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Use of Mobility Devices on Paratransit Vehicles and Buses (2014)

Chapter: Chapter 5 - Key Findings

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Suggested Citation:"Chapter 5 - Key Findings." National Academies of Sciences, Engineering, and Medicine. 2014. Use of Mobility Devices on Paratransit Vehicles and Buses. Washington, DC: The National Academies Press. doi: 10.17226/22325.
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Suggested Citation:"Chapter 5 - Key Findings." National Academies of Sciences, Engineering, and Medicine. 2014. Use of Mobility Devices on Paratransit Vehicles and Buses. Washington, DC: The National Academies Press. doi: 10.17226/22325.
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Suggested Citation:"Chapter 5 - Key Findings." National Academies of Sciences, Engineering, and Medicine. 2014. Use of Mobility Devices on Paratransit Vehicles and Buses. Washington, DC: The National Academies Press. doi: 10.17226/22325.
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Suggested Citation:"Chapter 5 - Key Findings." National Academies of Sciences, Engineering, and Medicine. 2014. Use of Mobility Devices on Paratransit Vehicles and Buses. Washington, DC: The National Academies Press. doi: 10.17226/22325.
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Suggested Citation:"Chapter 5 - Key Findings." National Academies of Sciences, Engineering, and Medicine. 2014. Use of Mobility Devices on Paratransit Vehicles and Buses. Washington, DC: The National Academies Press. doi: 10.17226/22325.
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Suggested Citation:"Chapter 5 - Key Findings." National Academies of Sciences, Engineering, and Medicine. 2014. Use of Mobility Devices on Paratransit Vehicles and Buses. Washington, DC: The National Academies Press. doi: 10.17226/22325.
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Suggested Citation:"Chapter 5 - Key Findings." National Academies of Sciences, Engineering, and Medicine. 2014. Use of Mobility Devices on Paratransit Vehicles and Buses. Washington, DC: The National Academies Press. doi: 10.17226/22325.
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Suggested Citation:"Chapter 5 - Key Findings." National Academies of Sciences, Engineering, and Medicine. 2014. Use of Mobility Devices on Paratransit Vehicles and Buses. Washington, DC: The National Academies Press. doi: 10.17226/22325.
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Suggested Citation:"Chapter 5 - Key Findings." National Academies of Sciences, Engineering, and Medicine. 2014. Use of Mobility Devices on Paratransit Vehicles and Buses. Washington, DC: The National Academies Press. doi: 10.17226/22325.
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24 C H A P T E R 5 Sources A summary of the research findings are presented in this section. The key findings were derived from the following sources: a literature review, national surveys, workshop and contributions from panel members and the transit industry. Literature Summary An extensive review of the U.S., Canadian and international literature was performed. There are a few key findings of interest. The U.S. and Canada permit a greater range of sizes of wheeled mobility devices to travel on paratransit vehicles and buses, than most other countries. The UK, Australia and the European Union do not permit the transport of scooters, and in general these regions are much more restrictive on the transport of oversize mobility aids. In addition, the U.S. is much more prescriptive with regards to mobility aid securement. In the other countries the frame of reference for securement on large transit vehicles is that people in wheeled mobility devices are exposed to the same level of acceleration as stand- ing passengers, and this is reflected in the wide spread use of rear-facing securement and in some countries side-facing securement. Since the diversity of WhMD is much more restrictive, the use of four belt securement on smaller vehicles is wide spread, and is consistent with US practices. In most countries the standard footprint for a transportable mobility aid is approximately 30 inches wide by 48 inches long and the minimum payload for lifts and ramps is 600 pounds. Survey Summary The TCRP Project C-20 Research Team worked with the Oregon State University Survey Research Center to develop the survey instruments for all the diverse stakeholders involved with the project. All of the survey materials were submitted for approval by the OSU Institutional Review Board (IRB) for the Protection of Human Subjects as well as comply with the requirements of NAS/TCRP. The IRB documents were sub- mitted for an “exempt” review, and final IRB approval for the surveys was received on April 30, 2012. The survey instruments were designed to be used in sev- eral survey modes. The survey instruments included cover letters that meet the requirements of TCRP and the OSU IRB. The Surveys of Transit Agencies, Transit Users and Wheeled Mobility Device (WMD) industry were online surveys. The five instruments addressed the items suggested by the project panel as well as other items that the research team had also identi- fied. The audiences for the surveys included (1) transit agen- cies, (2) transit users, (3) transit equipment manufacturers, (4) WhMD industry, and (5) funding