U.S. Access Board

Public Information Meeting on Bus Ramps 

and Updates to the ADA Vehicle Guidelines

Wednesday, September 19, 2012

Washington, DC

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MEMBERS PRESENT: 

James Bartel, President, AQBOC Technologies

Steve Asztalos, Dallas Smith Corp. 

Rhonda Neuhaus, Policy Analyst for Government Affairs, DREDF

Jeremy Pisigan, Dykema

Krystian Boreyko, Training/Tech Assistance Spec., Easter Seals/Project ACTION 

Kerry Legg, New Flyer Industries

Ghosh Choudhury, Manager, Bus Procurement, WMATA 

Jonathan Walker, WMATA

Cleatus Lewis, Engineering Manager, Lift-U 

Marsha Mazz, Access Board 

John Day, Federal Transit Administration, US Dept. of Transportation

Thomas Fodor, Architect, US Dept. of Justice

David Knight, US Dept. of Justice

Christopher Hart, Public Member, US Access Board

David Capozzi, Executive Director, US Access Board

Melissa Anderson, Transportation Engineer, US Access Board

Scott Windley, Accessibility Specialist, US Access Board
U.S. Access Board

Public Information Meeting on Bus Ramps 

and Updates to the ADA Vehicle Guidelines

Wednesday, September 19, 2012

Washington, DC

>> SCOTT WINDLEY: Okay. So I think we're ready to roll now. Are we 

not? 

Is CART ready to go? 

Okay. Making sure -- I'm just making sure she's good to go, so...all right. 

I think Melissa is going to have to be my clicker, so -- but let's start out with 

introductions since we're a small group and we'll be first to do that. I'll just start 

it out here. I'm Scott Windley. I'm staff with the Access Board and I'm the lead 

staff person on our transportation rule for transportation vehicles. Some of you 

may know Dennis Cannon who preceded me in this position, and we miss him 

greatly, but we'll try to get through the rulemaking without him. And so anyway, 

that's me and I'll be talking to you more about kind of what we're going to be 

doing today in just a few minutes and I'll turn the mic over to Chris, so... 

>> CHRISTOPHER HART: Good morning. 

Chris Hart. I'm a public member for the U.S. Access Board. I was appointed to 

the Board a year ago, and I chair the transportation vehicle. So it's my pleasure 

to welcome all of you here and I look forward to a very constructive dialogue 

today. 
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>> SCOTT WINDLEY: Great. So let's go around the room. Do you 

have a mic -- we'll need to get you a mic. 

>> I have an extra one. 

>> Hi. I'm Rhonda Neuhaus with the Disability Rights Education and Defense 

Fund, DREDF. Can't stay the whole morning but I'll listen in. Thank you. 

>> My name is Jerry and I'm with Dykema and I'm just here to get some 

information. 

>> My name is Steve Asztalos, and I'm with Dallas Smith Corporation and we are 

bus builders. 

>> Good morning. 

My name is Kerry Legg. I'm the vehicle safety and regulatory compliance 

manager with New Flier Industries. 

>> I'm Ghosh Choudhury from WMATA and I'm the bus manager. 

>> I'm Cleatus Lewis, engineering manager. 

>> I'm Marsha Mazz, the director of the Office of Informatiom and Technical

Services at the Access Board and my claim to fame is that I hired Melissa 
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Anderson behind me. 

>> Hi. I'm John Day, Federal Transit Administration, Department of 

Transportation. 

>> I'm Jim Bartel from AQBOC Technologies and we are a bus manufacturer. 

>> Good morning. I'm Khristian, with Easter Seals and we provide accessibility 

issues around public transit. 

>> SCOTT WINDLEY: And the all-important Transportation Engineer... 

>> Melissa Anderson, Transportation Engineer and official clicker with the Access 

Board. 

>> I'm Jim Raggio, the General Counsel with the Access Board. 

>> SCOTT WINDLEY: Your mic doesn't seem to be working really well. 

There is another mic here -- a couple of mics on this front table. So if anybody 

comes in and needs a mic, we'll try to distribute appropriately. 

So let's start out with what we're here for. Why are we here? 

Thank you. 

So this is a public information meeting. It's a little bit different than a hearing. 
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We're not going to just sit here and listen to you speak. We would like to have a 

dialogue and discussion of some issues and try to discuss it together rather than 

just sitting and listening and I'm going to do a quick little welcome and 

introduction and then we'll go into individual presentations and then we'll have a 

discussion. 

So next... 

So, you know, in all actuality, we have come a long way on the front of access to 

transportation. I found this on the internet in 1954, a bus that is actually from 

the University of Illinois that actually had a lift on it. It's kind of a scary bus. It 

doesn't have any edge protection or if I rolled out a little too fast, I might be in 

big trouble. So we have come a long way. 

Today, we're going to talk about low-floor buses and ramp slopes as well as 

maneuvering -- a little bit of maneuvering at the fair box and things of that 

nature. 

We'll try not to leave the lights down too much because then everybody falls 

asleep, but the -- so hopefully we can discuss that and I'll just kind of bring up 

some of the issues that we have been made aware of by comments that came 

after the original comment period closed that made us want to -- that 

precipitated the need to reopen the comment period and to have these 

discussions. 

So next slide, Melissa. 

So previous as you know, the old guidelines had a running ramp slope of 1:4 that 
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started at the doorway and provided the largest maneuvering space at the fair 

box before you started on the ramp, which was a good option because you 

usually hit the ramp square instead of kind of at an angle and we're just going to 

quickly show you a little video of some of the issues with the floor ramp and why 

we wanted to change those requirements just to give you a little bit of history. 

So we'll get that up here and just some examples of manual chairs trying to do 

the 1 in 4 slope or sometimes steeper depending on how it's been deployed. 

>> Seen it 10 times. It hurts every time. 

(Videotape) 

>> Oh, he's coming out. That's what it is. 

Okay. 

Okay. So as you can see, there's, you know, we do need to do something about 

the slope of the ramp. But here's the next slide, Melissa, if you can... the new 

1:6 ramp slope that we have proposed, some of the issues that have been 

presented to us after, you know, comments we received after the original 

comment period was that with the hinge mid-ramp it makes the change in slope 

or a grade break in the middle of the ramp that causes, you know, that causes 

difficulty for people that aren't expecting a slope change in the middle of the 

ramp. 
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Next... 

And also the way it has been implemented is putting the part of the ramp inside 

the vehicle has caused there to not be as much room at the fair box and it can 

cause problems with the turning space because you get one wheel off of the 

ground. Like I tell engineers all the time, you know, I do a lot of training for 

transportation engineers, unlike cars and vehicles, wheelchairs don't flex, so 

they, you know, can't adjust to elevation changes easily. And if you get one 

wheel off the ground, you have pretty much lost control of your chair, especially 

if it's the drive wheel that comes up off the ground. So, you know, you're going 

to go in whatever direction gravity is going to take you. 

So they have said that it's caused instability and loss of control of mobility device 

and we'll have a video in just a few minutes that kind of shows that we got from 

some of the comments that we received. 

And the next... 

So with that ramp being stuck inside the bus, it has limited the maneuvering 

space at the top of the ramp and within the bus it forces the mobility device to 

approach the ramp at an angle, causing the instability. 

Okay. So those that just came in, if you want to join us at the table, we're 

keeping it informal until there's no more room at the table. So, let's go and look 

at that second video, Melissa, if you can... 

>> While Melissa is bringing that up, I just want to mention that the comments 
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that we received after the comment period are on regulations.gov and available 

for your review. 

>> SCOTT WINDLEY: Yeah. 

So here's them trying to go up the 1 in 6 slope and the unexpected slope change 

causes them to get tippy. That's a technical term, you know, get tippy. 

(Videotape) 

>> SCOTT WINDLEY: As you can see, he's lost a lot of maneuvering 

space to the ramp, so... 

In this video, they're not all regular wheelchair users so there is a little bit of --

there is a little bit of user error added to this as well because some of the 

techniques they have used, us guys that use wheelchairs all the time kind of 

scratch our heads and say why did they do it that way? 

But it does show -- see, here's the problem where you get the rear wheel caught 

on that elevation change because you have to make the turn on the ramp 

instead of after you're done with the ramp. 

>> CHRISTOPHER HART: It's always interesting to see people that are 

using 1970s wheelchair design for wheelchairs. But powered chairs are actually 

realistic to what the --

>> SCOTT WINDLEY: Except for the fact that we usually wouldn't stick 
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out feet out to try to save us. 

>> CHRISTOPHER HART: Some of us might do that. It doesn't work 

well. 

>> Not a good idea when you're going downhill. 

(Videotape) 

>> CHRISTOPHER HART: If you ever have a chance to get a regular 

chair, you have a pretty substantial idea for how far we have come. 

>> SCOTT WINDLEY: So the last thing I wanted to go over with you 

guys before we go into our individual presentations, I kind of already laid this out 

for you. But we're going to have -- after I finish, we're going to have 

presentations by attendees, anybody who wants to -- I know I have had two 

people that indicated that they have presentations. If there's anybody that 

hasn't indicated that and does want to present something or just during our 

discussion, you can speak as well and we'll have an organized discussion, as 

organized as it can be and then I just also wanted to thank you all for coming 

today to help us out with this issue. And hopefully we'll get...and one more 

slide, please. 

And, oh, wow, this is really kind of hard to read on here. I don't know how it is 

there. But these are the four questions that we asked in the notice of opening 

up the rule for more comments. And it's can a bus ramp with a slope of 1:6 be 

provided without a grade break and without compromising the available level 

space within the bus at the top of the ramp? 
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And how might bus kneeling affect these designs? 

If the ramp slope were required to be uniform for the length of ramp with no 

grade breaks, how would such a requirement affect bus and ramp designs, 

manufacturers, transit operators, and transit users, including those with 

disabilities? 

How much level space measured when the bus is sitting on a level surface can be 

provided beyond the top of the ramp? 

And how can the space be configured to permit individuals who use wheeled 

mobility devices to access fare collection devices and to turn on to the main 

aisle? 

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

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

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

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

requirement affect bus design, manufacturers, transit operators, and transit 

users, including those with disabilities? 

So those are the four questions that we're kind of here to discuss and anything 

else that we can discuss in regards to the ramp and maneuvering space at the 

top of the ramp. 

So, Melissa, why don't you go ahead and come up here and join us for -- well, I 
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can help with the presentations for a while and you can be up here. 

>> There is a sign-in sheet going around. I'm not sure if it got all the way around. 

If we can get you to sign in. And when you speak, if you wouldn't mind 

introducing yourself so that our transcriptionist can make sure we get the names 

correct. 

>> SCOTT WINDLEY: Yeah, and that helps all of us because it helps us 

to remember each other's names for our discussion today, so that's a good idea, 

Melissa. Thank you. 

>> MARSHA MAZZ: Also, we need to make sure that we have copies 

of any presentations that are... 

>> SCOTT WINDLEY: Yeah. We'll let Cleatus go first and then Jim of 

the two that spoke ahead of time and then we'll open it up for anybody else who 

wants to talk. So Cleatus? 

Does anybody have any observations or anything while Melissa is getting the 

next one set up? 

Don't all speak at once. Yes? 

>> My name is Ghosh Choudury. Let me give you the spelling of my name. First 

one is Ghosh and the last one is Choudury and I'm from WMATA but before I 

came to transit, I used to work for worldwide bus company. So like I started my 

courier in 1969 and got -- and I've been in the bus industry since my first transit 
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property I worked for Chicago Transit as assistant chief engineer and my family 

lives in North Carolina and I moved to Washington, D.C. close to my family. But 

anyway, I personally was involved to design the low-floor buses and one thing I 

think the bus manufacturer has to do a little bit of expanding to that, we have a 

tremendous technological advancement now. With the air bag adjustment we 

can bring it down in the front a couple more inches, from 4 inches. We can bring 

it down to 5.5, 6 inches. What we did in the first low-floor bus we have designed 

and unfortunately I don't have the picture with me. Next time I come here, I will 

bring some pictures and show it to you. The front end come all the way to the 

curb height and 7 inches with the air bag and the front and with the ramp, the 

manual ramp, we put the ramp completely straight has no obstruction, nothing. 

And 7 inches down. That can be easily technically achieved. I think that bus 

manufacturer has to come up with some kind of design. Thank you. 

>> SCOTT WINDLEY: All right. Thanks. 

So, Cleatus. Think we're ready for you. 

>> Right. I want to get familiar with the clicker here. Well, my name is Cleatus 

Lewis and I'm a representative of Lift-U in California and first of all I want to 

thank the board for the opportunity to participate in this discussion. 

After Scott's lead-in and some of the videos that we have seen, a bit of what I 
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had prepared as background is somewhat redundant. No need to bore you with 

that. You know, I would like to again emphasize that, you know, when the 1:4 

ramp is deployed to the roadway, it's still too steep and we saw that from the 

videos. 

This image here is a typical 1:4 ramp that pivots at the step edge and when the 

buses kneel, you're looking at 1 or 8 or better with the ramp slope and when it's 

deployed to the roadway, we're looking at the 1 on 4. 

This is a couple of images of an incident that occurred in Long Island, once again, 

demonstrating that the 1:4 ramp is too steep to board from the street. 

