of the accessible route. You are allowed to 

have some of that space go into the accessible 

route. As long as you don't do things like, 

you know, block an aisle or what not in the 

rail car. As long as you get the chair over far 

enough it's not going to block the aisle.

>> That may be a dimension that would be 

worth us including that what that overlap 

dimension is. We have told people 6 inches 

sort of informally I don't know if there is 

anything in the rail car regulations that says 

how much it can encroach that space.

>> Blair: I am looking at it's as app for the 

PRIIA single level. 

>> Blair: It calls for minimum 34 by 52 

inches in a coach as well as lounge cafe and 

dining cars. (inaudible) 32 by 59 inches is 

recommended. So, what I am seeing there is 

it's almost like there is -- there is the 

definition for the maneuvering space which is 

almost as long as an alcove situation. But not 

quite. But then the same numbers given to 

the footprint. That seems a little bit 

confusing. That's why I thought maybe the 
intent was that -- there is moreover lap or 

implied overlap or maneuvering versus strict 

cubic space of 32 inches by 59 by I assume 

again 30 inches.

>> This is Linda. I think you are right 

Blair, I think there is some other benefit to 

making that clear because there was 

confusion with the bi-level as well.

>> Blair: Right. I think it's -- I would 

tend to agree with what Ed said about the 

overlap the 9 inches up and 6 inches out 

because what I have seen is a lot of the 

normal appendages on wheelchairs the 

footrest and things like that depending on the 

configuration are well love 9 inches, so -- well 

above 9 inches you don't get the maneuvering 

space it's a full dimension of the device 

instead of having you know that -- well, if you 

put your -- if your feet are in the 9-inch plane 

it can be ugly if your feet impact the seat or 

whatever may be -- might be hanging out 

there.

Well, that's a bit of a quandary. I am 

curious where did the 59 inches on the PRIIA 
come from what is the basis of that?

>> Maybe well can you speak to that.

>> This is Melissa Shurland. This was 

based on the research from the IDeA Centers 

as well as looking at the various sizes of 

power chairs and scooters. So the 32 by 59 

actually covered 90% of the power chairs. 

And I think about 80% of the scooters that are 

currently being used. And we have some 

background information on the research that 

went into some of the values in the 

specifications.

>> Frank: I am looking at Ed's work on 

minimum floor space he is showing the 32 by 

54 covers 90% of powered scooters and over 

95% of the manual operating chairs.

>> Dennis Cannon: I suspected that the 

59 came from including some of the 

maneuvering space.

>> It did.

>> Dennis: That you don't need. But if 

you then -- if that includes the maneuver 

space but then you look at that as the actual 

footprint of the chair, then you can't get it 
unless it moves side ways you can't get it into 

some spaces so what you would be stuck with 

is adding additional space beyond the 59 in 

order to get the maneuvering clearance. I

think you need to be careful about not 

specifying the foot print as being the 

minimum that you need for maneuvering you 

get into the problem of oh, now we have to 

add 6 more inches or whatever you allow for 

maneuvering space. I think that's -- you 

have to be careful about doing that.

>> Except for one this is Bob Reuter, again, 

if you have two facing each other the footprint 

can be 32 by 54 the two chairs if not moving 

at the same time is you know reasonable 

people wouldn't do that. There would be 

enough maneuvering room between the chairs 

for each one of them individually to get out 

not both at the same time they would share 

the maneuvering space.

>> Right.

>> Melissa Shurland: 32 by 59 would be 

in consideration maneuvering into the 

accessible space.
>> Melissa this is Rose Marie U.S. Access 

Board your line is popping in and out.

>> Sorry. About that I will call back in.

>> Okay. Thank you.

>> Bob Reuter again. We need a parking 

space or position standing still and the 

maneuvering space added to that.

>> Frank: The maneuvering space is a 

problem it depends on how are you 

maneuvering through the car. If you come up 

with a single number of 59 inches, maybe that 

works in one particular layout of the car and it 

doesn't work in another. I know this is where 

we got caught up last time is trying to explain 

how you can maneuver into a space. I said 

typically you put a box around the chair of 

whatever dimension it is 30 by 48 and 

demonstrate you can get in and out of there 

the maneuverability is associate with the 

typical wheelchair that we typically use. I

think if you can define it that way, then it is 

something that's functional and practical that 

you can demonstrate rather than coming up 

with a number that may or may not work 
depending on the particular layout in the car. 

You want to be able to get from outside the 

car to inside the area associated to be stored. 

And you should be able to do that. With 

whatever space is necessary, assuming that 

the envelope of your chair is in this case 32 by 

54. If you start putting additional numbers 

on there, really justifying them, I think it's 

going to be difficult.

>> The only problem with this I am saying 

as you say different chairs mid wheel drive 

power chair can pivot in its own dimension 

compared to the big scooters which is like 

parallel parking the car.

>> Gary Talbot: We need to come up with 

a number whatever it is plus or minus you 

have to have something to design to.

>> Dennis: Right. One of the things, 

remember that these guidelines aren't going 

to be applied to existing vehicles they are for 

new manufacturer. One of the things is if 

you are doing a design don't do a design -- I 

mean that cramps the chair and makes it 

impossible to maneuver in the space because I 
have seen this before in the old days with 

people putting alcoves or securement spots 

on light rail vehicles they did this in Dallas; for 

example they said no you had to be in that 

space but the rule doesn't really require that. 

It was impossible to get into that that was a 

design issue. If you are designing this thing 

from new look at the issues and space and at 

the footprint of the device that you need to 

do. And adjust your design accordingly. 

Don't -- don't make the design that's going to 

be difficult for someone to get into. It 

depends on if you have to move in you are 

approaching the space from the side or 

approaching it straight in like if you are going 

into a dining room under the table where you 

maybe be able to pull straight in there is a lot 

of differences. So, when talking about 

designing this, you are not going to de-- it's 

not going to work the numbers aren't going to 

work in the existing rail cars. For the most 

part. So, if you are telling somebody these 

are the numbers that you have to meet, then 

adjust your design accordingly.
>> These numbers to be --

>> the only requirement in a -- the only 

requirement in the statute for vehicles is 

re-manufacturing. And that is a term of art 

that means you strip it down to a frame. So, 

there is no requirement in the statute if you 

do an interior modification or whatever that 

you have to meet the requirement.

>> The re-manufacturing of the rail vehicle 

is not that uncommon that's what I was 

saying.

>> Well, defining what re-manufacturing 

is --

>> That would be --

>> I think Dennis has --

>> the D. O. T. has a definition. It has to 

do with it started way back when they did 

re-manufacturing of buses it has to do with 

money essentially. You get money to do 

re-manufacturing from the federal 

government only if you go to a certain level. 