agencies. The (1) Survey for the Transit Agencies, and the (2) Survey of Transit Users were reviewed by subject matter experts and as a result a num- ber of modifications were made to these instruments. The three online surveys required OSU IRB approval before they could be programmed for the web. The survey of transit equipment manufacturers (3) was hardcopy and phone sur- vey and most of the surveys were conducted by phone. The Survey for Mobility Device Industry (4) was also an online survey. Online surveys by the OSU Survey Research Center (SRC) were activated on July 9, 2012, and concluded Septem- ber 7, 2012. The survey of funding agencies was the most chal- lenging survey to conduct and was designed to be conducted by telephone. A short interview survey was prepared for this population group. Despite repeated referrals and attempts at recruitment, this population declined to be interviewed. In addition to the formal surveys a number of conversations in a number of different formats were held with stakeholders to identify the issues, problems, and potential solutions related to the transport of persons using mobility devices. As a result of organizing the workshop, a number of additional stake- holders were identified and interviews and conversations were carried out to determine issues that have not been iden- tified to date. Telephone interviews have been conducted with Key Findings

25 a number of transit vehicle and transit equipment manufac- turers. The structured interviews were concluded when it was determined by the research team that no new information was being gained. The complete Survey Report is available on the project website. Key Findings from the Surveys There were a number of common themes in the responses from the diverse stakeholder groups. It was consistent from all surveys, that oversize wheeled mobility aids are challenging for transit operators, passengers and many users. Many respon- dents noted the challenge of securing WhMDs particularly those with “shrouds.” Some surprising comments were received from transit oper- ators and the transit industry. Both entities requested more regulations pertaining to transportable WhMDs that have built-in and easily identifiable securement system attachment points. There was also a comment about the need to develop specifications for the minimum structural strength for vehicles transporting WhMDs. Interviews were conducted of transit operators in certain markets. One operator reported that since they switched to new belt securement system on their paratransit vehicles they had not had any operator injuries. The comments in the transit user survey that pertain to roadways and intersections were unsolicited. The number of comments on accidents that occurred off the transit vehicle and in the roadway was un expected. The key outcomes from each stakeholder group are summarized in Table 12. The Transit equipment industry also had a number of recommendations, and these are shown in Table 13. Detailed summary of all the surveys are in the survey report. The survey report provides a full description of all Transit operators Desire for strong regulations that mandate the following: Training and refresher programs for all operators on the safe use of equipment; e.g., lifts, ramps, securement systems Wheeled Mobility Devices: maximum length, width, weight and turning radius of transportable wheeled mobility devices attachment points for securement systems located at structural safe points this includes scooters Transit Users Require DME dealers to indicate which mobility devices are transportable on public transport vehicles Revise funding models and insurance payment policies for mobility devices to include securement attachment points or WC-19 compliant devices Encourage transit agencies to communicate with local DME dealers about mobility device size limitations Mobility Device Manufacturers Require public transport vehicles to be structurally strong to support securement systems and the weight of mobility devices Require more coordination between securement systems standards development group and domestic mobility device manufacturing industry Require mobility aids to have securement attachment areas Require WC 19 standards to be mandatory Require funding agencies to mandate securement system attachment areas Table 12. Key findings from surveys by stakeholder groups. Transit equipment industry Require regulations to control the size, weight and turning radius of mobility devices Size of transit vehicle is restricted - loss of seating capacity, if increase width of seat or space for mobility devices Lift and ramp manufacturers Many lifts and ramps are already designed for higher 800 pound loads Many new lifts and ramp platforms are now designed for longer mobility devices, however WhMD cannot board vehicle due to tight turning radius at front of bus and restricted interior maneuverability Seating manufacturers Seats are designed for 450-pound vertical load Wider seats may reduce seating capacity of vehicle Securement manufacturers Forward facing in bus and paratransit in U.S. In favor of developing improved standards and safety that are based on engineering research Fare payment suppliers Move towards smart fare payment systems Redesign mounting hardware to make sure fare box does not encroach into vestibule area Table 13. Transit equipment industry survey summary responses.

