ADAPT of Texas

To: Office of the Secretary, Department of Transportation via fax: 202–493–2251 From: David Wittie, ADAPT of Texas, Fax 512-442-0522 Phone 512-442-0252 Re: Comments on Docket number OST–2006–23985 On an almost daily basis, I and many of my fellow ADAPT of Texas members who are also fulltime wheelchair users continue to experience discriminatory treatment by transportation providers that receive public funds. On publicly funded BUSES: • Drivers and other personnel should not only be trained to, but also tested on, proficiency with regard to assisting with boarding and deboarding persons who use wheelchairs. Too many times we have heard the excuse that the access equipment does not work when it is actually “operator error” causing the problem. This has resulted in our people being left behind to wait for another bus while non-disabled passengers are allowed to travel. • A clear policy regarding priority boarding of passengers with disabilities should be established. Many times, especially during peak hours, bus ridership approaches capacity loads. But when persons with wheelchairs (or other disabilities) are left to board to board last, there is often no room left according to the driver. But when passengers with disabilities are allowed to board first, any remaining passengers seem to have no problem squeezing in to fill remaining space. • Public buses should ALWAYS be required to reposition for boarding and deboarding passengers with disabilities at inaccessible bus stops until ALL public bus stops are made accessible. • No more new bus stops should be placed or built that are inaccessible. Even though this is already a legal requirement, it is still not a common practice. Entities that continue to build inaccessible bus stops should be penalized. On publicly funded TRAINS: • Railroad tracks that intersect or cross over roadways and/or sidewalks should always provide for an accessible route for persons using wheelchairs. • All train platforms should be made accessible to persons who use wheelchairs. Too many times, we have been asked by AMTRAK to ride to the next station because of no access. • Until all platforms are accessible, bridge plates, lifts or other assistive devices should ALWAYS be readily available (ie. NEVER locked away, in storage, etc.) to any train personnel to provide assistance in boarding and deboarding passengers using wheelchairs. • Train conductors and other personnel should not only be trained to, but also tested on, proficiency with regard to assisting with boarding and deboarding persons who use wheelchairs. And finally, even though not specifically on this docket, Greyhound and other over-the-road bus service providers should not be allowed any extension beyond the current deadlines (2012 for Greyhound) for the requirement to have wheelchair lifts on their entire fleet and to have a minimum of two wheelchair securement areas (that actually function as such) for passengers who use wheelchairs. Again, training to proficiency with mandatory testing should be a minimum standard.