And what it says is stripped down to the 

frame. So you have nothing left by the actual 

overall frame, that's re-manufacturing 
anything less than that is not 

re-manufacturing doesn't trigger the 

requirements this is statutory not regulatory.

>> Where is that Dennis?

>> Dennis: It's in part 2B of the 

ADAAG -- I mean of the ADA itself. It talks 

about re-manufacturing and specifically says 

things like, you don't have to add a lift to an 

existing vehicle and so forth.

>> I mean, I am following -- this is Frank 

again I am following along with what -- we 

are looking at for buses 30 by 48 they add 

dimensions depending on the entry point. 

You know. I mean, we can come up and say 

32 by 54 and put the numbers in the 32 by 59 

to add for maneuvering space. But I still 

wonder if you put a number in there, if you 

are limiting yourself. Typically, you know, it 

all depends on the car layout. If you wind up 

laying out the car the seating space turns out 

you have 60 inches in there you get 60 inches 

of space even if you don't need that much. 

You are going to make sure that you have 

enough maneuvering space to get in and out. 
So, you know it's not always a matter of I am 

trying to make the space as small as possible. 

It's your trying to maximize the amount of 

seats you can put in the rail car and 

depending how the seats layout. You are left 

with saying that I got 50 inch space or maybe 

60 inch space that's my two options. Either 

the seat is there or it's not there. Sometimes 

you wind up with a little bit more than you 

need sometimes it's a minimum that you 

need. I know you are -- we are trying to 

specify a minimum. I get nervous when you 

put a number on for the maneuvering space. 

It's hard to explain where exactly maneuvering 

space is. How far does it extend through the 

vehicle. It all the way across the vestibule it 

all the way across the aisle? I don't know. I

mean, like I said, the way we typically do it I 

don't know if you have been involved in 

evaluating new equipment Dennis but don't 

you -- if you specified a common wheelchair 

and said this is the dimensions these are the 

spaces you could go into the car and them 

straight that you can get in and out of there 
without a 5,000-step right angle turn that 

would be kind of what you are looking for. If 

you had to do what I am suggesting how 

would you do it Dennis.

>> Dennis: The problem that we ran into, 

this was exactly the thing in the old the 

current bus rule which says, you have to have 

a space for this -- for the wheelchair in the 

bus, you have to have the width of a door a 

ramp or a lift. And then it says you have to 

have sufficient maneuvering space to get 

there. From the door to the space. What we 

had is a lot -- what we had is lots and lots of 

problems people trying to figure out what it 

was. And one of them was the box approach. 

But the box approach assumes that a 

wheelchair is square rectangle it's not. 

Something in which you couldn't physically 

move the box through might be perfectly 

accessible. The other thing that complicates 

it is that there is -- you know, we have 

eliminated this definition although the D. O. 

T. rule we have eliminated the Access Board 

eliminated the definition of the common 
wheelchair because it was being misused in 

the wrong direction. The purpose of the 

common wheelchair definition originally was 

to set a size and weight requirement for what 

you had to accommodate and what was 

happening is the transit agencies were using it 

to exclude people from services to get them 

off the service because their chair didn't 

actually meet the requirement even though 

they could fit in the bus or van perfectly well. 

So D. O. T. still has the definition of the 

common wheelchair. The problem of course 

is that that definition which worked for a while 

doesn't work anymore. A lot of these 

four-wheel scooters don't quite need it. 

There are a whole bunch of things that don't 

meet the common definition of the 

wheelchair. We have to sort of define what it 

is, if you say a common wheelchair or let's 

say, for example, securement people are 

talking about the WC19 wheelchair most 

people don't have that wheelchair. The vast 

majority of people in the world aren't -- don't 

have a brand new wheelchair with the 
so-called transportation package. So, trying 

to define -- that's why we were hoping that 

maybe the IDeA Center would come up with 

a -- I think Ed said they are actually working 

on some kind of a template or a virtual -- I 

am not sure what you call it a visualization 

guide where you can actually maneuver the 

wheelchair through and maneuver it like a 

wheelchair. Wheelchairs don't move side 

ways very well. Sometimes people use the 

box model they sort of push it around and 

maneuver it and realize, yeah, the box fits 

through the door, and you can get it in 

through the space but the wheelchair can't 

actually maneuver that way.

>> Maybe it weighs 600 pounds

>> It's a real problem of trying to get a 

clear performance or a clear specification and 

the answer we came up with in all of these 

things is you have to do a combination of 

both. Otherwise it's not going to work.

>> Yes. I was just wondering I am just 

visualizing it myself this is Frank again if I 

would do it I would make a cube and then 
define the wheel base and put some limits on 

maneuverability and the fact that it is a cube 

and not really the -- what you might have 

provide conservatism in, you know, or more 

equipment being able to fit through the area

>> I think 600 pounds that should take 

people from moving it side ways.

>> Once you say, you know, this is the 

wheels and you can only pivot a certain way it 

limits you to working things perfectly side 

ways. So, I don't know, if I am making a 

mobility device and majority of majority of 

mobility devices I am guessing would be 

based on what a wheelchair can do and better 

if you -- film selling a mobility device I am 

going to make something more maneuverable 

in a chair realizing more space is designed 

with a wheelchair in mind. So if you could --

>> Dennis: This is Dennis. What we 

found is the wheelchair in -- this goes all the 

way back to the 1970's the wheelchair 

manufacturers are not interested in designing 

something that's transit compatible. 

>> The answer is most people aren't riding 
transit we don't care we will make it according 

to what we want to make it. That's where you 

get strange large small peculiar maneuvering 

devices because the wheelchair manufacturers 

aren't building to that. Plus, if you go to buy 

a wheelchair in your local supplier, that 

supplier is probably going to want to sell you 

the highest, you know, the Cadillac version 

not the Chevy. You probably are going to 

want the -- you are going to look at the chair, 

even if you were to asked the supplier does 

this chair fit on my buses that supplier isn't 

going to have a clue.

 (LAUGHTER)

>> Or he is going to smile and go why 

sure.

 (LAUGHTER)

>> The other side of the coin if you have 

something like I use a manual chair every 

ounce counts if I have to push it with my 

shoulders every day I refuse that that's about 

a pound and a half of the weight of the chair.

>> That's right.

>> Blair: This is Blair. As frank was 
talking I was thinking along the same lines. 

If you are coming from the -- from the 

manufacturing side and the railroad side, 

engineers like to have and designers for that 

matter like to have some reasonable 

constraints. Because what you find if you 

don't have some constraints then people 

wander all over the place in the design

process. And when you look at -- if you look 

at ASTM every test has a fixture or something 

that is defined. You have to build the 

condition according to the -- test method you 

build the condition and then you perform the 

test. And I know that no one wants to lock 

into anything that's over constraining. But 

from a -- from a -- the hope that you get it 

right the first time standpoint, it would be 

really wonderful, I think if we could do 

something along the lines of what frank 

suggested we have a cubic measure, we add 

some wheel geometry to it that makes it so 

it's not like it's on casters and they can't, you 

know, pull in and suddenly move 90 degrees 

side ways which is never going to cap.
>> Casters.