26 the methodology, surveys and results. Table 14 summarizes the key findings from the surveys. Workshop Findings Summary A report that summarizes the results of the workshop that was held on June 26, 2012 and includes materials submitted by some of the workshop participants is available on the proj- ect website. A short summary of the key findings is outlined below. Workshop Objectives: • Demonstrate the impacts of changes in population demo- graphics and wheeled mobility devices technologies and the impact on the transportability of WhMD • Identify technical, operational and regulatory issues associ- ated with the transport of wheeled mobility devices on-board paratransit vehicles and urban buses • Convene an opportunity for key stakeholders from the tran- sit vehicle, WMD, and securement industry, to meet with transit operators and regulators to discuss the transport of WMD on paratransit vehicles and larger buses. • Synthesize and evaluate the workshop discussions, and prepare a workshop report. The workshop was organized into four modules to facili- tate full participation and discussion. Module 1 Framing the Conversation The significant issues were introduced, and the framework of the discussion was presented Module 2 Technical Issues The technical issues were categorized according to manu- facturers’ perspectives and included: wheeled mobility devices, bus and paratransit vehicle, lift/ramp, securement, fare pay- ment and transit seat. Module 3 Operational Issues The operational issues were introduced from the perspec- tives of transit operators, transportation consultants, regulators and trade association. A discussion of regulatory issues was also included in this module. Module 4 Balanced and Sustainable Solutions This module was a facilitated discussion that identified key areas of change to improve the accommodation of wheeled mobility devices on paratransit vehicles and buses. Suggested changes would impact all the stakeholders. In addition there was a discussion on short term and long term changes and implementation strategies. Technologies Mobility Device Industry The WhMD industry is comprised of manufacturers, suppliers, dealers and importers. The range of products include Tr an si t O pe ra to rs Tr an si t U se rs Tr an si t Eq ui pm en t M an uf ac tu re r W hM D M an uf ac tu re rs Regulaons that mandate max size of WhMD X X Regulaons that mandate securement system aachment points X X Require regular & refresher training for drivers X Provide Space for service animals X X Require DME dealers to indicate WhMD that are transportable on public transit X Revise WhMD funding to include securement aachment ( WC 19) X X Encourage transit agencies to work with local DME Dealers on size limitaon of transportable WhMD X Require more coordinaon between DME industry and securement standards groups X Develop securement standards that are based on engineering X Table 14. Findings from survey.

27 manual and sport chairs, power chairs, bariatric chairs, 3- and 4-wheel scooters, and wheeled walkers. These devices are designed to meet the diverse needs of people with mobility impairments who require assistive technology. The diversity of WhMD has caused challenges for the transport industry. Most manufacturers/suppliers are not aware of the limita- tion for a transportable mobility device, and therefore can- not inform the purchaser of the device accordingly. First time purchasers of scooters are often not familiar with the operation of such a device and require some training. Since these devices are often purchased through the Internet there are no provisions for appropriate sizing or training. Scooter users are especially not accustomed to boarding a bus, and maneuvering in and out of the securement position. The size and lack or maneuvering capabilities of the scooter user make them very difficult to use on a bus. Some suppliers/ dealers provide a basic training but others do not. Scooters in particular require attention because of their size, weight and turning radius. Table 15 is a summary of the transport- ability of WhMD onboard low floor fixed-route buses and paratransit vehicles. Transit Vehicle Large vehicles are considered those that have a GVW of 30,000 pounds and more. They include urban transit buses ranging in length from 35–60 feet, and extra-long articulated vehicles that are over 60 feet long and often used in BRT ser- vice. These vehicles can be standard urban buses, low floor or high floor, single axle, double axle, articulated, double Pe rs on w ith eq ui pm en t Tr an sp or ta bl e on fix ed ro ut e lo w flo or bu s/ BR T Y/ N Re qu ire sW C 19 Y/ N Tr an sp or ta bl e on pa ra tr an si tv eh ic le Y/ N Re qu ire sW C 19 Y/ N Co m m en ts Manual and sports chairs Yes Yes Yes Yes Power chairs Yes Yes Yes Yes Bariatric power chairs No NA Yes Yes 3 wheel scooters Yes Yes Yes Yes 4 wheel scooters 30” x 48 “ Yes Yes Yes Yes If turning radius does not exceed 36” 4 wheel scooters 30” x 49” – 54” No NA Yes Yes Wheeled walker Yes NA Yes NA Crutches and canes Yes NA Yes NA Persons who are blind/vision impaired Yes NA Yes NA Require a space for service animal Persons who are deaf/hard of hearing Yes NA Yes NA Require visual mode for informaon Person using Segway Yes* NA Yes* NA *If operator policy allows Person using stroller Yes* NA Yes NA *Only if envelope does not exceed 30” x 48” and a turning radius of 36” Person who is obese Yes NA Yes NA May require wider seat Table 15. Summary of WhMD transportability on-board fixed route low floor buses and paratransit vehicles.