You know, back in 2007, you know, after viewing many of these videos, Lift-U 

took the resolve to try to figure something out here and we came up with a 1:6 

ramp that, you know, we did introduce to the access board in our draft 

responses back in April. 

The 1:6 ramp as you can see has the pivoting part that extends outside the bus 

and then there's a slope portion that extends to the interior. This particular 

diagram is representative of the ramp that's in the Santa Clara and the lane 

transit bus. You can see that the slope portion extends in 28 inches. 

Scott, you have already addressed these issues that have been raised by Santa 

Monica, Santa Clara, Lane Transit and Doug Cross. 

I would like to provide a little broader perspective in that the only complaints 
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regarding these issues received by Lift-U were from these entities. 

You know, over the course of the last five years, you know, Lift-U produced 

several 1:6 ramps, several thousand ramps that are in service at over 400 transit 

agencies. These complaints are cited by less than 2% of the transit operators 

that have Lift-U 1:6 ramp equipped buses. Moreover, the transit agencies 

continue to purchase buses with 1:6 ramps. Many are repeat customers. 

Several have gone to the extent of refitting retrofit buses and several with 1:6 

buses. Immediately the absence of other complaints does not diminish the 

significance of those supported by the above entities. The user issues they 

describe in their reports are legitimate. However, the reports also include 

important information that should be underscored. 

The common thread among the complaint it is associated with wheelchair 

passengers boarding and the lining on the 1:6 ramps deployed to the sidewalks. 

Also, VTA and Lane Transit have taken certain measures to improve wheelchair 

passenger usability in 1:6 ramp equipped buses such as wheelchair lift 

recommendations to not kneel the bus when deployed to the walk or to at least 

minimize the grade break and added a bumper to influence toward the ramp 

level rather than allowing them to cut the corner on to the slope surface near 

the door. 

Also Lane Transit has replaced the fare box pedestal with a smaller version to 

increase the level floor space to the top of the ramp. Santa Clara and Lane 

Transit acknowledge their operational changes to a certain extent to improve 
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usability and reduce the number of incidents. 

It should also be said that Santa Clara indicated in their report boarding the 1:6 

ramp from street level is an improvements over the extremely difficult 1:4

ramps. 

With respect to the questions that the Access Board asked, there's regarding 

environmental constraints, potential ramp designs and I would like to take a look 

at some of the environmental constraints right now. 

For a ramp to achieve a flatter slope, either the vehicle floor step edge must get 

lower and/or the ramp must get longer. There are two environmental factors 

that both restrict and affect ramp length. 

One is the built environment and the second is vehicle space constraints. The 

two combined present a formidable challenge for manufacturers. 

Space constraints in the urban built environment limit the deployment of longer 

ramps. Topographic conditions in the built environment such as curb heights, 

road crowns and a multitude of combinations thereof can adversely affect the 

curb ramp slopes. Space constraints and contemporary buses limit the 

integration of longer ramps. Several vehicle design factors contribute to space 

constraints and therefore the ergonomics of a ramp system which ultimately 

impact the ease of which a wheelchair user boards and the lights from the low 

floor bus. Restricts ramp width, chassis construction and limited floor space as 

well as ramp length and storage space. 
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Step height which is a function of vehicle chassis design, suspension, tire 

diameter, ground clearance, approach angle and the extent to which the vehicle 

can be kneeled affect ramp length and slope. 

Vehicle vestibule slope which presently range from 1 to 4 degrees is also a 

function of chassis design affecting vehicle entrance slope, ramp installation, 

incline angle, ramp slope, and compromises level floor space. 

This particular detail which hasn't received much attention in the past warrants

further explanation. The step edge on most heavy duty low-floor transit buses is 

not on the same plain as the bus floor at the aisle. A 12 inch or lower step height 

is not merely the bus kneeling. Due to chasis, ground floor floors, et cetera, in 

order to achieve a low step most buses include some floor incline from the aisle 

down to the step edge. 

The result of vestibule slope or transit buses once again ranges from 1 to 4 

degrees. Steeper vestibule slopes are cheaper among lighter duty or cut-away 

buses built on truck chasis. For example, these vehicles have kneeled aisle 

heights of 17 to 20 inches with an entrance step at approximately 12 inches. 

Some cut away vestibule slopes are as steep as 9.5 degrees which is 1:6. In the 

commentary in the July 2010 NPRM the Access Board stated buses have been 

designed with lower floors and less ramps. Close quote. And in the 

corresponding footnote, quote, low floor ramp buses available today have floors 

that are 14 to 15 inches high and can kneel to as low as 10 inches, close quote. 

Of the dozen or so bus models offered by the eight major players in the heavy 
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duty low floor transit market only two floor buses kneeled lower than 11 inches. 

Circulation space within the front of the vehicle is restricted by wheel wells, 

driver platform, fare box collection device, fare box pedestal, and handrail. Since 

it's not practical to change the built-in environment to accommodate longer 

ramps, the burden falls on bus chair ramps to provide the better solution. 

I would like to present two progressive ramp designs. The first is a modification 

to the current one on 6 designs that increases the portion -- a portion of the 

floor space. 

Recently Lift-U has explored geometry alternatives to the outboard away from 

the aisle, thus increasing the level floor space forward to 8 inches. 

We intend to implement this enhancement on the 1:6 ramp as quickly as 

possible. 

The extent to which this transition APEX can be moved is greatly dependent 

upon the vehicle configuration and this alternative is most beneficial for vehicles 

that kneel a step edge to 11 inches or less. 

If you'll notice from the slide this range, the interior slope portion only extends 

about 21 inches into the bus and the interior slope portion is a bit flatter. So 

that when it's deployed to a curb and not kneel position, once again you can see 

that the outer and inner slope is -- and when it's deployed to the ground in the 

kneeled condition, you got the 1:6 and then a bit flatter in the bus. 

Second is a new ramp. 

In late 2010 soon after receiving the second complaint, Lift-U began 
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conceptualizing various designs that would adjust many of the user issues as 

possible. The goal is to work within the parameters of existing vehicle 

configurations and their inherent space constraints. In the end we came up with 

a design that is responsive to the majority of user complaints. 

A new Lift-U ramp is a dual use device that offers a 1:8 maximum slope to a 6 

inch curb intelligence transfers to a 1:6 curb to the roadway. 

The dual mode ramp design eliminates the grade break within a single ramp run 

regardless of whether the ramp is deployed to the curb or roadway. 

Further the dual mode ramp does not compromise the available level floor space 

at the top of the ramp when it's deployed to a sidewalk. 

Alternatively when deployed to the roadway, an interior portion of the ramp 

lower on an incline and becomes co-plainer on a ramp to achieve a 1:6 which 

does reduce to some extent the level floor space at the top of the ramp. 

Although floor space is somewhat reduced, the deployed ramp to the ground 

with a flatter 1:6 slope is far better alt enough than the steeper 1:4 ramp. 

In addition the dual mode ramp minimizes the ramp extends beyond the 

doorway to approximately 48 inches. 

The same as most 1:4 ramps. Subsequently the ramp does not compromise the 

present deployment space provided in urban environments. 

The dual mode ramp will be production ready within the next few months. 

The timing of the Access Board's reexamination of the prosupposed ramp slope 
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rule just happens to do incite with Lift-U installing prototypes over ramp at both 

Santa Clara BTA and for beta evaluation. Those have been installed for almost a 

month now and the initial feedback has been extremely positive. 

In conclusion the Access Board asked four questions in the NPRM. In response 

to the first two questions, Lift-U's presented two feasible ramp solutions. One is 

a 1:6 ramp with a revised transition geometry that provides a measurable 

increase in level floor space, outboard and away from the aisle. Second is the 

dual mode ramp that resolves all the issues previously cited when deployed to a 

curb. Both ramps deployed to the roadway without grade break and provide a 

safer more user friendly boarding at bus stops without sidewalks than the 

steeper 1:4 ramp. 

Due to the vehicle constraints described above, response to the last two 

questions will require input from bus manufacturers and transit operator. The 

two designed provided by Lift-U are just part of the solution. Level floor space 

can be leveled if combined with vehicle changes such as smaller or rear 

collection devices or rear floor box pedestals. Even greater improvements for 

wheelchair users will be realized if ramp equipped buses were designed to kneel 

the step edge lower than 12 inches, designed with wider doors to accommodate 

a wider ramp, and designed to include vestibule slope that did not exceed 2

degrees. 

These vehicle changes would enable a greater variety of ramps with reduced 

slopes, including designs that comprise a shorter and flatter interior slope 
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portion to maximize the level floor space. 

The transit ramp industry has evolved over the last 15 years to its present state. 

Many designs improvements have come about along the way, new and different 

challenges arise. Suggestion by some to allow transit operators when purchasing 

buses the option of selecting either 1:4 or 1:6 buses based on transit routes 

would in lift-U's opinion create issues because buses are often switched between 

routes with different topographic conditions. Subsequently the potential exists 

for 1:4 ramps to be deployed to the roadway and this will unfortunately lead to 

wheelchair passenger accidents and lawsuits. The 1:4 chair that proposed the 

rule in the first place must not be forgotten. Bus accessibility will be overcome 

through innovation. Our immediate hope is that the Access Board will take all 

relevant matters into consideration, including feasibility before making my 

further revisions to the proposed 1:6 slope rule. Lift-U appreciates the 

opportunity to participate in the rulemaking process and wishes to thank the 

Access Board for their efforts to improve the accessibility guidelines for 

transportation vehicles. 

Thank you. 

>> SCOTT WINDLEY: Thank you, Cleatus. 

That was very good. 

Melissa, can you get Bill's up. 

That's really -- to see those new ramp designs, we'll have to talk more about that 

during the discussion. Those were exciting. 
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Bill, you can go ahead. Jim. Sorry. My bad. 

>> I'm with AQBOC Technologies. We're a bus manufacturer. Our main products 

are smaller buses, typically categorized in the cut-away design in the floor. We 

have pioneered several things there. We are working on a pusher bus which was 

presented after last year and concept stage and again at Bus Con and production 

version. But what I want to do is first off is make sure I was understanding the 

question properly on ramps and grades that the Board was asking. And if you 

look at the top -- the top illustration here I believe is what we're posing in some 

of your questions is a 1:6 slope which we obviously support. All of our buses 

have no slopes anywhere in the bus or within the ramp that are greater than 1:6 

and I think that is very key. 

We fully support a 1:6 and do not feel that a 1:4 is acceptable under any 

conditions for the situations you have illustrated previously and other work we 

have done on our own. 

Obviously when the ramp is deployed, the 1:6 to the ground and continuing the 

bus at 1:6, that is I think what you are qualifying is that the ramp cartridge is 

actually part of the ramp slope and one in the same. 

Now, as I go through this, I question that and also ask they consider the situation 

of what that actual angle of cartridge should be. 

In some cases, especially on a small bus which is an entrance that is between the 

wheel bus, there are certain considerations that limit what can be done inside 

the vehicle from a slope. And that is the driveshaft. Current buses we all build 
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and what all of our competitors are trying to do to emulate us are rear-wheel 

drive buses. These are smaller buses and less expensive buses that are allowing 

use of low-floor technology and access to a wider portion of the industry. 

Obviously when the ramp is deployed to a curb, the slope becomes more like 

1:15 and so there definitely is a break. So in theory, there is only one finite point 

where this is exactly one ramp and that is when everything is exactly at 1:6. 

There is an infinite number of positions where there is a break in the slope and 

virtually in real operation it will be -- will have a break in the slope many times 

under normal applications because curb heights change, wheel surfaces -- road 

surfaces change and heights of vehicles change with load. 

Next slide. 

As we said, this is a bus that -- type of configuration of bus that we have 

pioneered and is currently in the marketplace in which you have a front engine, 

rear drive and an entrance within. This is proven to be necessary and we have 

been quite successful in the last four and a half years since we have been in the 

marketplace. We currently have approximately 85 to 90% of the volatile market. 

Next slide... 

This just shows typical installation -- ramps. 

Now, the illustrations you had on large transit and the presentation from U-lift is 

one type of ramp which is a single-fold ramp, leaf ramp that is utilized in those 

designs. 

We are using a bifold design in which the ramp surface is folded in the middle 
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and then deposited on top of the cartridge within the bus. 

The reason we did this is because of our limitations of chassis and the need for 

drive shaft. Any single-fold ramp would have gone through the driveshaft. So 

we had to go to another choice of ramp. This is just a competitor's ramp 

entrance. They're all using the same ramp. 

We pioneered the ramp in both length. Our suppliers have been very both 

Braun and Ricon have been supportive and are at... next slide. 

The other type of bus product obviously is the one that was shown in the 

illustrations and also talked about by Cleatus and his presentation from U-Lift or 

Lift-U is a bus manufacturer and rail chassis integrated structure and in the past 

entrance is 4 to the front axle. 

Next slide, this shows the bus utilized in this product. 

Now, this is the same ramp that we are using on our mid entrance, a smaller bus. 

Same width, same length and is a bifold. It is a -- this actually is 1:6 but we're 

actually able to achieve a 1:7 in our kneeling capabilities. Our bus is under 

develop and we actually get to 1:7 with a ramp on this bus. 