>> Yet I have seen that thing done you take 

the box -- if the box was floating on air you 

could put it anywhere but you couldn't put it 

on wheels doing that you bring it back to a 

point of realism. We could get wrapped 

around the axle trying to define what it is. 

But I think the goal would have to be you 

know in taking something out of the computer 

generated world and into what can often be a 

lot faster than the hardware world. Would be 

awesome. To be able to go through and, 

again, at least get very much in the ball mark 

with the device like that. I think we are 

always at risk no matter what we did, what we 

do if we brought in 20 folks and said please 

let's try it out, number 18 or 19 may come in 

with the newest scooter that has the worst 

case or maybe worse than the worst case 

dimensions we planned for and suddenly 

doesn't fit and then what do you do? You 

need to lean back on the regulation, of 

course, and that's the hard part.

>> Dennis: This is Dennis that's why we 
tried to sort of walk a fine line between the 

performance and a specific number 

specification and do a little bit of both. 

Because we are never going to design a 

vehicle that's going to accommodate you 

know 100% of the mobility devices. I come 

from California and there is a big rehab center 

down there called Rancho Los Amigos they are 

riding around on motorized journeys they are 

lying around on a journey lying out full length 

that are 6 feet long. You are never going to 

accommodate that on a vehicle I'm sorry. 

Those guys go all over on the streets. And 

they go out and go to bars and restaurants, 

but we have to assume that we are not going 

to accommodate everybody. 

Everybody -- every time you try to define 

something like a common wheelchair, you find 

somebody who doesn't -- who doesn't meet 

that requirement. And pretty soon you get a 

whole bunch of those people so I think you 

really have to be careful about trying 

to -- you need to nail down a little bit have 

some flexible room. Remember, there is 
always the equivalent facilitation provision D. 

O. T. actually has a process for awarding 

them, D. O. T. has a process where you apply 

for facilitation. That gives you wiggle room 

with coming up with a better idea and 

presumably those ideas then get folded into 

the next round of regulation or there is a D. 

O. T. issues these advisory notices which are 

essentially modifications of the regulation that 

say, here you can do this instead or you can 

do something like this and provide a better 

flexibility, justice doesn't do that. You are 

stuck with a lot of things in the building world 

that you are not stuck with in the vehicle 

world.

>> Blair: This is Blair I am with you there 

Dennis. It is a catch 22 it's the best 

description I can give it. It's difficult, I 

think -- I think it's safe for me to speak for 

maybe Ed and frank if they will allow me. It's 

frustrating as a provider you want to do the 

very best. Of course everyone knows you 

have got the other overwhelming pressure to 

put as many people as you can in a vehicle do 
it all safely. The last thing any of us wants is 

somebody to show up and not be able to get 

into the space and yet we think we have done 

a good job and done our best to 

accommodate and that's -- the risk is always 

there that you will have someone or some 

organization that wants to lean back on -- on 

a number for the sake of exclusion but I think 

more realistically from my perspective at 

Amtrak at least, it's -- it's to say, yes, we have 

met that, maybe we went a little beyond it but 

if the performance is -- let's say 54 inches for 

the length of the space, with maneuvering 

space allowance, when the maneuvering space 

allowance is gelatinous, it becomes very 

difficult --

 (LAUGHTER)

>> Like Jell-o. 

>> We did provide maneuvering space but 

here is a different device that almost fits. 

You know almost firsting into the space is like 

the airplane my old boss used to say, the 

airplane almost made it to the runway.

 (LAUGHTER)
>> It just, you know, almost doesn't work.

That is the perpetual quandary that we find 

ourselves in. Wanting to do well and not 

always being able to do that. But where do 

you draw that line. None of us want -- I 

don't think any of us want to be in the line I 

don't want to be provider drawing that line. 

But, yet, it is a real world of space and the line 

has to be somewhere.

>> Fortunately Amtrak is one of the ones 

that want people to make it. There are 

operators out there that use these regulations 

to exclude people. Every time you put 

something -- I have actually seen taking tape 

measures and measure you before they let 

you on.

>> I have never seen that. I would hate to 

be the person that had to go out and pull a 

tape measure out on someone

>> I wasn't real happy when they did it to 

me I know my chair is well under

>> This is Linda Martin about the 

measuring thing D. O. T. actually a couple of 

years ago took out the standard 30 by 48 and 
definition of the wheelchair and there is a 

definition I don't have it memorized verbatim 

but it's usually 3 or 4-wheeled device used for 

mobility or -- there is a specific definition but 

the reason it did that was just what you were 

just saying was that entities were using that 

30 by 48 dimension to exclude people from 

riding on buses and other vehicles even when 

they would fit. So, that was the reason that 

that happened. So, that may open up what 

you all decide to do here. Or at least keep 

that in mind as you are deciding what to do 

here.

>> Linda, do you know the reference for 

that.

>> Can I find it.

>> That would be great.

>> I don't have it off the top of my head 

but --

>> 49 CFR 37.3.

>> 3 or 5. Can't remember. Exactly.

>> Actually we are discussing this getting 

into a space, I think anybody that fits through 

the vestibule and get through the car would 
be able to maneuver just about into any space

>> Dennis Cannon: That's I didn't think 

that it's really by using the concept of when 

you got con fine on three sides you add extra 

6 inches for maneuvering space if that's the 

case if it's in the current or proposed 

wheelchair space for the buses, basically 

works as long as we maneuver -- as long as 

we massage the numbers that we want. 

Going from 54 by 32 and I think 

that -- remember, all of this is going to be 

subject to public comment when it comes out 

in the proposed rule. By that people people 

will have an opportunity, I think to really look 

at the numbers, do some designing and you 

will get comments from people saying that it 

doesn't work or you should do it this way or 

what not. Those are the kind of things that 

helps regulations confirm. And no regulation 

is going to include everybody at the end. We 

have a current requirement in the building for 

a 32 inch clear opening for a doorway. I have 

a friend who had a 34-inch wide wheelchair 

she was kind of heavy. My house has 
36-inch doors she could get in and out fine 

but she was basically couldn't get into a 

building that was designed -- defined as 

accessible that's just the way it works.

>> You almost have to set some sort of 

percentile has to be met you are never going 

to get 100%.

>> Frank: I think the extra couple inches 

does help you maybe that's something that we 

could do too. I have to tell you from my 

perspective if I had a box with requirements 

for maneuverability it's a lot easier for me to 

say you have to make that box with that 

maneuverability get into and out of that space 

just to add the extra 4 or 5 inches on there 

depending on the path may work. In our 

equipment you said if you get it through the 

door opening you should be good. But on 

our computer -- commuter rail we have 

50-inch wide door openings that's to get 

people on and off the train as quickly as 

possible

>> I think the box you build should be 

remote controlled so you can separate by 
remote. That way nobody can cheat.