28 decker, or as BRTs with several cars. Users of fixed-route transit are those who are able to enter, exit and maneuver their mobility device on their own. Most commonly used large urban vehicles for fixed-route operations are now low floor. The low floor section is acces- sible for mobility devices either via the front door or the cen- ter door. Most operators use a flip ramp at the front door for access with a slope of 1:4 from vehicle floor level to the road. Some operators use a bi-fold ramp which allows for a 1:6 slope. Ramp loads are presently limited to 600 pounds for an occupied mobility device. Today’s demands can exceed this limit with the growing weight of both mobility devices and occupants. Entry through the front door has its physical restrictions due to the space for a fare box which limits the turning radius for a mobility device to 36 inches. Front door ramp operations are under the direct visual control of the driver, as is fare payment. The width of the aisle through the wheel wells is limited to 36 inches. Front door access may also have an impact on seating types and capacities since the area around the securement systems require a large maneuvering space for mobility devices to get in and out, thus 2 + 1 seating or bench seats on one side are usually applied. Entry via the center/rear door allows for a greater turning radius and more maneuvering space. The operation of the ramp located at cen- ter or rear doors is controlled by the driver via interior/exterior mirrors or video cameras. There are trade-offs between the two access door systems. Front access is under the drivers’ direct control, but access is limited by the size of mobility devices and longer paths and maneuvering space to get to the securement position; center door access allows for larger mobility devices, larger maneuvering space and shorter distance to the secure- ment position, but direct visual control by the driver is more difficult. It is required that at least one of the securement systems in large fixed-route vehicles must be forward facing with both an occupant restraint and mobility device securement system as required by ADA regulations. Forward facing securement systems often require the driver to deploy the systems which increases dwell time. Research has shown that 3 g protection is safe to transport persons in mobility devices on large tran- sit buses such as those with a GVW over 30,000 lbs. Several countries in Europe, Asia, Australia and Canada use rear- facing systems. Rear-facing systems in the U.S. are permitted as long as a forward facing system is provided at the same time. Rear-facing does not require driver involvement and reduces dwell times significantly. It is also preferred by users of mobil- ity devices since rear-facing securement provides more inde- pendence and dignity. Cash fare boxes are the most common fare payment sys- tem in fixed-route operations. However, the position and size of the fare box mounting hardware can limit the vestibules’ maneuverability space. They can also present a barrier to persons with agility and cognitive problems. Many transit agencies are opting now for touch or touchless smart card systems which are easier and more convenient to use, and also reduce the space for a fare box, thus permitting a larger turning radius in the vestibule and longer mobility devices to access the vehicle. Small Vehicles Small vehicles are those with a GVW under 30,000 lbs. They range in length up to 28 feet and are mostly high floor, although low floor vehicles are becoming increasingly popu- lar. Users of paratransit services are typically those who are unable to use fixed-route transit. Small vehicles less than 22 feet are required to provide one securement location and devices, and the securement may be forward or rear-facing; all vehicles over 22 feet are required to provide at least two securement locations and devices and at least one must be forward facing. Most paratransit operators are still using high floor vehicles that are equipped with lifts, which can be located at the rear of the vehicle, at the side behind the rear axle, or at the side in front. Their typical payload is 600 pounds, but some lift manufacturers now supply lifts with a payload capacity of 800 pounds, and more due to the increase in combined weights of mobility devices and occupants. Lon- ger lift platforms, originally measuring 30 inches wide by 48 inches long, are also now available for the same reasons. Lifts are operated by the driver/operator and are stored inside the vehicle when not in use. In paratransit operations these are the only vehicles that can accommodate some mobility devices which exceed the typical 30 inches × 48 inches foot print and a larger turning radius. The interior lay-out of these vehicles varies according to the demand of local operations for the number of seats and securement positions. The posi- tioning of seats and securement locations allows for greater flexibility and larger maneuvering space to move mobil- ity devices in and out of their positions. Unfortunately in many cases occupants in wheelchairs are positioned behind the rear axle, where the suspension provides higher verti- cal acceleration forces resulting in dis comfort and injuries to the occupant. Due to the smaller mass of these vehicles, a belt type securement system is required to protect in a 20 g environment. In most cases the driver/operator maneuvers the mobil- ity devices in and out of their securement positions, and must deploy the securement and occupant restraint, which can result in injuries to the operator and undignified close physical contact with the occupant. Some persons are able to transfer from their mobility device to a seat, and this is strongly recommended for all scooter users. Most seats are