Next slide. 

This is just typical entrance. We have already cover these well in the other 

presentations. It's just showing what is typically out there today and as I go 

through this, I'll show where we have changed and what we think is achievable 
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in entrance criteria. 

Next. 

We did a little computer simulation here and some of you were in the board 

meeting a couple of months ago I presented this back then but I'll just go 

through it quickly because one of the things we did here was to look at what are 

our options. 

And one of the concerns I have and I think is very, very critical and what we have 

established out in the field and have gotten much feedback and success from our 

customers is that the path from the road surface or curb street surface to the 

bus is best when it's the least slope and it's the smoothest transitions. 

Large slopes and abrupt transitions are very detrimental to traversing into or out 

of a vehicle of any type. 

And that's what I'm showing here is, you know, there's several alternatives, but 

the -- it's not news -- next slide. 

It's not news to anybody here that this is an issue because the -- next slide. 

The wheelchair is a very useful device and very maneuverable but it has some 

bad characteristics and it's got a very short wheel base and a very high CG which 

makes it a less than ideal state stability device. 

In fact, if you look at it, the front tip-over angle of a typical 95th percentile in 

wheelchair is about 12 degrees, 1:4 slope is 14. That's why we are fully in 

support of making 1:6 the absolute maximum slope that should be allowed 

anywhere in a vehicle. 
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Next...next slide. 

>> I'm not getting a next. 

>> SCOTT WINDLEY: Is the computer locked up or something? 

>> Yeah, that's the next one. 

We did this computer simulation of a wheelchair traveling -- a standard 

wheelchair traveling out of a vehicle at normal walking speed at 3 miles per

hour. 

And the chart on the right here shows the wheel forces which indicate the 

impact it has on the passenger as it proceeds through this journey. 

This is an abrupt transition path and you can see the spike loads that occur. 

Next slide. 

>> Maybe you want to try the clicker that you have there. 

>> There it is. I don't know why these slides causes problems. 

This just shows the same path being occurred through a smooth transition ramp 

and the load forces are reduced. 

More importantly -- next slide. 
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This shows a comparison of the two. But more importantly -- next slide. 

Shows the impact on the customer literally. 

Head velocity change, and the head accelerations, which obviously is noted by, 

you know, by the passenger and is an indication of instability. 

This is why we have spent a serious amount of time to make our transitions in 

and out of the bus as gentle as possible. 

What does this look like? 

Next slide. 

This is the entrance of our current product with a cut-away which is an entrance 

within the wheel base. This has a 1:6 cartridge where the ramp is stored when 

it's not deployed. And as you can see throughout this area, we have done 

everything we can, there is a fully-formed developed surface computer surface 

that immediately starts to transition as it -- as the surface leaves the ramp. 

The idea is to make this transition as gentle as possible for all occupants, 

especially those in chairs. But all occupants do not feel abrupt surface change. 

Next slide. 

What this looks like in the actual vehicle, this is our spare mobility bus. Now, 

your questionnaire asked was effective kneeling on the properties of space 

utilization. We actually are the only manufacturer that has all three conditions. 

We have a bus that is within the wheel base kneeling. We have another bus that 

is not a kneeling bus within the wheel base. And of course we have the rear 

engine bus that has a front entrance that has kneeling also. 
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As we stated before, on the smaller buses where the entrance is within the 

wheel base, the key limiter to anything is a drive line. 

Many attempts have been made throughout the years to do a front-wheel drive 

vehicle of this type of bus to avoid the driveshaft. They have been virtually 

unsuccessful. One of the main reasons is that no chassis are made currently that 

have a front drive axle, front drive system that are robust enough to operate in 

all conditions and full-time drive. They're meant to be a supplemental. Not to 

be the main force of motivation. 

And any operation that has hill turning or especially if it's in wet or snowy 

conditions, has poor traction which are further limited. These buses have been 

tried over a decade and never reached over 100 units a year because of these 

limitations. 

But as I said, this is a situation where the cartridge in the bus is 1:6. We don't 

think 1:6 is an ideal cartridge angle, but it is what is required on these to clear 

driveshaft and we have pushed the technology further than anybody else in 

lowering our drive train to do this. So we think this is pretty much near the limit 

with any conventional drive will be on this type of bus. 

And I'll go further...the reason being is that when you're 1:6, the floor eventually 

is flat. You have to make that transition. 

The longer you stay at 1:6, the less zone you have to make that transition and 

the more abrupt it has to be. 

Next slide. 
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And this is our spirit of mobility bus. There are several things we do here is that 

we actually have an angled doorway. We did this to allow us to move the 

doorway far as forward in the bus, which gives the driver straight view and 

access to the fare box and provides the maximum zone to transition in the 

vehicle. 

In this type of product, you have a fair amount of width once you get in the bus. 

You don't have a fair amount of length. So those are trade-offs between the 

other type of bus and I'll demonstrate that more. 

What I'm indicating here is my concern is that there not be a ruling that states 

that a flat area is defined as perfectly flat. That it is designed as a sharp edge 

because sharp edges and transitions are detrimental and we have indicated -- we 

found that out through many of our customer base. 

Our competitors have also found this out because that is what they have tried to 

produce for the last three years copying us. 

And have been rejected, and each show is a revelation because all our 

competitors come out and say here is our newest bus and we think it's almost an 

ARBOC. We find that a real compliment. But we are very serious to the work we 

have done and our point is that if you have a curve surface within the bus but is 

within limits, that it is definitely stable. 

In fact, I know that the two gentleman down here from the Justice Department 

has been in our buses several times. I know you have made complimentary 

points about our buses but they have tried to measure our bus with instruments 
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that measure flat surfaces and they have difficulty because there are very few 

flat surfaces within our entrance. We have done this by design. 

As you pointed out earlier that when you take a flat plane and you try to run it 

an angle going to the bus, one wheel of the chair comes off. 

We avoid this through this method. We have done this work and tested on 

chairs to make sure that at all points you have four wheels in contact or if you 

have a power chair, that you have your traction wheels in contact. 

And that is all part of our design process. We have spent a lot of time doing this 

and it is important for the customer especially that this contact and stability we 

provided throughout that transition and that's what we have tried to do. 

Next slide. 

Now, this is our -- we call our spirit of freedom. We have by the way, we 

introduced a mobility -- spirit of mobility model four years ago and we have just 

delivered our 1,000th unit and we have 500 in our backlog. So we have been 

very successful. This is not a pitch. But we have been accepted quite well and as 

far as we know have not had any complains about our entrance. What we have 

done is we found out that our mission is to provide mobility and access of a lowfloor type product to the widest possible customer base. 

So we have just introduced, we call it the spirit of freedom. It uses standard 

suspension which means the bus cannot kneel. Whatever it is, it is. 

So we assure the customer under normal conditions we'll be 1:6, but we cannot 

guarantee it because obviously if a large group of passengers go in the back, it 
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will raise the front of the bus. It will not be quite 1:6. But we have got a -- we 

have had a large request from our customer base that operate small operations, 

that operate at rural or more remote areas that do not want to work or have the 

sophistication of an air system on the bus. They're used to a simple bus, you 

open the door. The passenger comes on and you shut the door. And they don't 

have maintenance departments. They outsource their maintenance work, so 

they want a simple bus that works under all conditions. 

That is what we have done this for. It also is a lower cost bus. The way we have 

achieved this is the door is no longer angled like it was in the other buses, 

parallel which extends our slope available and we pushed our cartridge actually 

two inches outside the door to achieve this. Which means is that we have a 

slightly longer to get to the floor because our floor is not lowered now. It's 

higher. And the transition is longer here. 

Next slide. 

There's good news and bad news about it. 

You have a longer time to transition, but to clear that driveshaft, you have to 

stay at the 1:6 for a portion beyond the ramp. Whereas on our other bus, we're 

able to transition virtually as we leave the ramp, start our transition. 

We have a slope in here that extends beyond the cartridge before we actually 

start our transition. 

We are just getting this into production. We have our first customer is using this. 

We will monitor them very closely. So far it's been very satisfactory response, 
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but we have not -- we have limited experience with it in the field. 

You also notice here that our door is straight parallel to the bus which essentially 

pulls our cartridge out and gives the longer time to get into the bus. 

The fare box request are versus a fare box and do we have a flat surface that 

allows access to fare box is an issue in this kind of box because you are in a 

transition zone in either case. However, because it is a sloped -- a warped 

surface that provides a stable position for the chair, we do feel it provides an 

adequate and safe position for people within a chair and within the fare box. 

Obviously the spirit of freedom compromises that to the greatest extent and all 

of these entrances have been pulled out by Cleatus and others are compromises. 

Next slide. 

This is our new bus, which will be hitting the marketplace in about six months, 

production version prototype was displayed at Bus Con last week and this is a 

picture of it. 

What we have done here is because of our -- the bus we're using here, we used 

smaller wheels, used 19 wheels versus 24.5 inch wheels, tires. It allows for lower 

wheel houses. We use a special IV front suspension which allows for very large 

pass-through. We're almost 40 inches between the wheel houses. And we 

again, we do not put the cartridge in the vehicle at 1:6. 

Next slide. I know this is a bad picture, but what we have done is because again 

we use the bifold ramp and when it's folded over, we are so efficient in our 

package that we indeed protruded to the wheel house area which would create 
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a trip hazard. So what we have done is we have a motorized Stanchion so when 

this is in place, it is placed right above the edge of the ramp so it's not a trip 

hazard. Go back a slide. 

So it pivots out of the way and allows full access. Go forward two slides. 

This is a bus as we propose it and this is one of the questions is I think that any 

regulation that is proposed sets a minimum standard, but does not is innovation 

and improvements beyond that. 

We in this bus placed the cartridge in a 1:8 within the bus. So we go from 1:8 to 

1:6. In fact, here is about two degrees sloped and warped and again assure that 

you have 4-wheel placement and stability for anybody going in the bus. 

It also says that when you put the same ramp to the curb instead of going 1:15 

and 1:6 which once you're on a 1:15 ramp moving and you hit a 1:6, it feels like a 

pretty good block there. A 1:8 is less so. So we have gone to a 1:8 as we feel is 

the best compromise here and my point is that if a ruling were to state that the 

cartridge had to be -- or the ramp had to be a single plain throughout it and you 

limit the 1:6, it would actually force us to raise the floor of our bus. That is 

counterproductive to the operations, to space that will be available at the end of 

it and that is our concern right there. 

Next picture. 

This gives you a plan of we have been able to do. With our small wheel 

openings, wheel size, we have a wider on our suspension type, we have got a 

wider front. We obviously can kneel this bus to below 10 inches at the door. We 
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can actually make a 1:7 but we'll guarantee a 1:6. 

Which wheel protects the corner and this is a path that allows you to start your 

turn, and we have developed our many surfaces so there are continuations of 

flow off the ramp. It's just like an intersection in any road in the country. You do 

not have abrupt change when you get to an intersection. 

You transition as gently as possible. 

It also -- all of our ramps are 34 inches. As you see bus designs, all of our designs 

allow that. We have great support from our ramp manufacturers so everything 

goes at 34 inches. 

What it allows is a 36-inch area flat above the wheel house here. And the floor 

of the passenger does not impede anywhere within a -- in the fare box zone, but 

also is completely within the zone for a passenger who could stop and put fare in 

and the fare box here is the largest one out there. It's a GFI. They're a large box. 

But there are numerous number of boxes that could be placed anywhere within 

this area and we made sure that it did not intrude anywhere in the zone. We 

were able to accomplish this because we started with a green sheet of paper. 

We started new green field and optimized it. We also have a slide angle at the 

doorway. We do not have a 12 degree. We have a 5 degrees. It is gentle 

enough so that normal route can pull off curb and not have an issue, but the 5 

degrees is what allows us to start us to get back and get around this corner in a 

much easier flow pattern. 
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Next slide. 

So just in summary, our positions are that -- we agree that we need to limit 

slopes anywhere within the travel zone of the passenger no more than a 1:6. 

Should be 1:6 or less. 

There has to be a provision that allows that quarter inch transition because we 

work to drop our ramp within a pocket so we minimize that. But you can never 

guarantee. The quarter inch is always someplace where there is a misfit or 

something. We will allow a quarter inch to show up but we think that's the 

largest that can show up anywhere within it. 

We also think there needs -- the ruling needs to recommend or permit all 

transitions to have a maximum radii between slopes to reduce wheelchair 

occupants accelerations. And we want to be sure that it's acceptable space and 

flow but do not prohibit future improvements. And also any slope within the 

passenger compartment that is abrupt and greater than 4 degrees we feel needs 

to have, identified by warning yellow line. We have seen this and have done 

several trial on ours and we have noted on our current buses we are current --

small buses, we have transitions in the floor, went tell you where, that are 2 

degrees or less. Nobody's found those in -- in a thousand buses, nobody's found 

those. They flow in. When you go to 4, you trip. 

And the problem is, is that an abrupt 4-degree change in a floor without a 

marking is almost as dangerous as a step with no marking because your mind 

thinks -- there isn't greater lighting and your mind thinks it's a continuous slope 
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and you trip. So we have put very large radiuses in and one of my concerns is 

that how do we define a zone that our work or anybody's work that would make 

the flow dice and make the measurement that is only the flat part of zone that 

can be counted would penalize the design and really the usage of the vehicle for 

the customers. That is our main concern. I've gone on quite a while now. I 

appreciate all your patience and open to any discussions and questions. 