 (LAUGHTER)

>> The restrictions I'm sorry Dennis. The 

restrictions that you put on it are the 

maneuverability you say it has two fixed 

wheels and two pivoting wheels in the front 

next you need dimensions and locations now 

you have restricted the motion of that vehicle 

you can create something like that in a CAD 

model and maneuver it around even in a 

design phase you can say, look, there is no 

way to get in there reasonably because this 

thing doesn't pivot that way move perfectly 

side ways you have to -- you have a pretty 

good way of checking to make sure that it's 

done it's relatively an easy requirement to put 

on a car builder, this is what we want you to 

do. This vehicle that I defined and 

constrained has to be able to get into that 

space easily. That's something that you can 

check. We can put the extra couple ins on 

there and hope it covers everything it may or 

it might not. In either case you are liable to 

miss something because you are not going to 
get everything. But if you define that device 

now it becomes a standard number -- when it 

goes out on in NPRM people make comments 

you fine tune it make it better. Number 2

maybe it's now a design goal for people 

designing mobility devices to say, Gee, I am 

going to design a mobility device it has to be 

at least maneuverable as this so people can 

get on to the transportation systems.

>> Most mobility devices come 

with -- wheelchairs don't come with warnings 

saying these aren't to be seating devices in a 

vehicle.

>> Right.

>> I expect their attorneys had them put 

that information in there

>> I am sure.

>> No offense Linda.

>> None taken.

 (LAUGHTER)

>> I am absolutely sure you are right on 

that one but --

>> Blair: This is Blair. What I 

would -- just listening to this, let me throw 
something out and let's see what everyone 

thinks about it. We have -- we talked about 

32 by 54 that's information that we got from 

Ed 32 by 59 looks like it's included by default 

the footprint of the wheelchair and 

maneuvering. But here is -- let me throw 

this out. 32 by 54 with maneuvering space 

that's the nebulous part. And then begin to 

address that the maneuvering space may 

overlap the movement of the vehicle by 6 

inches instead of 9 inches above the floor at 

11 inches above the floor. Does that sound 

like a place to start?

>> I think you are -- yeah it sounds 

like -- it's a starting point that seems like it 

might work. The dimensions might need to 

be jiggled some.

>> Obviously we won't be able to talk more 

singly about the dimensions until we try to 

plug information into real conditions. I do 

think that it would be very good if we in the 

process if it's within our purview to try to 

define or suggest the definition of -- of a of a 

geometric device a cubic device with fixed 
axle and wheel locations and maneuverability 

which I think would by default capture a large 

percentage of people and devices and just 

so -- again, thinking about the engineering 

side so that we have a reasonable way of 

testing and saying, okay, you are able to 

maneuver into this space or you are not you 

have to do something else. You got to come 

up with a different design that allows for 

maneuvering into the space and I wouldn't I 

don't think it would be fair to make it a center 

axle with casters on the end because -- with 

casters on the end someone mentioned earlier 

it can turn in its own dimension if you are 

fixed axle with steering axles at some 

dimension away from the fixed axle in that 32 

by 54 dimension you are going to create a 

strictly conservative device that helps define 

that maneuvering space that you need. And 

then, where can things overlap and that sort 

of thing. So, that would be my thinking. I 

don't know maybe someone from the board is 

that something that is in our realm to do, to 

define the measuring device? And my 
thinking is one, it gives us a design tool but 

also maybe it gives a way of prohibiting the 

kind of restrictions of simple measuring that 

Linda mentioned before. Where maybe a 

device was longer than the 48 and someone 

was restricted but if you have a test device 

that is defined then that sort of blows the lid 

off of that activity.

>> MELISSA ANDERSON: Blair this is Melissa 

Anderson you could come up with a 

perform -- performance specification.

>> This is Dennis I was dropped now I am 

back on.

>> One of the things I think about is how 

you actually -- we could define the cube 

rather solid how you can define 

maneuverability some chairs have like mine is 

mid wheel some have rear wheel drive with 

casters in the front some have front wheel 

drive with casters in the back and 

maneuverability changes dramatically I don't 

know how you define how that is

>> Bob Reuter the four-wheeled scooters 

you should define it based on those.
>> Frank: This is a tough one standard 

wheelchair may not exist you have two fixed 

wheels in the back casters in the front and 

there is maneuverability constraints based on 

that arrangement. If you have a 

middle -- mid axle chair you are going to be a 

lot more maneuverable than that if you have 

something else you may be less maneuverable 

I think that's a good starting point.

>> The problem with that every 

manufacturer runs down to the local 

pharmacy and buys the cheapest thing they 

fine and call that the wheelchair

>> No, no, no I am saying we define the 

spacing between the fixed axle and the swivel 

points we define you know the height, 

distance, and then you know, we try to 

encompass most built wheelchairs, remember

we are only defining maneuverability we are 

not defining the chair so you could have 

something that's slightly bigger and more 

maneuverable slightly smaller but from my 

point of view if you don't do this it makes it 

difficult to really evaluate whether you meet 
the requirements or not. Taking a tape 

measure and showing you had 59 inches here 

maybe that's not the whole story you can't get 

down the hallway to get there in order to 

maneuver in the space. So, I think -- you 

know, I think what Blair is saying is a great 

idea. We can write this up and come up with 

something I am sure. And then you know, 

just like you said the NPRM process gives us 

comments and people may add, fine tune 

whatever cubic we come up with and we have 

something that is really good. I mean, Blair 

as saying before our intention is to make it as 

accessible as possible you can't really always 

tell just by measuring a couple of dimensions 

so what we typically do is get a wheelchair 

and maybe put a box around it and make it 

maneuver to get in there

>> That's what you get down to --

>> MELISSA ANDERSON: This is Melissa 

Anderson. Blair, I'm sorry I tried to talk 

before you can write a performance 

specification we can't address how to enforce 

it that's outside of our scope, but you can 
choose to write a performance spec or 

performance standard that addresses the end 

result that you want to accomplish.

>> Thanks Melissa. This is Blair. I think 

the key thing is if we do that, if we define this 

measuring device that you can -- can you 

take from the entrance of the vehicle to the 

parking space and then into the restrooms 

and things and it has the built in maneuvering 

restrictions that are realistic that are not 

necessarily the best case, because as we said 

before the best case would be a 

center -- center fixed axle with casters on the 

end that can go anywhere. You can 

put -- that kind of device is marvelous. But 

if we make it restrictive enough and in doing 

that, consider -- make sure we don't miss the 

geometry of the mid axle sort of traditional 

wheelchair maneuverable device because you 

will get The Arc swing the diagonals of the 

corners of the box are going to be very 

different from one type to the other. Do a 

little -- do a little study to make sure that that 

dimension whether it's a rectangle or maybe it 
becomes a multifaceted space for the sake of 

maneuverability so that we can do -- we can 

do testing and design and verification based 

on a common device that is encompassing 

lots of -- lots of geometries.