29 upholstered, have a headrest and pivoting armrest to facilitate transfers, as well as a three point belt system for protection. One safety issue has been identified for operations which are the boarding and alighting with lifts and ramps on road- ways with high cross sections (cambers) or side slopes and this increases the risk of incidents. Low floor small vehicle use is increasing due to the recent availability of such vehicle types and the demand for safer and more convenient operations. These vehicles are accessed via the front door with a ramp, which requires less involve- ment from the operator and provides a more dignified access for all passengers. The ramp also reduces many of the risks encountered on high lift platforms. Some manufacturers are providing an angled ramp design which allows for longer mobility devices to enter the vehicle. Forward facing secure- ment systems are used and their locations are at the front behind the driver station, with a short distance from the entrance to reduce maneuvering space. Positioning behind the rear axle should be avoided. It should be noted that there are some operating environments where a high floor vehicle equipped with a lift is to be preferred. Other Transit Equipment Lifts Transit operators use lifts for high floor vehicles to pro- vide access from the road level to the vehicle floor level for persons who cannot negotiate steps/stairs. Lifts require a significant space when stored, either inside a vehicle above the floor or under floor. Capital and maintenance cost for lifts are high. Currently, payloads and platform sizes can- not always accommodate heavier or longer mobility devices and heavier occupants. Some manufacturers provide lon- ger platforms and lifts for payloads of 800 pounds. Under the U.S. Department of Transportation (DOT) Americans with Disabilities Act (ADA) regulations at 49 C.F.R. Section 38.23(b) (1), wheelchair lifts must accommodate a design load of at least 600 lbs., with a safety factor of at least six (3,600 lbs.) for working parts, such as belts, pulleys, and shafts that can be expected to wear, and a safety factor of at least three (1,800 lbs.) for nonworking parts, based on the ultimate strength of the material. For vehicles equipped with ramps, the design load must be at least 600 lbs. for ramps in excess of 30 inches in length, with a safety factor of at least three (1,800 lbs.). There is nothing in the regula- tions preventing the procurement of lifts that accommodate larger and heavier mobility aids. When the vehicle is parked on a road with either a vertical slope or a cross slope there is a danger for both lifts and ramps because of their may not be full contact between the end of the lift or ramp at the interface between the lift and ramp and the sidewalk. There are only a very few locations where a high floor vehicle would be preferred over a low floor vehicle and this would include vehicles that cover very long trip lengths such as over the road buses. Ramps Ramps are used for low floor vehicles, usually positioned at the front or center doors. They are typically hydraulic or electric powered flip ramps operated by the driver from his/ her driving position. When not in use the ramps are folded flush with the vehicle’s floor. Ramps should be hinged at the edge with the bus floor and folding out onto the sidewalk/ road. Transit operators typically require the ramps to be cycled every day before the vehicles start operation. Single flip ramps with a length up to 48 inches may exceed a slope of 1:4 when deployed to the road, which can make access for some mobility devices difficult. There are new bi-fold ramps with longer lengths and slopes of 1:6 on the market. Often the vehicle is knelt to achieve a 1:6 ramp slope. Unimproved stops that do not have a sidewalk or curb are challenging for ramp operations. The driver from his driving position can visually control the operation of the ramp at the front door location; ramps at the center door require visual control by mirrors or video cameras. Seats There are a variety of seat types used on fixed-route vehicles. The type of seat is a function of the operating environment, the culture of the transit agency and the type of operations. This is reflected in the combination of seated and standing passengers, and the number of positions for wheelchairs. Commuter operations for longer distances typically require more seats, short distance urban operations allow for more standees. Although seats are designed for a vertical load of 450 pounds heavier persons exceeding this weight may need stronger and wider seats. Single, double and bench fixed seats can be in combina- tions of 2 + 2 and 2+ 1, or side facing. Flip seats are used in the positions for wheelchairs. Sometimes the flip seats in the wheelchair location are also designated as Priority Seats for elderly, pregnant women or other persons with disabilities. This should be avoided since it can lead to conflicts when these seats are occupied and a person in a wheelchair is board- ing. A bench seat does not reduce the number of seats if not occupied by a person requiring a wider space. Seat lay-outs are typically determined by local transit agencies, for exam- ple, for longer distance service more seats are provided with few or no standees, on shorter routes fewer seats are required and more standees are allowed.