>> SCOTT WINDLEY: Okay. 

Is there anybody else that wants to give any kind of presentation on their stuff? 

Yeah? 

Go ahead. 

>> My name is Steve Asztalos and I represent Dallas Smith Corporation. And we 

don't build buses but we provide chassis and suspensions for the bus industry. 

Mainly the small buses that Jim Bartel addressed. 

And the real issues we have are how they measure the floor. We have our ramp 

installed, very similar to Jim's where the cartridge is on the same angle. We're 

on 1:6, too ground, and of course that makes -- if you deploy to a curb, that 

makes the change, you know, probably 1:8 or 1:10. But we never exceed 1:6. 

Also the ramp and then the floor transition goes up close to the center of the 

vehicle. 

But, again, we have to clear the exhaust in the driveshaft just like ARBOC does. 
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Those are fixed things that you just have to clear. And the -- one of the main 

differences between ours and their it is the area where the wheelchairs go is flat, 

parallel to the ground. 

And we provide, working with the bus manufacturers, we provide at minimum of 

a 48-inch circle at the top of the transition where the cartridge and then the 

floor slope to the middle of the bus. We have a 48-inch flat floor circle to 

position the wheelchair so the wheelchair can go straight in and straight out 

parallel to the ramp. 

The only issue that I see that affects -- that really affects us is how they -- how 

the ramp angle is changed depending on the floor height from curb. 

You know, if we can get 1:6 and get to the center of the bus and have the circle 

to turn the wheelchair, then -- and then a flat floor for the wheelchair space, 

then the floor height, I don't understand why we have to change angles on that. 

On the chart that you had up previously, we had a 1:4, then 1:6, then 1:8 and 

1:10 and it got all the way up to 1:12. 

And from the pictures, from the photos and everything that I have seen so far, if 

we can get 1:6 from the ground to the flat floor and have the area to swing the 

wheelchair, the 46-inch or 48-inch flat area, I think that should accomplish what 

you're trying to do. 

And basically, you know, Dallas Smith Corps, Jim talked about the front-wheel 

drive, and we do build that. 
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We have one customer that has over 200 of those and they're in Canada, you 

know, which does the extremes. 

The problem is those buses are very, very expensive. They are 10-year buses but 

they are very expensive and they're subsidized a lot by the Canadian 

government. We have another order for 80 up there also, and we have probably 

built close to 300 units total in that configuration. But it is very expensive. 

I think that in the United States in the shuttle bus market we have to work 

around the parameters that Jim's discussed and that I've discussed which is the 

drive line, the exhaust, rear-wheel drive, van-type shuttles they're probably over 

$100,000 a vehicle cheaper. 

So that's what I would like to get accomplished at this meeting, is get this floor 

configuration straightened out. 

Thank you. 

>> SCOTT WINDLEY: If there isn't anybody else that wants to talk 

right now, we might just take like a 10-minute break before we go into kind of 

just an overall discussion or is there anybody that wants to say anything specific 

about their particular manufacturing or whatever? 

Or their thoughts on this stuff? 

Anybody? 

Okay. Let's take like a 10-minute break. 

So the bathrooms are through that door, past the elevators and women's is on 
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the left and men's is on the right. 

>> Anybody who did not sign in, can I have you do that, please, before you go? 

(Break) 

>> SCOTT WINDLEY: Let's get back to our little less informal, but still 

informal discussion here. 

Hopefully I haven't lost too many of you. Nope. I haven't lost you. Good. 

You're all here. So I'm going to let Chris start us out on this next phase. 

>> CHRISTOPHER HART: Okay. Chris Hart, public member. I want to 

first ask Cleatus to show his video that he has. And then if Cleatus want to 

describe that video and then I'm going to ask him many questions, get discussion 

going. 

>> SCOTT WINDLEY: All right. So, Melissa, can you get that video up 

for Cleatus. 

>> Like I mentioned earlier, about a month ago we installed prototypes of the 

dual-mode ramp at Lane Transit and Santa Clara and a couple of weeks after, 

John Fusco, our sales manager, went up to Lane Transit, met with them. And 

they took the bus out on some routes and did some -- took some videos. 

(Videotape) 
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>> You can see here the ramp is deployed to a sidewalk and the vestibule floor is 

flat. 

>> Now it's being deployed to ground level and unfortunately John Fusco didn't 

take video of that in Lane Transit and they made a trip over and one of our 

colleagues who is disabled --

>> SCOTT WINDLEY: Your mic isn't on. 

>> Okay. 

Here is a ramp deployed to the roadway and the person using the wheelchair is 

an ambulatory passenger learning how to use a manual wheelchair so he's trying 

to negotiate. Still pretty steep. But it's better than -- with a manual chair, it gets 

back to something that was discussed earlier and Jim brought it up also with the 

-- where the center of gravity and the passenger applying force to the wheel 

rings and things can -- there's enough inertia to cause that to slope. 

>> SCOTT WINDLEY: That second part of the ramp, that only has to 

happen when you go up to the street, right? 

When you do it up to the curb, you don't have to do that second little drop, is 

that right? 

>> Correct. 

>> SCOTT WINDLEY: Great. 
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>> CHRISTOPHER HART: And do you have a -- it's kind of like asking 

how long is the stream. But do you have any idea based on your customer how 

often the street level deployment would occur versus a curb deployment? 

>> That's going to vary with the different communities. 

Santa Monica and Santa Clara have also stated that the majority of their 

deployments are to curbs. 

I received an e-mail yesterday with a cycle count on this new dual-mode ramp at 

Lane Transit. So in less than a month now, they have deployed it 1,334 times to 

a curb and 288 times to the roadway. 

>> CHRISTOPHER HART: Okay. 

>> Thank you. 

>> CHRISTOPHER HART: So one of the questions that has bounced 

around in my mind for a long time and so travel sensory is not always -- is the 

degree to which the ramp design is integrated into actual vehicle design and I 

think for this, typically you guys have -- or is it a design process like ARBOCs 

does? 

>> No, the Lift-U and the Ricon products are drop-in modules. 

Bus manufacturers may have to make a few chassis changes from time to time to 

fit the module, but other than that, it's just a drop-in replacement. A mechanic 

can replace the entire unit in less than 30 minutes. 
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>> CHRISTOPHER HART: Right. Right. 

So probably what I...various...was certain...was beginning to place the whole 

front vestibule and right-of-way design. And how can someone like Lift-U with a 

major background get in the well discussion when say NOVA or NAVI or any 

other manufacturer begins to change their entry design? 

Or do you get --

>> Typically, we provide an envelope drawing that has, you know, the width and 

length, the major dimensions of the unit, its mounting points and then the bus 

manufacturer designs around that. 

As far as interior vestibule, we haven't really had much in the way of discussions 

of trying to open that area up. 

You know, I mentioned earlier that there's only about two of the heavy-duty 

transit bus manufacturers that presently kneel lower than 11 inches. New Flier, 

Exceler is one and the nova LFS is another. And they both have wider door 

openings, wider vestibules. Because they kneel lower, their apex at the top of 

the transition at the interior slope portion is moved farther toward the step, so 

they have a flatter area. 

By way of information, just this past Friday, John Fusco, our sales manager, was 

in New York with the ADA coordinator there and they pulled together three 

buses, an ORyan that had a wheelchair lift ramp in it, an Excelier and a nova LFS 

and they had disabled users boarding and aligning from the three buses and the 
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Excelsior and the nova LFS, they weren't having the same issues that they were 

on the O Ryan and this gets back to this generation 3 that I referred to earlier 

where we're looking at moving the apex out board a bit to try to improve the 

level floor space. 

In the video, the dual-mode ramp doesn't have that integrated in it yet, but 

that's our intent, is to be able to move that apex out a bit farther as well for the 

roadway deployments. 

>> In the integration of the ramp and the vehicle I think by most manufacturers, 

at least for us, is integral with the whole basic design. You know, Lift-U is a single 

fold ramp and the choice really at the beginning is will the single-fold or the 

bifold serve the design better? 

In our case, we took the bifold. But, you know, we have been only in production 

for five years. At five years ago, there was a 32-inch 48-inch long bifold. I did a 

1:4. We said that was acceptable. Brawn came up with a 1:5. I said that wasn't 

really acceptable. Use it. Ricon came up with a 1:6 in the same thing and then 

they also came up with a 34-inch ramp at the same time. So we work with both 

of them, kind of worked one against the other but they were both very active 

and the end thing is the industry now has a 34-inch wide, bifold ramp and both 

are rated 1,000 pounds which start out at 600. So the industry has been very 

active. We haven't worked with Lift-U only because our design works better 

from our standpoint with a bifold ramp. Otherwise I can see from what Lift-U 

has presented. They have been very active too and I'm sure they have the same 
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partner that the other two manufacturers were. But I think the ramp 

manufacturers have been very proactive and very responsive to bus 

manufacturers. 

>> I guess some of that question was related to us, Kerry Legg with New Flier. 

As far as how integral the ramp design is to the bus design, obviously a lot of the 

vehicles on the road today were designed back in the early '90s and back then 

we had a ramp which was integral that meant 1:4 and realistically hadn't been a 

whole lot of changes to that and over the time period it was more a matter of 

trying to meet the requirements for the vestibule-way and the clearance getting 

to and from the areas. 

Five years ago I met with the board and basically asked them because the 

regulation stated 1:4, give us a regulation to design to and so it started off with 

suggestions for 1:8 and 1:6 and we found that we could design a 1:6. 

The Excelsior model which he mentioned which is a vehicle that has been 

designed around accessibility, trying to achieve the best slope that we can with 

the existing designs which we're working with, the axles, the tires, the other 

frame work of the vehicle. 

So there has been a lot of thought put into it. There will be further changes as 

time goes by. The whole concept of the problem with a sloped floor at the fare 

box or, you know, tipping issues with having that portion of the ramp inboard of 

the step, these will eventually be addressed but it takes time, you know, got to 

get the engineers hyped up on caffeine and see what they can come up with. 
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But I hope that addresses your question somewhat. 

I mean, the newer bus models are obviously being designed with accessibility in 

mind. 

>> CHRISTOPHER HART: So going along that line, to what degree will 

you see -- let's say use a wider door at the front door and therefore you add a 

little length to that vestibule and you get a little more space at the fare box...go 

back to the drawing board and what if --

>> Kerry Legg: Changes like that always bring on more issues to be addressed. 

For example, if we put in a wider door, that means our overhang from the front 

axle is longer. Breakover angles change. And now we're finding that because 

streets are not level, when the buses go around corners, bends up and downhills 

and turns and thing and they're actually bottoming out at the front end so we're 

getting damage to the ramp so more things to try and work through. 

Wider door is obviously preferable. And in some places they actually prefer to 

have rear door access or center door access to the wheelchair securement 

positions. That kind of takes care some of that. But like I say, every time you 

make an advance, sometimes creates more issues which then have to be 

addressed and realistically, you know, we're working on these things, but it will 

take some time to get them sorted out. 

>> To play devil's --
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>> SCOTT WINDLEY: To play devil's advocate for a moment, I've 

always wondered -- I know the fare boxes have to be there to collect fares. For 

the life of me, with all the electronics, you know, the smarttrip cards and all 

these days, there's not that many people putting in cash. I always wondered 

why it these go down to the ground. I mean, you could get a lot more space and 

get some room to maneuver your feet, you know, under the fare box if it didn't 

have to go all the way to the ground or if it was in a different location. 

>>KERRY LEGG: The problem being is that we don't design the fare box or decide 

what fare box is going to get in there. Our customers tell us what fare boxes 

they use and then we have to try and design a something for that space and still 

get our wheelchair within the regulation. 

I like the idea of getting the fare box off the ground and it doesn't need to be 

that big anymore as you say because not many people are using cash. A lot of 

Smart Cards going on. But we're at the mercy of our customers in that respect 

unless they specify a fare box manufacturer that will work in that respect, we're 

still stuck with some of these fairly prehistoric fare boxes. 

>> SCOTT WINDLEY: I have no experience with fare box 

manufacturers. But are any of them being, you know, looking beyond the 

dropping it down to the ground and being this big middle box that's in the way? 

>> KERRY LEGG: The last expo in New Orleans, I talked to some GFI people. I 

think they're on making changes to very compact fare boxes with Smart Card or 
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electronic credit card. Those kinds of things that they're working on. I think in 

the next few years you will see some European style fare box collection system 

in this country also. And in Europe, they don't have fare box. It's punch the card 

and go away. So that's something that's coming -- it's in the state of 

development. So as soon as we see that, I think that we'll have some better 

look. 

>> SCOTT WINDLEY: Because that's seriously prime real estate that 

could be used. 

>> That's right. 

>> CHRISTOPHER HART: You just raised a very interesting question. 

Because you have experience, to what degree is -- how will this best fit here in 

the U.S. to manufacturers and bus systems that's not being aware of what is 

available overseas? 

Is it buy America? 