>> That device has to be separated both 

forward and backwards.

>> Yes.

>> Then it would encompass more 

geometry.

>> Right. If you have say a power chair 

that has the front wheels are powered and 

casters on the back that's going to be a little 

different geometry than going the other way 

around. I think that you would want to take 

that device and go in one direction and then 

go back out again, turn it around and come in 

the other way. For people that have driven 

forklifts with steering in the rear, or devices 

like that, it's a very different dynamic than 

going the other way around. And you always 

wonder what is the back end doing what is it 

hitting because of the odd geometry back 

there.
>> So, for the sake of moving forward, can 

we -- can we move forward like that at least 

for now? I will be glad to draft something up 

or everyone's man

>> That's a good idea give us a strawman 

to play with.

>> Okay. I will do that. 

Marsha: Blair, this is Marsha Mazz question 

for you do you have capability to do anything 

in 3D modeling?

>> Blair: Yes.

>> Marsha: I am wondering if there is a 

way to work with Ed Steinfeld to extract his 

data to develop a 3D model?

>> Blair: I was going to ask -- I can 

stumble through our 3D program I was going 

to ask one of our really good guys if he could 

do that for me, and I am pretty sure it's not 

that big of a deal to establish the the 

constraints on the model. So that it would 

behave with those restrictions in other words, 

it wouldn't just slide suddenly 90 degrees 

or --

>> Marsha: I would think that you would 
need some kind of access to the data, and Ed 

of course doesn't make that easy.

 (LAUGHTER)

>> Marsha: But there might be a way to 

work with them to get them to develop the 

model with your input.

>> Blair: What I will probably do is work is 

the dimensions that Ed has already provided.

>> Marsha: That's a single dimension he 

has data points for every individual that he 

has tested.

>> Blair: Okay. Right. I am with you 

there. I am thinking about it from a starting 

point to try to come up with some 

dimensions. You know what, I will contact Ed 

and see what we could do.

>> Frank: I would think you try to look at 

the standard wheelchair fixed axle and swivel 

axle okay maneuverability with a wheel base 

this is fixed axle swivel axle this is box. You 

can look at other equipment to see if it's more 

or less maneuverable than that maybe he can 

ask that question. I don't think it's going to 

be easy for him to say, I think it's easy for 
anybody to say, this particular type of 

restraint are going -- constraints are going to 

allow all of the mobility devices to work. 

That's going to be a tough one.

>> Yes, this is Blair again, Ed, I think that 

you are -- Frank I'm sorry you are absolutely 

correct. Here is what I envision. What I 

would imagine. If we do this right, we get the 

spaces right in the design process, then a 

large percentage of people that come in using 

devices that we are seeing commonly now 

with the possible exception with some of the 

scooters can come in to a car because it's not 

always about seating space for a transit 

authority it's about dwell time let's get on the 

train and go. Come into the car, find their 

space or their seat or whatever is relevant to 

them. Get in it, doors close train goes. 

There may be situations where some of the 

less maneuverable devices are going to have 

to did a little parallel parking because of the 

outside geometry of and steering geometry 

that they have. But if we can keep that 

percentage very small, then -- but you can 
still get in without doing a ridiculous number 

of back and forths then I would say, well, okay 

that's reasonable. But I think that we would 

like to capture the as large a group as 

possible to just be able to go in and very 

quickly maneuver into a space and maneuver 

out of that space and off the train again at the 

end of the trip.

>> Yeah, I would think a long wheel base is 

going to get you that lack of maneuverability.

>> That's (inaudible).

>> Yeah I am saying if you make the wheel 

base relatively long most wheelchairs are less 

than that you are going to have a tighter 

constraint than actually exists and you will 

cover other types of devices that you weren't 

particularly envisioning but I think that's a real 

good way of doing it. These wheel base look 

like 15, 20 inches maybe something like that. 

If you require it to be like 30 inches you 

should be covering a large majority of the 

wheel devices one fixed axle one swivel. You 

can only pivot about one axle.

>> My wheel base is 17 almost 18 inches I 
have a traditional type chair.

>> That's kind of what I was saying maybe 

a little bit longer than that is what we fess 

identify. For sure, you should --

>> My chair is very short.

>> Yours is a short one I am not sure what 

the dimension is. That maybe Ed could help 

us out with that maybe add an inch or two to 

add a margin of safety.

>> But I think that it-- in deciding what the 

final recommended numbers might be we 

would like to see with this defined device 

maneuvering in with relative ease and then 

and if you go out to an extreme condition, of 

some of the scooters, can that device still get 

in but maybe takes a little bit more effort to 

get in there but it's doable you are not 

excluding just because of the steering 

geometry. It just may mean it takes a -- it's 

like me trying to parallel park it takes a while.

>> Gary could get into space with that 

wheelchair we would be here all day. Me too.

 (LAUGHTER)

>> Blair: Well, let me do this, I will write 
this up and try to make it as logical as 

possible to see if we can build a 3D model 

here that can help us add some of those 

dimensions and we will come back and chew 

on this one again.

>> This is Linda. I had a question.

>> Yes.

>> Linda: Basically, the question dealing 

with the request and Blair's request for the 

wheelchair definition where that's from. 

Should I send that because there is -- the rule 

that talks about that there is also FDA 

guidance talking about wheelchair spaces. 

Well that's what I was asking Melissa Anderson 

should I send it to you to distribute or how do 

I do that

>> MELISSA ANDERSON: Why don't you 

send it to Paul Beatty or RVAAC? Send it to 

RVAAC @ access-board.gov and Paul will take 

care of it.

>> Okay. Thanks.

>> As we museum forward I want to ask a 

question Bob Reuter.

>> Okay, Bob.
>> Bob: Are we going to be defining 

number of spaces for example, or is that 

beyond our purview?

>> I think that's a realm.

>> That's the scoping provision that you 

need to establish how many positions there 

are and what cars and how many doors and so 

forth that's all part of the spec you have 

technical specifications and scoping 

provisions as well.

>> Bob: That was the point that I wanted 

to bring up I have been reviewing a lot of 

plans over the past month or so it seems 

library the newer the car the fewer the spaces. 

And I know the regs said no more than two 

they all seem to be putting just one in now. I

am wondering if maybe we should up it to I 

am looking as just some two no more than 

four.

>> Dennis: No more than two is statutory. 