30 Fare Payment Most fare payment systems are still on-vehicle, using a cash fare box. One of the most rapidly evolving technological areas in public transportation is new fare payment systems. Both large and small U.S. public transit agencies are currently plan- ning or implementing open (standards) payment systems, in which contactless credit/debit cards or near-field communi- cations (NFC)-enabled devices are accepted directly at fare gates in rail stations and at fare boxes on buses. The Chicago Transit Authority (CTA) launched an open payments system in late 2013, and the Southeastern Pennsylvania Transporta- tion Authority (SEPTA) will roll-out open payments in 2014. Similarly, other transit providers are pursuing fare collection systems in which riders pay using smartphone applications. Portland’s TriMet recently launched a pilot program for smartphone payments, and Dallas Area Rapid Transit (DART) plans to provide mobile ticketing options. Transit agencies in North America are planning and implementing new fare payment systems at an extraordinary pace. While new fare payment systems have the potential to deliver many benefits to transit agencies and transit riders—including reduced costs to collect fares and increased customer convenience— one key issue that must be addressed is how to meet the needs of riders who do not have or do not want to use open standards-based fare media. In many transit agencies, the fare boxes are positioned at the front vestibule of a bus, where they impact the maneuverability/turning radius of a mobil- ity device in the vestibule. In cases where the fare box is still required, the researchers propose that the box be cantilevered, or mounted above the floor and thus providing more space for maneuvering. Operations The discussions at the workshop and the voluntary com- ments as part of the surveys indicated that the physical infra- structure and operating environment can create barriers and challenges for people who use WhMDs. It was noted that the dwell time is significantly impacted by lift and ramp deploy- ment and that roadways with large cross slopes or cambers create significant challenges for the safe deployment of ramps. Bus Rapid Transit with level boarding by a bridge plate at a center door had the lowest dwell time. Other comments were received on the need to insure safe and sufficient space for service animals. At the workshop, fare boxes were mentioned as a common impediment during the boarding process, and that off vehicle fare payment or smaller fare collection devices would also help to promote shorter dwell times. A common theme from both transit operators and passen- gers was the need for more recurrent training on sensitivity awareness for operators. Technical The fixed-route transit industry has moved almost exclu- sively to low floor buses. Low floor buses are easier for all passengers. Recently, several models of low floor paratransit vehicles are being procured. It is anticipated that over time more and more models of low floor paratransit vehicles will become available. In the meantime, high floor paratransit vehicles are being procured with lifts that have longer plat- forms and heavier payload ratings. This is to accommodate the increased length and weight of wheeled mobility devices. Transit agencies, transit operators, transit industry and people who use WhMDs indicated that there should be stan- dards that define a transportable mobility device. Almost universally there was a desire for securement attachment areas or devices to be made available for all mobility devices. In addition there was recognition that the ADA “footprint” of 30 inches wide by 48 inches long did not satisfy the current WhMD market, thus there was a desire to redefine a footprint for a WhMD and also include a measure of maneuverability. During the literature review and workshop activities, the change in ramp slope from 1:4 to 1:6 was identified as having unintended consequences. The operations staff at several transit agencies, worked directly with vehicle manufacturers and ramp manufacturers to solve most of the challenges that the new slope and designs had created, and this resulted in new models of ramps that meet the new 1:6 requirement. Regulations There are three main topics that pertain to regulations and standards: (1) the recent changes in the definition of a wheeled mobility device, (2) the use of voluntary standards, (3) and the changes in reimbursement for durable medical equipment. Recent Changes in WhMD Definition There has been modification in the definition of a wheel- chair. Both the Departments of Justice and Transportation have made modifications. The term “common wheelchair” has been removed. This concept was originally developed to provide a set of parameters for designers and manufactur- ers to use in the process of designing and building accessible vehicles and equipment. The original DOT ADA regulation created an operational use of this design concept, saying that transportation operators were required to transport “com- mon wheelchairs.” Over time, transit operators began to apply this concept to exclude wheelchairs that did not fit into the common wheelchair weight and dimension “envelope”