How do we incorporate best practices at industry level that we...or in Asia, but 

have not gotten to the rest. 

>> KERRY LEGG: Well, buy America does fall into it a little bit, but typically since 

we don't install the fare boxes is not something that we as a manufacturer need 

to worry about. Although Buy America is a big consideration for us. We're trying 

to use new technologies as best we can. But once again, limited by the 

provisions of Buy America sometimes, we can't incorporate some of the really 

nice stuff. 
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But what I think it really comes down to is dollar and cents. 

If you have a very large transit agency, let's say -- I don't like to use examples, 

but let's say New York. They have fare boxes on 4,000 buses and there is, you 

know, in order for them to change the amount to a new design or a new system 

is an extremely large amount of money that someone would have to, you know, 

outlay in order to do that. 

And I'm not saying it's not a worthwhile thing to do, but it's getting the 

justification, getting the authorization and getting the money in place to do that 

kind of thing. 

So a lot of times it really comes down to what can individual transits afford 

because smaller transits, it may not be a big thing for them to do. But for the 

larger transits it's quite an undertaking. 

>> CHRISTOPHER HART: I was actually thinking not just the fare 

boxes, but overall vehicle design because certain Jim's diagram with a slightly 

angle door, international manufacturers figure out --

>> KERRY LEGG: Make no doubt about I, we're keeping a close eye on our 

European competitors and I can't speak for the other U.S. manufacturers, but 

we're always looking for new ideas, better ways to do things, greener ways to do 

things, and sometimes they look really good, they look great on paper. But 

they're also more expensive. And bottom line is a lot of buses are purchased 

with federal funding and if they want to get as many buses as they can for the 

amount of dollars that they have got, so they don't go for the more expensive 
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options that are out there. 

>> SCOTT WINDLEY: Not to beat the fare box to a bloody pulp or 

anything, but does anybody know -- let's say they came up with a better design 

for the fare box. Is there any reason why newer buses, newly-acquired buses 

wouldn't be able to have that better fare box and still be able to use the, you 

know, not make it so that the older fare boxes can't be used on the older buses? 

But I understand the whole thing of having to change out 4,000 fare boxes. I'm 

just saying maybe it has -- because we do this in accessibility all the time. You 

know, newly-purchased devices should meet the new requirements. Older 

devices until they get renovated, stay the way they are, so --

>> Ghosh Choudhury: The way we procure the new buses, we buy the buses and 

give the bus manufacturer a sample of the current fare box. We don't buy fare 

box every year. We take the old fare box out and the fare box manufacturer 

come to upgrade with the new technology, electronic device on it. So all the J 

1939 competitor and we use the same fare box. With the new fare box, we give 

the one sample to the manufacturer based on the design they have to provide 

the location of the fare box wherever you want. 

>> MARSHA MAZZ: It would be helpful if people would say their 

names for the record. 

>> Melissa Anderson: If people could say their names as they speak, that way we 

can keep better record. This is Melissa Anderson from U.S. Access Board. If 
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there were regulations that designated a turning space at the front of the bus, 

would that put a big cramp in the whole fare box turnover? 

Because I know our regulations apply to new and altered vehicles, but there 

does have to be a way to use old technology while the new technology is being 

transitioned in. Is that something that would have a really big affect on bus 

operations? 

>> Can I speak on -- so my name is Jonathan walker. I'm with GOSH as well, 

Washington transit authority, bus engineering. 

WMATA at this point in time is actually looking into advance technology as far as 

collecting fares and we're actually moving more towards an ATM-type of device. 

But unfortunately that's three to five years away because of once again, there's 

always funding. 

The challenge that you have with bus manufacturers as well as fare boxes 

competition, so some may or may not know now at this point in time there's 

only two bus manufacturers in the United States. Likewise, the fare box, there's 

-- correct me if I'm wrong, there's what, two manufacturers, okay. 

So what we're finding out is it's better for us to look at some of this more 

advanced technology, which is slowly but surely coming around and that will 

eventually hopefully free up some of the real estate space. So it's a combination 

of timing and it has to do with who's actually in the industry at this point in time 

producing certain things versus what we currently have in our fleet. 
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I foresee in probably another three to five years that we will get to a point where 

the existing fare box that we have will be obsolete, but that has a lot to do with 

finding funding, finding manufacturers that have that capability, American 

manufacturers hopefully. There are European countries but then you get into 

the Buy America issue that the authorities are getting pushed more and more to 

increase their Buy America percentage and trying to find American companies 

who have that capability. So I think it's a number of factors. It's not just one 

factor. But I think in three to five years you will see a major change in the 

existing fare boxes that you see now on the buses will be no longer and that will 

free up some of the space needed. 

>> I'm sorry. I'm Gosh...in addition to Jonathan's statement. Four years ago in 

Europe the buses and I said do you have an interest to come into the United 

States? 

We have buses, they have fare boxes and they're not there. And two months of 

liability and they try to stay away from that. The other reason in order to start 

coming that soon and our way that what we like to have. 

>> And just one more note also to let you know...the last count if I remember 

correctly, there's only roughly 4,000 buses per year produced in the United 

States for the U.S. 

>> Heavy duty buses, yeah. 

>> Heavy duty buses. That's not a lot when you look at the trucking industry and 
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things of that nature. 

The thing challenge that we're having with moving to this new technology with 

ATMs and so forth, there is a lot of infrastructure cost that needs to be 

implemented as well because if you look at your ATM machines and so forth, 

those are directly connected to some type of network where they validate the 

transaction immediately, in seconds. 

So one of the challenges that we're having right now or they are looking into is 

funding funding. WMATA is finding funding to get all that back-end 

infrastructure set up so there is a lot of stuff in the back end, a lot of money, a 

lot of design and so forth that needs to be in place before you can in turn put 

these ATM-type of devices on the buses. Thereby, getting away from the 

existing fare boxes. 

>> Kerry Leg...in answer to Melissa's question, if there was a specific regulation 

which stated vestibule sizes and things, what affect would that have? 

Generally that would mean that our customers would find themselves in the 

position of having to procure new fare boxes before they could put the buses 

into service and they would generally not be in a very favorable position for that. 

I mean, we have well over 200 different transit agencies in North America that 

we service right now. 

And, you know, some of them have very expensive machines. The best one I 

ever saw looked like a big brass platoon. You walk in and throw in your coins 
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and you're done. 

>> Who was that? 

>> It was in Northern Fiscata and I'm not going to embarrass them by saying who 

it was. So every customer is different. But we don't want to put them in the 

position where -- or put ourselves in a position where they would go with a 

competitor's product because, you know, they promise they can make your fair 

box fit. Obviously the regulation needs to be in place for the passageway. But 

whether we can regulate out fare box sizes and that sort of thing, I'm not sure. 

>> Devil's advocate, what if in your current regulations we call out for 9-inch --

what if regulations called for 9-inch turn curb under a fare box, what would that 

do? 

>> Well, that would remove the fare box and the pedestal it's sitting on. 

>> CHRISTOPHER HART: But I'm familiar with wheelchair GFI 

equipment. Half of that -- is that the case in most GFI fare box vendors? 

>> I can't answer that question. 

I don't know the interior workings of most fare boxes. 

>> If you raise the fare box anymore, what we have now I think the maximum 

you can go is 6 inches with the large fare box but then -- there is a regulation 

that driver responsibility so they would have to meet it so that means they can't 
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go any much higher. 

>> SCOTT WINDLEY: So what you're saying is the fare box has to go 

down to the ground. It can't be just a device that really has -- I mean, does it 

have to be as deep as they are? 

>> That is a very, very good question. That's the thing we have discussed, why 

have to be so big and so deep. I think that's the thing I just -- they are getting 

new design, new, slimmer compact design which compares to the current 

technology. I think we are going to see very soon that kind of thing. 

>> SCOTT WINDLEY: Okay. 

>> CHRISTOPHER HART: Jim, I think you were going to say something 

before. 

>> I go along with Kerry's note on fare boxes. We have got -- we have a lot of 

buses in Calgary and they're very proud that they buy old fare boxes and use 

them and we have had to go in and redesign our bus and put them in places that 

we never thought we'd have to. 

>> CHRISTOPHER HART: Can I follow up on the comment of heavy 

duty boxes. I would like for all of us to know what the agenda was? 

>> The volume of the -- I have a chart in the bus industry that was done this 

2001. Every year you change the date and nothing else changes. 

Basically as Kerry noted the big buses are 4,000 to 5,000 a year, period. And 
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then the mid-size bus manufacturers and the one under 30 feet are about 12 to 

15,000 a year. 

And what ice been a big gap is the gap in between because the cut-away market 

used to be known and still is known to pure high-four cutaways as throw-away 

buses. 

You know, I went to one on our dealers meetings in Hawaii and he said he 

started a maintenance schedule for small shuttle buses and everybody laughed 

because they don't maintain them. They just throw them away. That's one of 

the battles we had when we went to the same size bus with a low floor and 

basically we had to go in and first convince the university and the industry was 

that this wasn't a throw away bus because obviously whether it's Steve's design 

or anybody else's, if you make the low-floor bus and make the modifications you 

do, there is no way that you can compete dollar for dollar with a high-floor bus 

built on standard rails. You know, it's a more expensive bus. You have to get 

functional value. So the duty cycle has to be longer on the bus and you have to 

offer them other things and other efficiencies are the fact that you don't have 

steps so loading and unloading times and efficiencies go up. You know, the 

number of cycles that Kerry indicated that he saw on buses of use or Cleatus said 

on buses, we have a fleet in Lubuk, Texas. We have 16 buses down there. They 

run six days a week, eight hours a shift. They run 16 hours a day, six days a 

week. And when we started out, we started having problems with our ramps. It 

happened to be a brawn ramp. I'm not pointing fingers at them. But they went 
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down there again and discovered that in two months they had 5,000 plus cycles 

only ramps. Engineers came back and said you're using the ramps too much. 

No. The answer was they're not using it the way expected. They're being 

ineffective. The Lubbuck, Texas has indicated that by use of our low floors there, 

that each bus saves 100 minutes of idle time that they can do something else 

with and they can make useful trips with. They take anything from normal 

passengers to passengers on hospital gurneys to dialysis on this bus all the way 

through, the full range of them. And that's what's happening and again it's the 

operational fleet that when you can use a bus like this and rather than normal 

use than having to call in a specialist, your costs go down much lower. 

Frankly, when we started out our product, we did not expect as much of the 

current product to be used at normal route services as it is. We're having a 

tremendous amount being used in standard route service because it is efficient 

and effective and it also helps fight -- one of the biggest problems fleets have is 

the ghost bus or empty bus syndrome where people call in and say I saw a bus go 

by three times and it only had six people in it. That can't be efficient. So a lot of 

agencies are using smaller buses. Are parking the big 40-footers on off-hour 

times and putting the smaller buses on the routes to be more efficient and get 

the operation costs down. But the quantity of the buses is very stable and if you 

take small to large buses, use it in transit or paratransit operation, you're talking 

a maximum of 20,000 units a year and that's the problem is you go to South 

America, I's 200,000. If you go to China, it's a quarter of a million or a half 
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million buses a year. It's a whole different game. 

>> CHRISTOPHER HART: I want to get back to one other question, 

Kerry, and...is when you think about having a bus, that passage way of the front 

wheels, how wide can that get given all of the regulatory requirements for 

vehicle size and for engineering of suspensions? 

>> Well, I think I responded to that in one of the letters that I sent to Jim Pecht

back in November 2010. And with the existing axles, we were looking 

somewhere in the range of 35 to 36 inches between wheel wells. So -- and, you 

know, that also took into account that there needed to be some sort of tapering 

at the floor level to make sure that the buses were easier to clean and that sort 

of thing. But --

>> SCOTT WINDLEY: What's the width of the cab in front of the rear 

wheel for like entry and the driver's seat and all that? 

>> I don't have the front overhang angle numbers with me, unfortunately. 

>> CHRISTOPHER HART: Would it be helpful in... my challenge is 

knowing fleets around the world and some manufacturers...have slightly bigger 

entry vestibules and if we could actually identify all of -- and figure out who's 

doing what and have you at New Flier done that comparison of vestibule and 
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passageway sizes, has anyone? 

>> KERRY LEGG: Well, yes. We have looked at that. Obviously if you look at a 

Nova bus, the front overhang in front of the axle is much larger there. Their 

front door is larger. But in turn they have more issues with approach angles than 

we do. 

The buses actually physically is making contact with the surface whenever it's 

going into a parking lot or, you know, abrupt changes in the street configuration. 

So it's -- you know, which way do you want to go? 

You can suffer more damage or you can, you know, try and work with what we 

have got and make it work. Because we think we can. 

You know, having larger door is desirable. We'll get as large a door as we 

potentially can. 

I really don't -- what else can I tell you about that? 

I mean, it's a design consideration to try and prevent damage from the vehicle 

and to, you know, overall make the ride more enjoyable because when the 

physical structure of the bus actually contacts the ground as you're turning 

corners and things, it's a little alarming for the passengers. 