You can't get around that. But I think it 

should be for every other thing inner-city rail 

it's two my opinion it should be two for 

everything
>> Apparently there are a number of 

commuter operators that are getting cars with 

only one and they are calling themselves 

inner-city

>> This is Linda I am not sure it's correct. 

There is a requirement for the space to 

transfer and there is a requirement for space 

to park and stay in the wheelchair. And not 

more than two per car is (inaudible). In the 

statute. I think the reason they are doing less 

Dennis I am sure is familiar phase in the 

number of wheelchair spaces Amtrak was 

initially trying to meet that by having two 

spaces because it's one per car you are saying 

one space per car of the train set. And 

Amtrak was initially trying to meet that by 

retrofitting cars to have two faces on -- two 

spaces on some car.

>> One per train roll.

>> Yes, eventually they rolled out new 

trains cars they have one per car as opposed 

to two every other car.

>> but the problem is now more and more 

people are traveling and people are traveling 
together.

>> Right. It is a problem.

>> This is Blair. As I recall, too, initially 

the number of -- the number of spaces had 

equal the number of cars per train with no 

more than two of those spaces in any one car. 

The restriction of two was to prevent authority 

from coming in and declaring that half of this 

car is accessible. And you got 10 wheelchair 

spots there.

>> Cattle car roll.

>> Cattle car effect.

>> The original requirement or the some of 

the commuter folks wanted to make a single 

car for nip to be the accessible car and be 

done with it that's where the cattle car issue 

came up. The other issue about number of 

spaces per coach cars and what not had to do 

with the interim requirement that is already 

long past didn't actually apply to new cars. It 

was -- it was to make sure by the time 

whatever the date was you had that number of 

spaces it meant that you had a choice you 

could buy new cars or you could retrofit some 
of the older cars and take out some seats 

which is what Amtrak did. But that provision 

is gone now, it's long past in the requirement 

now is for all new cars. And, again, 

inner-city it's at least one no more than two. 

You are right access seating spaces a lot of 

companies are putting in one. Which 

is -- which is why I think you should change it 

to two, period.

>> This is Blair. From the other end of the 

spectrum, what we run up against is there is a 

lot of cases where two seats two spaces 

become very valuable. We have a couple of 

people traveling together. And with that 

right now the definition is a space to park a 

wheelchair and stay in it and another a seat to 

transfer to and fold and store wheelchairs. 

So, you could have -- you could have two 

people arrived in wheelchairs. With the new 

thinking be two spaces to park a wheelchair 

and stay in it and what would we do as far as 

fold and store. I will talk about fold and store 

more I don't see a lot of wheelchairs these 

days they can be folded.
>> Wheelchairs are getting to the point 

where nobody folds them anymore. They 

can't be.

>> From a --

>> This is Dennis.

>> I'm sorry, go ahead Dennis. 

>> The original thing was the two referred to 

each type. In other words, one but not more 

than two parking spaces and one but not 

more than two transfer spaces. And in the 

regulation we said, a transfer seat can be a 

normal seat it doesn't have to be any special 

thing. What that means is basically there is a 

double seat on one side of your car, the train 

car, and a space on the other side with the 

wheelchair. Somebody can transfer into the 

regular train seat it doesn't require anything 

special to do that. The place to store the 

wheelchair is the tricky part because you are 

right, a lot of chairs don't fold or the wheels 

come off they collapse but so defining the 

space, the original intent was to define the 

space that was wide enough to fit a manual 

folding standard chair in, and somehow 
squeeze it into a space where you 

could -- where you would normally put the 

lug gag. You are right, these days I am not 

sure that you could define the space two 

spaces to store a wheelchair if you assume 

that the wheelchairs are not going to be 

folded. I don't think you are going to be able 

to do that.

>> The one thing with storage it doesn't 

have to have the other amenities like windows 

and things like that.

>> That's right. But now -- and now I 

see -- there doesn't seem to be on Amtrak 

there doesn't seem to be any restriction unlike 

airlines on the size of carry on luggage I have 

seen people bring luggage on to the trains 

that you know have a hard time fitting in the 

space and sometimes it's quite a bit of space 

it's a big open space one of those be people 

moth quote quarry on suitcases take up all of 

the space. 

**NOTE: Behemoth

>> There is one that defines the size

>> Probably as effective as the limitations 
in the aircraft.

 (LAUGHTER)

>> It stops at BMI air for the Marc trains 

with the luggage going to the airport. 

>> Blair: The PRIIA recommendations were 

for two spaces. And from a -- when you are 

on reserve trains versus showing up, when 

you are dealing with reserve spaces, the 

railroad has the opportunity to get the space 

ready. 

And one of the things that I was thinking 

was that if we have -- if we can make the 

vehicles so they are more flexible, then there

is the potential of having the best of both 

worlds.

>> Doesn't the regulations allow for folding 

seats?

>> Blair: Yes. But if we are talking about 

clear floor space and things like that, then 

how you -- how you achieve that, I guess is 

what we have to make sure that we are clear 

on.

>> Dennis: Yes, this is Dennis in the bus 

realm when you are talking about folding 
seats typically it's the side facing seats behind 

the wheel well which you flip up as long as 

they are fairly thin, and whatever, you can still 

get the space requirement. With a 

chair -- the problem with things like Amtrak 

is that you are talking about in many cases as 

opposed to even commuter rail, you are 

talking about somebody who is going to be 

sitting in one of those seats for maybe a very 

long period of time. You don't want the kind 

of seat that you provide in the bus or in a rail 

vehicle that is not going to make it in terms of 

the comfort needed for that kind of seat. So, 

you are a lot more restricted when you on 

what kinds of quote fold up seats if you look 

at the seats that are the spaces in a over the 

road bus for example, that are, you know, 

fairly comfortable seats, in order to get the 

one wheelchair space, that's actually two 

requirements. But for each wheelchair space, 

they have the seats that sort of fold up and 

then slide back against each other and 

collapse. And what you end up is losing six 

seats for every wheelchair space. And I am 
not sure that that is something that -- that 

the inner-city rail folks are going to be very 

happy with.

>> Blair: Dennis, this is Blair I can tell you 

they won't be very happy at all.

 (LAUGHTER)

>> Blair: We have the -- there is an 

acursed law that says we have to behave like a 

private business. And yet, we are the 

receivers of federal money so we have to also 

be accommodating and that creates a lot of 

conflict sometimes. But I think that most of 

these things can be resolved with creative 

design so long as the regulations that we are 

using are broad enough to allow for that. 