31 regardless of whether their vehicles and equipment could accommodate them. The definition of a wheelchair is modi- fied to include “three or more wheeled devices;” this is in recognition that some powered wheelchairs have more than four wheels. Transit operators and part of the transit industry have expressed a desire to have a new definition of wheeled mobility devices that will establish new parameters with respect to size, weight and maneuverability. Under the new definition, transit agencies that have vehicles that can accommodate larger mobility devices that exceed the defini- tion of the common wheelchair are required to transport those passenger if the vehicle and lift/ramp can physically accommodate them, unless doing so is inconsistent with legit- imate safety requirements. There is recognition that the pre- vious footprint of a “common” wheelchair does not reflect the current market. Changes of Standards/Regulations The survey results and the input received at the workshop also indicated a desire by some of the stakeholders for the establishment of mandatory rather than voluntary standards for wheeled mobility devices. In particular the current ANSI/ RESNA and corresponding ISO standards are voluntary. The standards of interest are: ANSI/RESNA Standards WC18/ ISO 10520 (SAE J2249); and WC19/ISO 7176-19 WC19/ ISO 16840-4. There are a few wheelchair manufacturers who manufacture their products to meet these standards, but there are many WhMD that are distributed in the US that do not meet any of the voluntary standards. Reimbursement for Wheeled Mobility Devices In the past 5 years there have been changes in the rules for Medicaid reimbursement by the Centers for Medicare and Medicaid Services (CMS), which has resulted in making it much more difficult to prescribe wheeled mobility devices that are designed to be used out of doors. In addition, it is very difficult to get reimbursement for wheeled mobil- ity devices that are “transit safe” or WC-19 compliant. This raises a dilemma for many people with disabilities and their families. Assistive technology and accessible transporta- tion facilitate independent living, access to education, and employment on the one hand, and yet the reimbursement policies for wheeled mobility devices confine people to an indoor environment. Summary of Phase 1 Findings Table 16 summarizes the findings of the project in terms of topical themes, sources and impacts. Table 16. Summary of project findings. Source Theme L ite ra tu re Re vi ew Su rv ey W or ks ho p Te ch ni ca l Im pa ct s O pe ra o n Im pa ct Re gu la to ry Im pa ct Wheeled Mobility Devices(WhMD) X X X 1. Standards/Regulaons a) Weight establish maximum weight of occupied WhMD X X X Y Y Y b) Length establish maximum length of WhMD to be accepted for transport X X X Y Y Y c) Turning Radius establish standard turning for vehicle access X X Y Y Y d) Securement systems require securement system aachment points of all WhMD. X X Y Y Y e) Scooters mandatory for scooters to have securement system aachment points if they are transported X X Y Y Y f) CMS and Insurance require reimbursement for WC 19 or equivalent securement system aachment points on WhMD X Y Y (continued on next page)

32 Source Theme L ite ra tu re Re vi ew Su rv ey W or ks ho p Te ch ni ca l Im pa ct s O pe ra o n Im pa ct Re gu la to ry Im pa ct Large Transit Vehicles Access doors consider use of center door boarding for WhMD reduce dwell me X Y Y WhMD orientaon consider use of side facing for large transit vehicles X Y Y Ramps flat level area inside vehicle, ramp start at threshold X X Y Y Y Lis /ramps minimum payload 800 pounds X X X Y Y Y Plaorm lis increase minimum length to 54 inches X X X Y Y Y Ramp slope 1:4 or 1:6 X X Y Y Y Seats for obese passengers X Y Fare payment X X X Y Y Small Transit Vehicles WhMD locaon place WhMD securement between front and rear axle X X Y Y DME Dealers Transportable WhMD X X X Y Y Y Revise funding/reimbursement model X X Y Transit Operators Training X X Y Y Risk management X Y Funding Agencies X X Y Y X: Source Y: Impact Table 16. (Continued).

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 Use of Mobility Devices on Paratransit Vehicles and Buses
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TRB’s Transit Cooperative Research Program (TCRP) Report 171: Use of Mobility Devices on Paratransit Vehicles and Buses describes the current and emerging issues which limit the use of mobility devices in paratransit vehicles and buses, and includes a guidance document to assist transit systems, manufacturers, and transit users in the implementation of potential accessible design and accommodation solutions for the short and long term.

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