>> We're not talk about how much a new bus contacts the curb or a --

>> I think we have tried the front angle. We have purchased several hundred of 

the buses that you see on the street. Those are way, way larger front overhang 

and as Kerry mentioned we had some issues on that one plus you're adding 
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more structure and more weight. Those buses are 5,000 pounds heavier than 

the current Excelsior buses. I they back away from that when they saw the 

negative side. So there are some issues there so that is correct. 

>> CHRISTOPHER HART: Well, what would be -- what would happen if 

it was in the guidelines or a requirement to angle the ramp a couple of degrees 

sooner than in the diagram to improve that approach into a passage or aisle? 

>> Kerry Leg with New Flier. Are you suggesting instead of having the doorway --

>> CHRISTOPHER HART: At a 90-degree angle. Just 2 degrees. 

>> That's a lot of design changes and it would have to go through Altuna testing 

again for the structure. 

Difficult to say. I mean, it would change the whole appearance of the front of 

the bus, the location of head lamps. You know with the cut-away it's different 

because the actual front of the vehicle is smaller than the back of the vehicle. 

On heavy-duty transit bus, we're set with a front mask design. If we put that 

though on a slight angle as they have done, that's going to change the front mass 

design. It's going to probably or potentially remove the possibility of ever 

putting bike ramps on the front of the bus. 

>> Kerry, I ask that because I'm seeing high turnover...certainly, Nova, Delaware -

- why they're doing that and I...with their buses, so clearly --

>> Yes, we are getting away from the box design. You know, it's not very 

creative. We're getting a little bit more in the way of tapering and design styling 
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and I can see for the nova to put this because it helps with their steering when 

turning. 

Does New Flier has any plans to do that? 

Most likely yes just to make the buses look for stylish necessarily but one of the 

advantages is that it could help increase the size of the vestibule or perhaps put 

it at a slight angle so that it's better room. But I can't guarantee that's the way 

it's going to go for right now. 

>> CHRISTOPHER HART: Does a door type impact -- San Diego has a 

buses on...does that change that --

>> The single plug-style door has its own issues. You could either have the plug 

go forward or back. If it goes forward, then there is the potential of it striking a 

pedestrian. If it goes back, it could hit the tire if the wheel is turned at a certain 

angle. We have pretty much stayed away from the plug-style door on the front 

of the vehicle. We have tried it mid coach on the Invera design and with not a 

great deal of success. It certainly had a lot of design issues. Currently we're 

using slide glide doors on the front. We have had a lot of success with the 

maintainability, serviceability and they can come in larger widths as well. 

So realistically as long as we build an opening for them to put a door into it, it 

seems to work just fine. 

So it's an overall design change and there will be new models of buses coming 

out eventually, but currently we're not doing that, no. 
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>> CHRISTOPHER HART: Is it conceivable that a space that's identified 

for a rail to be dropped in, could that be angled without changing -- and using a 

slightly wider door to get that same angle? 

>> With our existing design, I don't think so. Not with the location of the wheel 

wells and it would be fairly difficult. I can't speak for all of our competitors. 

They may have pending designs out there, but currently we don't have anything 

like that. 

>> SCOTT WINDLEY: So is there anybody that has any other burning 

ideas or things that they would like to -- sure. 

Go ahead. 

>> Sorry to do this so long after the video we looked at from Lift-U, but when the 

ramp deployed, it looked like it unfolded and then dropped the 1:6 portion that's 

located inside the vestibule dropped into place. But is is structurally possible to 

keep that -- I mean, can the ramp be made sturdy enough to withstand the 

design load and not drop against the 1:6 structure underneath? 

>> I'm not sure if I'm following your question. 

>> Okay. In the video, there is a part where it unfolds and then the top of the 

ramp kind of drops down into place at the 1:6 slope. 

>> When it's deployed to the ground? 
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>> Right. 

>> SCOTT WINDLEY: It doesn't do that when it's at the curb. It just 

stays. 

>> But where it creates the grade break with the rest of the ramp that's causing 

the issues that we have. 

>> If we're referring to the new dual mode ramp, there is no grade break. 

>> Okay. Back to the one where there is a grade break, which are we going to 

get away from those, that would be good. But if the grade were held constant 

but the hinge were at the top of the ramp, is that possible? 

I mean, it looks like in the video part of the ramp was supported by the structure 

underneath. Does it have to be that way. 

>> The video which was the dual mode which has the operable ramp that's 

inside the bus. The other 1:6 design when the ramp is deployed, the interior 

portion is fixed and you'll notice that the pivot is not at the top of the step edge. 

It's in the side rails of, you know, an inch or so below when the pivot occurs and 

the inner ramp and the outer ramp all align themselves to be plainer and when 

it's deployed to the ground, there's no grade break. When it's deployed to a 6 

inch curb, no kneeling, there's essentially grade break. Road crown, bus 

kneeling...a lot of times drivers are used to kneeling the bus all the time for ramp 

deployments. It's a carry-over from the 1:4 ramps. That was a standard 

practice. They always knelt the bus whether the 1:4 bus was deployed to the 
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ground or sidewalk. But with the 1:6 design, it's best that they don't kneel when 

they deploy to the sidewalk. Otherwise, you introduce that grade break. 

>> So can we basically get rid of the grade break problem just through 

operational policies? 

>> Not entirely just because of the other items I mentioned, sidewalk height, 

road crown. 

The next generation of that ramp that has the fixed slope, I had showed a couple 

of slides of that where we're taking advantage of the threshold transition that's 

allowable where you have the quarter inch and then up to a half inch 1:2. We're 

able to lower the apex at the top of the interior ramp by doing that and then also 

on the exterior end of the deployed ramp itself, we have put a bit of a bend in 

that so we have raised the top surface up and in so doing, we're able to get the 

apex of the transition moved outboard. For the Santa Clara and the Lane Transit 

installations, we could move the apex out four inches. 

Now, if the bus were to kneel to 11 inches, we can move it out another four 

inches for a total of eight inches. And in most cases we can also flatten that 

interior slope by about a degree and a half. 

So instead of it being a 1:6, it would be a 1:7. 

>> Thank you. 
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>> CHRISTOPHER HART: I want to add to that hypothetical question. 

Going back to the wheel wells...if there was a requirement to taper a wheel well 

so it was not 90-degree angles, would that be harmful? 

>> Kerry Leg with New Flier. With the existing suspension components, I don't 

know if it's going to be possible. That front interior corner of the wheel well is 

where your radius rods are going to attach physically to the structure. 

>> CHRISTOPHER HART: So I'm confused because I know some New 

Fliers with tapered wheel well corners. Is that just an interior design option? 

>> Some of the older Fliers had some tapering on them because obviously we 

had some space in those. Some of the newer designs it may look tapered, but 

basically we're making the wheel wells as small as we can obviously so that we 

have got more room for seats and passengers in general plus the wheelchair 

corridor. And --

>> CHRISTOPHER HART: Because one of the things that we have 

heard depending on the type of chair, as you make that turn into the 

passageway, you will catch your rear left wheel on that 90-degree corner. If that 

was tapered slightly for you to adjust a little more wiggle room and you don't 

beat that corner up. 
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>> One of the things, you know, again, you go with technology...one of the things 

we have done is our bus floor is designed in 3D solid works and the floor is 

composite and we were actually, by doing that, we were able to drape the wheel 

houses right over the suspension bits as close as possible. It's -- you know, it 

again gets into a type of construction. If you have got -- depending on the 

structure underneath, that could limit the amount of in our case we designed 

again being fresh sheet, we were able to design it around and in fact our wheel 

houses are the same side to side. They're shifted over to the curb side so that 

you have two more inches to make that corner better. But all of that was only 

possible because we literally 3D draped the surfaces and CNC cut all of the floors 

to do that. 

>> But ultimately, though, isn't the size of the wheel house limited by the need 

for the bus to actually turn? 

I mean, you have got those big tires in there and they need the -- I'm not sure I 

understand how we're trying to taper the wheel of the bus. 

>> CHRISTOPHER HART: John, you...there's always going to be --

where there's nothing in that space. And so you just cut off an inch or onedegree angle that says you get that back into the passageway. 

>> I guess I'm wondering how big of a taper we're talking about. I mean, if it's 

just the interior surface, actually reducing the area of the wheel housed --

>> CHRISTOPHER HART: How can we think about squeezing it into 
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that vestibule passageway and how will it help the industry rethink their 

practices, what we see on --

>> This is Kerry Leg with New Flier again. 

Chris, I mean, there is a couple of factors to think about here. First of all, you 

can't confuse the existing buses on the road with what we want them to be like 

and obviously there's some older designs out there that can't be modified simply 

because of their structures. In our current designs, we're trying to maximize the 

space in there as best we can to make the wheel wells smaller, but there are 

other design considerations. You have got radius rods, air springs, shock 

absorbers, break canisters and all of the components for the wheel plus the 

room for the legal to turn and not make contact with the ground. Sorry, with the 

structure. And then you have got to make it last for 12 years, so it's got to go 

through the heavy duty cycle testing, so if you try and make the frame work in 

there smaller, which is the only thing we have control over, because we're 

buying set components from manufacturers like MAN for the axle or Gabriel 

shock absorbers and things like that, those things we can't really change. 

The only real change we can make is to the structure itself. The structure has to 

be able to survive, so we have tapered it down. We have made it as, you know, 

as small as we can. And so really the only thing we can look at or can affect is 

future design. 

And I know you've seen some unusual ones out there on the street, but once 

again, that's past components of things would probably be never be retrofitted 
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simply because there aren't the dollars to retrofit or not enough funds to 

change. 

>> SCOTT WINDLEY: That's what we're talking about is new designs. 

>> CHRISTOPHER HART: And also I want to add to the question...if 

given the disparity between heavy-duty buses in New York and D.C., buses 

in...should we be thinking a little differently? 

If you have got a 25-passenger...should we be applying 40-foot --

>> I think there does need to be some difference in the regulations because 

you're talking about different restrictions. 

The pusher bus has no drive shaft. That's not limited. The other one was when 

you have the door between the wheel base you're always dealing around a drive 

shaft unless in the future you can go to electric, but that's a ways off and very 

expensive at this point. 

So I think that it does need to be looked at. Either the standards have to be 

broad enough and work for both and maybe that compromises too much to do 

that or we need to look into some areas that need soft separate provisions in 

them. 

>> SCOTT WINDLEY: We do have separate provisions for smaller 

buses but we need to look at where they're all --

>> Because I mean just in the loading for wheelchairs obviously when you have 

an over 30,000 pound bus, your loading to wheelchairs anchors are much less 
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because the bus becomes a ramp. Whereas if you had a lighter bus, it's 

different. You have higher load requirements. 

>> SCOTT WINDLEY: Okay. 

Well --

>> Well, Chris, I would agree that there are probably some areas of the 

regulations that could be modified specifically for vehicles over a certain weight 

classification. 

Obviously, the cut-aways have some design advantages that they can take into 

account that we can't do in a heavy-duty application. So I agree that potentially 

there are, but we'd have to look at them, you know, in case by case and find out 

which are unobtainable in a heavy-duty application or which are nonapplicable 

to say cut-away application. But, yeah. I think there might be some way of 

classifying the regulations to apply to different vehicle types and sizes. 

>> The one thing we're running into in realization of that in our new product, 

that new bus, Pusher bus that I showed the pictures of, one thing that's very 

different about it is it's 12,000 pounds lighter than a standard 30, 35-foot bus. It 

weighs 12,000 pounds less and there was a lot of deficiencies because of that 

and everything was optimized. But we're a betweener, let's call it. We're not 

30,000 pounds, but we're configured like a 40-footer and we're not -- you know, 

and we're not the configuration of a cut-away. So we have had issues in finding 

components that work for us, but it also becomes in which regulations do we fall 
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under because under configuration bases, we look like a 40-footer. I mean, our 

33-foot bus has -- yet, that bus weighs 16,000 pounds and a 40-footer would be 

30,000 pounds. So those are the things that we're learning and as technology 

goes, those are things that you always run across. When you cross those barriers 

and create new things, you discover things that work, but rules that don't quite 

fit anymore and it's the application point. So I think, you know, obviously light 

weight is going to be a factor in the future. I know we're not the only ones 

working on those, right, Kerry? 

(Laughter) 

>> And we'll be seeing more of that, but they do fall in between. 

>> This is Melissa from the Access Board. 

So what seems to be more practical, dividing the classifications between weight 

or length of the vehicle? 

Right now we have it divided by length, but what's more of an industry 

standard? 

>> Well, if you look at the -- call it the cut-away style or buses that are built on 

cab chassis, there is a bus out there called the Passport which Eldorado builds. 

It's built on an international medium-duty chassis. But it has the characteristics 

of our cut-away base product and that is the front engine rear wheel drive and 
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therefore has the same opportunities, same limitations. 

So again, it's difficult to take one qualification of length and fit them or one 

qualification of weight and fit them. 

I don't have the answer, but, you know, it's good that we're thinking that way. 

>> CHRISTOPHER HART: I hear you --

>> I think that this is -- this is Steve Asztalos with Dallas Smith. I think that Jim's 

comment about the front engine cab chassis versus the rear engine Pusher is 

probably the divider no matter -- because whether you build a 30-foot reengine 

Pusher or 40-foot, you have the same advantages and constraints that they have 

to work around and we have the same thing in a chassis cab whether it's an E350 

Con Line or an international bus chassis, that's a chassis cab. We have the drive 

shaft and exhaust which is an issue on those which is not on the Pusher. They 

have the front wheel box and things like that that's in their way. 