And, I mean, that gets back to some of the 

conversation about the limitation of the 

number of spaces. I don't think -- the 

limitation obviously was to prevent an 

authority from creating a cattle car and 

saying, okay, everyone in a wheelchair you 

have to sit here. Wasn't really thinking about 

the concept of wow well my friend and I both 

happen to be in wheelchairs are traveling 
together. Why would I be in this car and they 

are in the next car sort of defeats a big part of 

the fun of traveling together. It could be 

three people or four people. And I would -- I 

would like for us to have the flexibility to 

accommodate people and yet when we don't 

need that much accommodation, to have the 

opportunity to still recover that revenue from 

the seats. And that pressure is -- is pry on 

every seat space of Amtrak it's probably 

especially high on the long distance trains 

where they tend to be the greatest money 

losers depending how you do the math.

>> Yes. 

>> So it is again we are back to the catch 

22 of actually wanting people to come and 

ride our trains and enjoy the trip and come 

back over and over again, and then having 

that ugly evil bottom line that we have to deal 

with. So, back to the wheelchair storage. Do 

we need to give a further definition then has 

been done in the past for what the folded 

wheelchair space is? They arrive in a fold 

willing chair -- and then -- folding chair.
The trickiest part of that if we go away from 

having the fold and store, if it's two 

wheelchair parking spaces, and a seat to 

transfer to and store a wheelchair if we are 

aware from the folding wheelchair condition, 

then we are in to take ago lot of seats out of a 

vehicle. Even in a car car it reduces it's 

potential obviously. What are we going do 

with that.

>> This is Linda. I think that you can take 

out the folded wheelchair concept because 

that's in the statute. I mean, I think that 

perhaps your second wheelchair space could 

be the space that the folded a folded 

wheelchair would go in perhaps, you know, 

but you can't take out that concept 

completely. And the other thing, you may 

remember this, we just went through an 

exercise trying to figure out, you know, what 

was reasonable for a space for a folded 

wheelchair for the bi-level cars. And there is 

no dimension in the guidelines so to the 

extent this group could come up with a 

number that would be great. We gave -- we 
gave the the number based on the various 

input from Amtrak and others but we are not 

sure if it's the correct number but we can, you 

know, maybe that could be the place that we 

start in this group.

>> I am looking at the diagram of the 

superliner coach at the moment. And it's sort 

of like you have got three spaces total, it can 

be either two people in wheelchairs one 

transfer or two transfers and one wheelchair. 

If you understand what I am talking about 

here.

>> Blair: Yes, but at the end of the day in 

that existing condition you should have -- if 

two people arrive in wheelchairs at a minimum 

you should have a space for someone who 

wants to stay in the wheelchair and a space 

for someone to transfer and store a 

wheelchair. Anything we do beyond that is 

great.

>> This looks like three spaces. You can 

have two people stay in the wheelchair have 

one storage or one person stay in the 

wheelchair and have great space for two 
storage I am going with what the drawing 

looks like

>> Twofolded wheelchairs could go in the 

one park wheelchair space

>> Right.

>> Right. I know the car that you are 

talking about. There -- they are across from 

each other.

>> Right.

>> Um-hmm. I am not sure which one it 

is Blair.

>> Lower level superliner coach.

>> Frank: Blair, the current regulations for 

inner-city require you to have one wheelchair 

parking area and one space for somebody to 

transfer to? Which could be a fixed seat. 

And one storage location.

>> Yes.

>> Frank: All right you are asking if you 

go with two parking areas you need two 

transfer seats and two wheelchair storage 

locations right? I am just trying to clarify it 

that's what you are asking right? That's what 

we are discussing.
>> Blair: My assumption would be that 

that would be the case. That if -- that you 

would have that capacity. These the logic.

>> Bob: Just wondering if three is the way 

to do it where you have either or one space 

becomes a barking -- becomes a parking 

space or a sitting space a parking space or 

storage space

>> You are saying Ed if it's a single parking 

space and you remain in the wheelchair, and 

up to -- up to three -- say everyone 

transferred out. You could transfer into three 

locations, and still have room to store 

wheelchairs?

>> Right. That would probably work that 

way. But it wouldn't -- it would only be set 

up as two unless all three transfer. And then 

I don't know how third person would transfer 

because then there would be storage space 

would be occupied. That wouldn't work.

>> Blair: I --

>> Dennis: This is deny ins I wouldn't 

assume the person transfers and then stores 

fold and stores his or her own wheelchair. 
There is going to have to be an assumption at 

some point the conductor gets involved in the 

process.

>> Well, if it's anything like me my chair 

never goes the length of my arm away from 

me.

>> This is Linda. You know, what we have 

run up against here are people who use 

wheelchair as a mobility device ongoing like I 

do and apparently like you do. And then 

there are elderly sort of person who a 

wheelchair is is used to get them on the train. 

They are given the seat the conductor get gets 

the wheelchair and folds it and stores it so 

there is a little bit of both. 

>> Frank: How much of that happens this 

is Frank I am just curious a lot of the elderly is 

using mobility devices that are not 

wheelchairs they take up at least a the space 

of a wheelchair.

>> Yes, a lot of elderly are using scooters.

>> Frank: Yes I am saying I don't know

how often somebody is folding up a 

wheelchair to get it out of the way.
>> Blair: This is Blair we have a lot -- a lot 

of folks that show up that come all the way to 

train side and even use one of the wayside 

lifts to get up to train level where there is no 

level boarding. And then they will either go 

in on wheelchair or they will ambulate into the 

space. But they are -- their range is very 

limited. So, once they are on board, they 

may not even bring the wheelchair with them 

it may be for boarding getting from the 

distance from the station to the car and then 

back again. But in the train it's maybe not so 

bad

>> MELISSA ANDERSON: Blair this is Melissa 

we are 5 minutes out from finishing up.

>> Blair: Yes.

>> We have 20 more minutes to go.

 (LAUGHTER)

>> I want to make a comment about the 

wheelchair inner city rail is different from 

transit there is lots -- we get complaints from 

the people all the time FRA no offense Blair, 

but you know where where they do show up 

with their manual chairs because the thing 
about the scooter is it requires a transport so 

there is a lot of elderly people pushing them 

around in manual chairs to get them on trains 

and they sit and ride through the train they do 

what they do and they push back.

>> I am wondering how many people ride 

commuter trains most of the people I have 

seen are people that regularly ride commuters 

most people have a system down.

>> I think it's less with 

computer -- commuter more with inner-city 

rail

>> I can't see transferring on a commuter 

train. If you are going to be in a seat 4 or 5 

hours you might want to get out of the chair 

because hopefully it will be more comfortable.

>> Blair: Okay. Well, we are right up 

against the 3 o'clock hour we did manage to 

get one point at least with ink against it today.

>> Wheelchair storage have we inked that 

or still thinking on that.

>> Blair: Wheelchair storage the question 

remains, I think we should define that. I

think Linda's point that would be -- I know we 
fumbled with that and I think 12 or 12 and a 

half inches was a number that or 11 and a half 

was a dimension that the Henry Dreyfus 

human scale provided many moons ago and 

then when you look at manufacturers some 

have it some don't. But I -- I think we do 

need to define that.