I think the vehicle -- that particular layout is the -- should be the configuration 

that the vehicle overall not their weight. 

>> CHRISTOPHER HART: And that was what I was hoping that folks 

would begin to discuss because I think as we go to more electric motors --

completely change how we do...it's going to open up a lot of opportunities to 

rethink the vehicle layout and --

>> And I think as long as -- Jim Bartel...as long as the regulations or standards are 

put together so you don't restrict what's done to improve beyond it, that's the 
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important thing because what we don't want to do is create standards that are 

built around the drive shaft in the middle of the vehicle assuming it's always 

going to be there and that if you do it in the future five years or 10 years down 

the road, do all wheel motors and have no drive shaft, that prohibits the 

manufacturer from improving the vehicle because of the standard. 

>> WMATA, I got a question. Is there a chassis determined by the heavy duty, 

medium duty, light duty, this type of description, the chassis? 

>> The cut-away is obviously built on a General Motors chassis. The new bus 

we're building the chassis ourselves because after talking to every chassis 

manufacturer in the country and even getting the deer and the headlight look or 

we'll go back to Germany and see if in three to five years we can put it in the 

schedule, we built our own. 

(Laughter) 

>> Normally buses are heavy duty buses, those are 12-year tested buses and 

most of the transit property keep the buses 15, 16, 17 years because that 

reason. 

And those are average weight about, starting from about 38, 39, it can go up to 

45, 46, 48,000 pounds. So those are significant difference from the let's say cutaway bus. So weight is the main factor. Not the hardest sitting capacity. 

>> Exactly. Our new bus that I indicated has a curb way of 16,000 has a GBW of 
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2055. There's some benefits to that. It's fuel economy. It's hydraulic brakes. A 

bunch of things that make it friendlier and easier to find operators for. There are 

a lot of buses but there are a lot of trade-offs. 

>> From a DOT standpoint, does this conversation give you heartburn? 

>> Not as such. You know, the things going through my head right now are the 

different ways that buses are classified for purposes of say the national transit 

database and things like that and I don't know, you know, if there are any, you 

know, NITSA-type things that come up in terms of safety regulations or not. 

That's not my end of things. 

I'm sure the further we get into this discussion, you know, the areas of heartburn 

will become apparent. 

(Laughter) 

>> Okay. Thanks. 

>> This is Kerry Leg with New Flier. The DOT classifies buses by weight and by 

type. So either you're over 10,000 pounds or you're a school bus, you know. 

(Laughter) 

>> Is that the classification? 

>> Pretty much. 

>> I've had many ways trying to fig you out which regulations actually apply to a 

heavy-duty transit bus because we're not school buses by definition. 
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But we do or have to follow the spirit of the regulation for a lot of things that are 

created for school bus. We are over 10,000 pounds, so a lot of the regulations 

are basically written for vehicles under 10,000. And so do they apply or do we 

just incorporate them because if we don't, we'll get sued. But, yeah, the 

classification and rating system for buses is not hard set with the DOT and NITSA. 

>> That's for NITSA? 

>> Well, they don't necessarily specify between a highway coach or a city coach. 

But, yeah, a lot of times people seem to be under the impression that city 

coaches never go over 45 miles an hour. 

>> CHRISTOPHER HART: Every day in Boston. 

>> Yes, they do. 

That's another one of my nightmares. But I won't get into that. 

So, no, there isn't a set classification system currently established with the U.S. 

government, I'll put it that way. 

>> CHRISTOPHER HART: How much space can we get at the top of 

the ramp and the fare box if there is no integral design process --

>> This is Kerry Leg with New Flier again. The fare boxes as they are today are 

pretty much as high as they can possibly be without interfering with the driver's 
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line of sight. 

>> CHRISTOPHER HART: Right. I don't make any suggestions to 

raising the fare box. 

We just wanted to...and we need to understand if that was possible. If the bus 

design was an integral process, would the -- and the fare box all in the 

same...and you had your seat manufacturer and your driver control dash 

manufacturer all in the same room, what could be achieved in terms of 

rethinking that whole entry barrier? 

>> Well, obviously, I mean, they would need to re-evaluate the storage space 

that they have in there because fare boxes have these big empty canisters to 

collect coins. Whether those storage spaces are of proper design, location, what 

have you, if they can be relocated, repositioned, made smaller, the mounting 

provisions for it, now, they would have to try and mount it off of the side wall of 

the passageway as opposed to a floor mount. And, you know, unless we do 

actually get those fare box manufacturers into the same room and, you know, 

keep a good distance between them and let them try and discuss what it is they 

want to do, I mean, we couldn't incorporate or design and build a bus with an 

integral fare box because a lot of our customers wouldn't accept that. 

>> CHRISTOPHER HART: I think we all get that. But what I'm trying to 

understand, how do we change -- does the board need to help further the 

dialogue between all the manufacturers or technical assistance? 
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How can we help? 

>> Well, you got the meeting coming up in Seattle. I suggest that you put the 

invitations out there and ask them to attend, you know. 

>> SCOTT WINDLEY: Get them in the same room. You're telling me 

you got to have some distance between them. 

>> Either that or give them some Nerf bats. 

>> SCOTT WINDLEY: You don't want to have October 2nd turn into a 

Jerry Springer Show. 

>> CHRISTOPHER HART: I think do you have an understanding of 

what that design process could be. 

>> I have a basic philosophy. If you're going to make an omelet, you got to break 

some eggs. 

>> I think potentially, Melissa, if these manufacturers were put into the same 

room and told, okay, guess what, you know, in three years time, this is the space 

you're going to be allowed to put your fare box in and see how they react to 

that. 

>> I raised three kids. I can put them in the same room. 
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>> MARSHA MAZZ: Chris, earlier there was some discussion about 

flatness and how we measure flatness and I think there was some discussion I 

think during the break about warped floors, et cetera. And I would like to focus 

the discussion on those issues for myself to have at least a better understanding 

of exactly what the state of the art is and what the concerns are. 

In general, we consider anything that's sloped 2% in all directions as flat. 

Also there was some discussions --

>> It's 2% and not 2 degrees, right? 

>> MARSHA MAZZ: Percent. 

And also there was some discussion about a threshold, which sounded to me like 

it was at the top of the ramp. Typically in buildings, we have a level landing 

before a threshold. We don't have a threshold at the top of a ramp. So I wanted 

to understand those two issues a little better if I can. 

>> SCOTT WINDLEY: Thank you, Marsha. So let's do the level floor 

issue first -- or the floor issue. 

So who wants to start the discussion --

>> CHRISTOPHER HART: Who wants to dive in? 

>> JIM BARTEL: You know, that decision or how it's defined is integral to what 

we're doing, what we have been doing and to continue success to the customer 

in the future because we are warping surfaces. All of our entrances are warped 
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and they're warped for a reason. And that is to create the most gentle transition 

we can and to assure that in all cases under normal flow of the chair that all four 

wheels are able to contact. In doing that, I think we have made the product 

better for a better customer base, more usable. I think your success in the 

marketplace test to that where 90% of the volume and everybody is trying to 

copy us. 

But what we don't want to do is create standards that cause it to back off. Not 

that it wouldn't be -- it would be easy for us to back down from where we are. 

But the product, if the product becomes less user friendly, then that's the wrong 

thing to do. I'm not saying we have all the answers. I'm saying -- and that's why 

I made an offer to the board to if they would like to send representatives to our 

facility because we have products that cover the broadest ranges and they're all 

in cad that we would be glad to share that and have those discussions and help 

define those because, you know, maybe what we're assuming, maybe some of 

the things we're assuming are a little too far out. Maybe they're not. But, you 

know, like I say, we have -- with 1,000 units out there and services as far as the 

ramp to transition into the buses, as far as we know, I have had zero complaints 

from anybody, which is we're -- we're very happy with. I mean, we're happy 

with everybody. 

>> MARSHA MAZZ: A follow-up if I may, Marsha Mazz, U.S. Access 

Board. I'm having time visualizing how a warp in a particular area where you 

may be turning serves to keep all four wheels plainer, if you will. 
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>> JIM BARTEL: That's why we have to show you the data. I mean, basically what 

it is if you take -- it's when we're talking earlier where you would have -- when 

we showed the early ones, the heavy buses with the ramp that goes down, 

comes up and a bus and a chair was trying to make the corner, you obviously got 

a ledge or something there. 

If you look at it if in especially in the application where in the cut-away style 

where it is desirable to start the turn as soon as you can which means you're 

partly on the ramp yet. 

As you make this turn, if you have a flat plain where you come up and bend, as 

you go at any angle but straight on, one wheel is off. One wheel is off. 

However, if you very carefully warp those surfaces, yes, we do assume there is a 

slight amount of flex in the chair. If it's a perfectly rigid chair with perfectly rigid 

wheels and tires on it, yes, theoretically you can't do it. But there is some flex in 

those. Not a lot. But there is a little bit. 

>> SCOTT WINDLEY: From what I understand, Jim, the way you 

design your floors, is there's really not any place that's actually flat dead level. 

>> In the transition, correct. Absolutely not. 

>> MARSHA MAZZ: I think I got a picture of it now. 

>> CHRISTOPHER HART: I realize now I was on your vehicle a year 
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ago. I don't recall -- it was really an aha moment. 

>> MARSHA MAZZ: If I can, one more follow-up question. Marsha 

Mazz. Does this work equally well for all types of wheelchairs? 

I mean, every wheelchair has a different wheel base obviously. But scooters in 

particular, does it work equally well for scooters and say manual chairs and 

power chairs? 

>> JIM BARTEL: Well, we're still doing studies -- I mean, there is a broad range 

and --

>> MARSHA MAZZ: Particularly the 3-wheel scooters. 

>> Right. Three wheels are not a problem because three points always create a 

plain wherever you put them. It's the four wheels that are -- you have to watch 

more closer, much more closely in doing this. And like I say we have spent a lot 

of time and a lot of effort doing this, and we have done it to make it the most 

friendly and usable for the people who need it, and like I say again, I'm not 

saying that we have all the answers, but I want to make sure that what we come 

up with as a final regulation or a standard is usable for the end customer, most 

usable possible and is the most flexible so it doesn't say, okay, only your ramp 

works or only my bus works or only his, you know --

>> SCOTT WINDLEY: We would never try to write something like that. 

>> JIM BARTEL: You don't knowingly do that, but -- so, yeah, so that's why I think 
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to fully understand it and the work we have done and get other people's, 

especially the board's insight to it, that's why I'm recommending a visit to our 

facility where we would be willing to share this and look at all of our products 

and the cad data on how we have come up with this. 

>> CHRISTOPHER HART: Is if you had a very short wheel base 

wheelchair like John and it was a completely rigid frame, you might...very, very 

short time. If you happen to hit it at the right angle. But it's a larger, more 

typical -- I can't conceive of a scooter tire. It's high enough. You know, I don't -- I 

would be very intrigued to actually look at it in detail and see your cad pieces 

and we could -- as someone who has dealt with chairs in the last nine years...and 

whenever you lose that traction, as you make that trek going down the rail, it's 

scary. Likewise when you take that lift going up and you don't have enough to 

get over that lift, that's a challenge. And that's why we want to eventually get all 

information to get this right. 

>> SCOTT WINDLEY: Jim, just a question...are most of your customers 

more paratransit-type application or do you have mass transit? 

Because somebody might be more independently --

>> JIM BARTEL: We have got 100 buses in Calgary that are run all road service. 

Hamilton, Ontario. Lubuk runs a paratransit. We have got a broad range, but I 

would say more than 50% of them run route service. 

>> SCOTT WINDLEY: Okay. Thanks. 
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>> JIM BARTEL: So we have got a very broad range and a very broad customer 

base. 

>> MARSHA MAZZ: It's cheaper as possible because of the materials 

that you're using, does that make it --

>> JIM BARTEL: I mean, all entrance, our entrance -- the transition between our 

ramp and the main floor a molded composite structure. In our new bus, the 

entire floor is composite. But the entrance is a molded composite, all C&C cut so 

that it's very accurate. I mean, the latest one -- the toughest one to do has been 

the latest one which has no kneeling and that's really to get -- what we found out 

is that getting through a low-floor bus on a cut-away brought the product price 

down to around $100,000. But you have assisted living facilities and private 

operators who do not get any FTA assistance and contractors who could still not 

warrant the extra price. So this last product was done to address that. We do 

not see this freedom product ever going in most route service except the first 

customer and that's always Calgary who brought 100 of them. 

(Laughter) 

>> SCOTT WINDLEY: One reason I ask that question is because it --

you know, from my experience with -- I don't use paratransit, but most 

paratransit, they're more willing to assist the person getting in and out and so 

that wouldn't give us a real feel of how these surfaces actually work because 

when it's mass transit, you know, you're more on your own to get in and out. 

>> JIM BARTEL: It's interesting because it varies a lot in Canada. 
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In fact, the ones we have in BC transit, they only put one wheelchair position in. 

ADA would require two besides the bus. 