>> if you define it as 24 you get twofolded 

chairs or one not folded chair. That's the 

deal.

>> This is Linda, except with the folded, 

stored wheelchair you might have a height 

dimension as well you might you are going to 

assume you are going to put it in a closed in 

area one being the bi-level struggled with if 

you just if you fold the wheelchair up against 

a wall you run the risk of it flapping over so 

they have to figure out a way to secure them.

>> Twofolded

>> Blair: Linda, you bring up an 

interesting comment. I was looking back 

over the older drawings for the Acela and the 

fold and the stored -- folded storage space 

for wheelchairs on the Acela was intended to 
house two. So, I have to go back and look at 

the dimensions I think it was at least 24 

inches. But so -- that -- and then what we 

did is above that becomes luggage storage 

which is the space is used one way or the 

other. But where we can obviously where we 

can stack space and stack use you know it 

takes the pressure off of the space on the 

train. Well just for the sake of having 

something to put there, why don't we put 24 

inches as a minimum. The trick that we are 

going to have to look at some of these things 

is the length of the folding device which, 

again, can be all over the place --

>> It's not going to be shorter than it is 

when the person is in it probably.

>> Blair: Well it depends --

>> if you have removable footrests it's 

quite a bit shorter.

>> They are removable seats too.

 (LAUGHTER)

>> The ones that don't present the greatest 

problem with the width across the car you 

almost want to go to a longitudinal storage 
which gets back into the whole floor space 

issues. But we can pick it up on the next trip. 

I want to give you folks some homework 

somehow. But I think right now I am the one 

with the homework.

Does everyone have success to the PRIIA 

documents?

>> No.

>> We have been asking for it for a while 

we have never seen it.

>> I look it up on the Internet wait a minute 

let me find it. I found it on the Internet. 

And downloaded it's only 3 or 400 pages it's 

not a big deal.

 (LAUGHTER)

>> Blair: I think we can glean the 

accessibility parts out of it

>> Here it is PRIIA train set approved initial 

release PDF.

>> Can you E-mail the link to us?

>> I don't have it --

>> No I don't have the link I downloaded it 

stuck it in my computer

>> This is Melissa Shurland I can send the 
link out.

>> Blair: I was going to offer to take it it's 

a PDF I think send it back to the board or 

distribution.

>> Is that just all text document? I think 

one of the things --

>> It doesn't have many drawings it's 

mostly text one or two drawings but not 

many.

>> Yeah.

>> Maybe I have not flipped all the way 

through it.

>> I think it's like --

>> Pardon? I

>> I think the accessibility part is like page 

300 or something.

>> It's a very short document.

>> Maybe I was too lazy to look at the 

document. The car drawings so that you 

have a sense of --

>> It's in there I am looking for it as I look 

here as we speak here right near the end there 

is a drawings

>> Melissa Shurland this is Marsha Mazz if 
you can excerpt the actionability information 

and put it in a Word document that would be 

very helpful.

>> Okay. I will do that Marsha.

>> Thank you and then we can just add an 

alt tag to any figures that happen to be in it 

thank you.

>> All right. Page 345.

>> This is Blair, I would like folks to look at 

the PRIIA document, what I have done is I took 

that in its most conservative or liberal 

againing how you want to look at it, 

interpretation, and have applied it to a rail car 

with space for service animals, and there is a 

space that we need to define as well. What is 

a reasonable space. I thought about how big 

my dog was came up with a dimension. But 

and where the animal needs to be relative to 

the person that they are with. So, I can do 

that for next time. In the meanwhile if folks 

look at PRIIA document so we can discuss that 

since that's work that's already been done, 

and I think we need to lean on that where it 

makes sense. And then, also, the 
information that Dennis pointed us to, I know 

I need to go do a lot of homework and read 

that and back familiar with it but I would 

suggest everyone else do the same thing. 

Meanwhile --

>> Of 126 -- all 526 pages?

>> Blair: No just --

>> I have never seen that.

>> Just the ones with pictures.

 (LAUGHTER)

>> (inaudible).

>> The PRIIA thing has 526 pages

>> Blair: Don't read the whole thing we 

need just the accessibility the other stuff will 

drive you crazy. So, if everyone will look at 

that with the idea that we will try to pick down 

through that and again continue to fill in the 

blanks, I will write a strawman on the 

wheelchair space the parking space and 

maneuvering, and I will obligate to get that 

back out to the board so everyone can have it 

and chew on it well before the next meeting. 

And hopefully also we will be able to sort out 

the issue around the floor plans and things 
like that so everyone can have access to them.

>> Okay. And do you want photographs 

of the exteriors of the various cars because I 

think I have a photograph of every car 

mentioned.

>> Ed, I would only say it would be nice 

because if what I am finding is building this 

document it may become a very useful 

resource to add to. That's fine as far as I am 

concerned. But it's not necessary.

>> Well it makes it easy all of the 

photographs that I sent you will belong to me 

I will put a copyright of my own and allow 

everybody to use it.

>> Makes life easier.

>> Would you like to add alt text to those if 

you give us a call I can tell you how

>> I will send it to you as PDF or --

>> No Bob that won't work for us.

>> the alt text for it.

>> Bob, if you send it as a PDF we won't be 

able to make them accessible don't send any 

images that you don't feel are necessary 

because it's a lot of work to make these 
accessible.

>> If I sent you a jpg with a separate 

document with the alt text.

>> That's fine it has to be added. So, just 

don't send us hundreds of photographs 

because we won't be able to make them 

accessible.

>> I have 17 photographs -- 17 

(inaudible).

>> Blair: All right. Any -- from the 

Access Board folks?

>> by the way the drawings of the cars are 

on page 204 to 207 in the PRIIA document. 

They only have one wheelchair this is a single 

level one okay. Looking at the wrong 

document. This is a single level. That might 

be worth looking at even though it hasn't 

been put out yet.

>> Well -- that is from any guidance from 

the folks at the Access Board before it's 3:08 

by my clock.

>> I think we are good. I think Paul said 

the next meeting is on July 10 so we will talk 

again and Blair you and I will talk before then.
>> Okay.

>> Okay. On the bi-level specs it's on 40 

to 44.

>> Chris Hart: Melissa we should try to 

figure out a time to chat.

>> MELISSA ANDERSON: Okay that's fine 

Chris thank you everyone.

>> It was a good call.

>> Thank you.

>> Thanks Chris I appreciate that coming 

from you especially. Only because you give 

Gary a hard time.

 (LAUGHTER)

>> Listen, he deserves it.

 (LAUGHTER)

>> He has all the -- he needs all the help 

he can get there. Okay. Thank you very 

much. And have a nice summer.

>> Bye everybody.

>> Operator. Thank you for your help 

today. Please disconnect all lines. (end of 

meeting.)