And the individual has to get on the bus and has to tie themselves down, secure 

themselves on period or they don't take them. I mean, it's bizarre. But that's 

what it is. That's the way they operate. 

So we have got a wide variety and the main thing that has drawn them to it is 

the accessibility obviously and the -- I mean, I refer to our buses once you have 

entered the bus, turn the corner and start walking down the aisle, we're just 

another bus. 

The whole deal is the entrance. 

>> SCOTT WINDLEY: Yeah. Great. 

Oh, yeah, can we talk about the threshold that you were talking about, Cleatus? 

Was that at the top of the ramp that you're doing the threshold? 

>> Yes. Cleatus here. Is it possible to load up a couple of slides? 

Yes. That's the correct one. Before we get into the transition, Marsha had 

mentioned, you know, the vestibule slopes, and indicated you consider 2% being 

flat. 

There is a dozen different bus models here. I didn't name them by name, but 

their vestibule incline angle varies from C 1 and 0, but most of them are from 1 

to 2.5 degrees. There's one at 3.7 and there is another one that's at 3 degrees, 

and that's just the natural slope in their vestibule. 
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Next slide. 

This is a plan view of the 1:6 ramp. It's installed into front vestibule of the bus 

here and you can see the dimension to the right that's in the flat surface of the 

ramp. There is a dimension there of 20.8. That's our generation 2 that's 

currently installed at Santa Clara and Lane Transit. And you can see between the 

transition apex and the fare box is 20.8 inches. 

The transition that I'm going to try to highlight in just a moment is on the 

generation 3 version and you can see that the flight area has improved by 4 

inches. The apex transition has moved toward the door 4 inches. 

Request request. 

And then for ramps that can kneel to 11 inches -- excuse me. Buses that can 

kneel to 11 inches, we're able to move that apex out another 4 inches. 

And so as you get farther away from the aisle, it's going to increase the flat floor 

area to help keep as many of the ways on a level surface as possible making that 

turn. And once again, if the pedestal is downsized, then there would be more 

space to make that turn. 

Now, let's go to the next slide. 

The picture in the lower left, I had referred to this earlier when Melissa asked a 

question. The outward tip of the deployed ramp has got a bend to it now so that 

it -- and it complies with the transition rule. And then the picture to the right 
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and it may be an illusion here, but the apex up near the yellow stripe on the 

ramp is just slightly below the flange. The trim that bridges to the floor adjacent 

in the bus is there to the left a little bit. And that transition is beveled to the one 

on 2. 

And that apex is moved down about a half inch, but it's only at that apex as the 

floor moves inboard, it diminishes. And so it's flush with the floor on the inboard 

end. 

And what this has been able to do is get the transition apex moved outboard. So 

you can see in the picture in the upper left corner, you can see how the 

transition is tapered. 

>> SCOTT WINDLEY: So you have a -- so you actually have a curb all 

the way along this edge, right, too, because when you go to the top of the 

yellow, this -- you get up there, is that half inch beveled as well up there at the 

top? 

>> Yes. 

>> SCOTT WINDLEY: You're starting to turn into the bus? 

>> CLEATUS LEWIS: Right. At the top of the apex of the ramp itself to the lower 

portion of the 1:2 is only a quarter inch vertical rise. And then the remaining 

quarter inch vertical rise to the top of the floor is beveled at the 1:2. 
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Yeah, if you want to go ahead and advance to the next slide...this is, you know, a 

cross sectional view of that ramp that we were just looking at the photographs 

of. 

And you can see how the apex on the interior portion of the ramp is now only 

20.8 inches from the step edge. 

Whereas what Lane Transit and Santa Clara was doing, it was at 28 inches. It's 

approaching 29 inches. 

>> Is that enough with the passenger -- to pay the fare and come up there and 

stay pretty much? 

>> CLEATUS LEWIS: Since the interior slope is flattened just a bit also, it helps. 

If you go back to -- yeah, go one more slide back. 

>> That is 20.8. Your flat surface and up. Is that 20.8 room enough for it? 

Will I pay the fare on the fare box? 

>> CLEATUS LEWIS: What's happening and it was expressed in some of the 

letters from Santa Clara and Lane Transit was some wheelchair passengers, 

particularly manual wheelchairs where they -- if they don't lock their brakes and 

they stop to pay the fare, they --

>> That is my point. 

So if forget to lock the wheelchair, I mean, in terms like that. 
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>> Yes. 

>> That could be a safety hazard if you think about it. 

>> CLEATUS LEWIS: Right. If that area can be lengthened like is illustrated there 

to the 28 inches, and then if the fare box pedestal could be downsizeed a bit, 

that would help tremendously. You can see the dimensions at the bottom from 

the step edge to the fare box is 49.5. And from the fare box to the driver's 

platform it's almost 15 inches. 

I don't have everyone's measurements, but of about four bus manufacturers, the 

dimension from the step edge to the pedestal varies from 46 inches to 50 inches. 

And the dimension from the face of that fare box pedestal to the driver's 

platform varies anywhere from 10 inches to 19 inches. 

>> Right. 

>> So if the fare box pedestal could be downsizeed, you're going to have some 

improvement on the clear floor space. 

>> That is the key to our fare box, the base is almost about 18.2 inches. It's a 

huge base with the fare box inside which is from underneath. So that 14.8 

inches, my fare box will not fit in there. 

>> CHRISTOPHER HART: Does your fare box keep the driver --

>> The fare box we have, those are tank. Those are fare box empty are 92 pound 

weight. 

So that's monster fare box. 

If I come in there with a wheelchair passenger, if we have this 20.8 inches on 
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there and I'm going to slide back out. 

>> SCOTT WINDLEY: Brings us back to why your fare Boxs have to be 

so big. 

>> CHRISTOPHER HART: It also brings us back to the...taper on that 

wheel of why that taper is so critical that you cannot get that fare box out of the 

way, then something's got to give elsewhere. 

>> The buses we have just now from New Flier, our fare box base, just little bit 

over the edge, a little bit on the base. But the fare box sits inside of the base. 

The base is little wider. 

>> SCOTT WINDLEY: I think what Chris's point is on that bevel on the 

wheel well is that, you know, when you're having to turn and my wife can tell 

you from every corner in our house that a 90-degree corner is going to get torn 

up more than a beveled corner is. So just because of the way things are. 

So... because you can kind of rub against the beveled corner more and actually 

keep going and not get your wheel actually caught. So... 

>> MARSHA MAZZ: Well, Scott, if you taper the corner, you 

essentially change the turning and that really will make a difference. 

In fact, ANSI A 107 standard is looking at whether you turn for that corner. 

>> SCOTT WINDLEY: Right. So, Marsha, did that answer your 

question on the --
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>> MARSHA MAZZ: It did. It did. 

>> SCOTT WINDLEY: Is there any other issues that we would like to 

discuss? 

Melissa, did you have something. 

>> I guess between the bus manufacturers and the ramp manufacturers, what 

kind of testing do you use for visibility and it sounds like you might have some 

analysis and if you have it, we would like to have it. But do you test these 

products on people before you put them out? 

>> Way back when we started the first bus project, we built a Buck, wooden 

Buck and we actually did it add one of the Auto manufacturers, arranged a 2-day 

session and we had 65 people. Each one with different mobility issues go 

through the Buck and the Buck was built on jacks that could be angled and it was 

movable and flexible. So we moved the Buck around. We changed angles. We 

did various things. We had everything from people in walkers to people on, you 

know, full mechanical power chairs and everything in between. Not that I would 

call it, you know, I can't say it was statistical andized and totally accurate, but it 

was the best we could do and the broadest range of people we could put 

through it. And that set kind of the standards for what we saw were usable 

angles and usable transitions in that. 

I looked in from the beginning and saw that the 1:4 slope was really not 
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acceptable. We pushed beyond that right away. 

We built our first couple of buses with a 1:4 because that's the only hardware 

ramps we could get. We actually never, ever sold one. I think there may be one 

bus out there that has it in, a demo bus. But these were the type of things we 

did as before we put anything into the field. We worked with the ramp 

manufacturers, brought in the ramps and we went through trials of deploys and 

other things like that to make sure they were compatible. 

Like I said, in the ramp stage of bifold ramps we have been pretty much the 

company pushing the envelope there and both brawn and Ricon were both 

national companies responded and supported us through those going from 600 

to 800 into 1,000 pound weights from 30, to 32, to 34 inch widths and from 40 

and 62 lengths of ramps and also we also have good association with Q-strength 

who is their strength device manufacturers that pretty much dominates the 

market here in the U.S. and they have been partners of ours. So in all of these 

cases, we tend to go through push it to the limit and build a demonstration bus 

and then review that at our dealer's meetings and some other field service work 

before we ever go forward with it. So we are careful to make sure we're not 

pushing limits beyond -- with all of the things we're doing, we think we are doing 

things that are better than the standards, not intruding into the standards. That 

is at least our interpretation. Maybe some of our interpretations are different 

than other people thinks are accurate. But as we interpret them, we're always 

trying to improve upon things versus trying to back off of anything. 
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And so we can provide some of that information. I guess the question is, this 

information is proprietary. I won't supply it to be published for obvious reasons. 

>> And that's fine. Don't send it to us. 

>> We won't be sending it. 

>> That's fine. We respect that. 

>> SCOTT WINDLEY: But whatever you feel you can send us, that 

would be great. 

>> MARSHA MAZZ: Just to make it clear, anything that results from 

the public comment period would be put in the docket. 

>> SCOTT WINDLEY: So only send something that you feel 

comfortable with anybody and their dog looking at it. 

(Laughter) 

>> SCOTT WINDLEY: Cleatus or New Flier -- Kerry? 

>> KERRY LEGG: With regard to new ramp design, we do at our research and 

development department, they put the bus -- or sorry. The ramp itself through 

multicycle testing. Put it through 30,000 cycles and see how it stands up and 

tweak that and try again. Because it not only has to do what they project it to 

do, but it also has to be maintained well and all sorts of things. With regards to 

usage, we have got the demo buses running around and typically if there is an 

ADA advocacy group in that area, then, you know, they'll be invited to come and 
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try it out and that's a good user test for us to tell us whether or not it's better 

than they have had before. 

There's also some very embarrassing footage of me trying to work a wheelchair 

up a ramp. 

(Laughter) 

>> I'm not going to be releasing that either. 

(Laughter) 

>> But, you know, we do play it with a lot, both at our research development and 

customer service if I'm hearing about issues in the field, then I'll go out and test 

it myself as embarrassing as it may be sometimes, but -- yeah. 

>> SCOTT WINDLEY: Cleatus? 

>> Cleatus with Lift-U. As far as user testing, our prototypes, our initial units are 

installed in demo buses and evaluated. But as far as focus groups or something 

of that sort where we have gone out and tried to solicit a variety of different 

types of users to evaluate, no, we haven't done that. 

That's why on this new dual-mode ramp we have specifically started work with 

Lain Transit and Santa Clara to get these prototypes and beta testing before we 

even go to production. 
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>> SCOTT WINDLEY: Great. 

Okay. 

Chris, you want to close us out? 

Is there any other questions that anybody had that didn't get addressed? 

>> CHRISTOPHER HART: I think this was a very worthwhile discussion. 

Certainly looking forward to continue dialogue on October 2nd at 2:00 or 2:30 in 

the afternoon. 2:00 to 5:30 and the room will be down the street. I don't have 

that --

>> SCOTT WINDLEY: We do. 

>> 611 and 612. 

>> SCOTT WINDLEY: Of the Washington Convention Center, right? 

>> Yes. 

>> SCOTT WINDLEY: It's on the 6th floor. 

>> CHRISTOPHER HART: We are asking all the manufacturers that, 

including fare box manufacturers because we really want to continue this 

dialogue and this information-gathering effort to better refine the draft 

guidelines and hopefully finalize them very quickly. 

>> SCOTT WINDLEY: Thanks a lot. We really appreciate you guys 

coming and sharing with us and having an open dialogue. It's always good to do 

that. I appreciate you guy's presentations, all of the information you have given 
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us. Given a lot to think about. So thank you. 

>> For anyone who wants more information about the meeting and a copy of the 

federal register notice, if you haven't actually seen it, if you go to our website 

and look at the top link for vehicle guidelines, there is an article and a link to the 

federal register notice and to the comment web page and on the right-hand side 

there is the information for the meeting in Seattle. 

>> And Melissa, when does the time period close? 

>> The time period closes October 31st. 

Yep. Halloween. 

So don't send us anything scary. 

>> SCOTT WINDLEY: Or all the buses turn into a pumpkin on 

Halloween. 

>> I have got a question. I unfortunately on that date is committed to be on the 

farthest place of the United States probably Key West and I can't make that. Is 

there any way of audioing in on the conversation? 

>> No. There won't be. But the transcript will be posted. 

>> SCOTT WINDLEY: We try. 
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>> When is the information -- taking of the information, is that October 31st? 

>> SCOTT WINDLEY: The comment period is open -- the comments --

the docket is open except the comments until October 31st. Sorry. I was trying 

to get my federal language correct. 

>> And if anyone has specific context at the fare box manufacturers or retail, let 

me know. Otherwise, I'm going to be fishing for them based on what I find on 

the internet. So if somebody has name, that would help me out.