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We look forward to the day when that will not have to be the

case.

To nimmarize and close this statement, CTM believes that

Anactment of the Americans with Disabilities Aot is an important stop. but only a stap, toward our own goal of full accousitility

to nobility regardless of who you asi or wharı you live.

Thank you again for this opportunity to prosant our vions

and I will be happy to try and answer any questions you may

have.

86-878 091-39

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CTM Board Resolution on Accessibility

(Approved September 18, 1989)

The Board of Direotors of the Community Transportation Association of America balloves there is an urgent need to take frosh look at national transportation policies and priorities to dotornino their adequacy in assuring full mobility for all members of our society. As a nation, we should comast ourselves to specific, mousurable and attainabi. goals of reducing Individual and community isolation by the year 2000. It should be the objective of such a 10-year campaign to assure the right of access for all citizens to jobe, neaded education and training, and to mast lito's rost basio naads --- • vithout, record to ploc. of raidanca, age, econonio status or dia.

We therefore support the proposed Amarioans with Disabilities Aot (ADA) to assure full scossibility of public transit services and to provide for Individual mobility needs through the establishment of attordable paratransit sarvions in urban and rural communitiu. However, if anasthant of ADA 18 not accompanied by appropriate financial support, transportation sarvices may be diminished rather than nade nor equitable and adaquata. We therefore recogniso that ther 1e • public responsibility to pay for such acoussible sarvion u outlined in ADA.

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AIRPORT GROUND TRANSPORTATION ASSOCIATION, IN

901 Scenic Drive, Knoxville, Tennessee 37919

Phone (615) 525-1108 / FAX 615-522-9663

September 26, 1989

To:
Re:

House Public Works Comunittee
Americans with Disabilities Act of 1989

OFFICERS
John Shoup

President
Middlebury, Indiana
Rogo Pescarella

Vice President
Formingdale, New Jersey
BOARD OF DIRECTORS

John C McCarthy

Chairman
Chicago, Illinor

John Andrews Allied Representative De Plounge. Minor

Glenn Balonnn
Attenua, Georgia

Richard Griesbach
ASOCIAIO Representative

Washington, DC

Graon Mughes
Lartspur. California

Edward C. Kurytuk
Milford, Connecticut

I would like to share my deep concerns surrounding Sena te Bill 933/H. R. 2273. i am making these remarks on behalf of the Airport Ground Transportation Association. The Airport Ground Transportation Association is a non-profit trade association composed of airport ground transportation providers, the major as well as many smaller airports, and industry suppliers. The one hundred twenty-seven operator members provide a range of services from taxi/sedan service through limo, van, and minibus service to large bus service. These services are provided in all configurations of demand - responsive, fixed route, fixed schedule and mixed combinations. The vast majority of these operations are small businesses, most with fewer than twenty-five vehicles, and many with only four or five vans.

Michel Mannin Ameonato Representative

Orlando. Florida

Witham V Mag Wilmington. Dolawar.

WM Smythe. I Momonis, Tennesse.

Patrick Stran Minecoluga. Oniano. Caneca

As this Bill is presently constructed, it would severely impact our nation's intercity bus carriers: create economic chaos in the van and bustype vehicle markets, displace the present services of many small airport ground transportation providers, and, perhaps worst of all, decrease the i evel of service now provided for the disabled in small urban and rural areas. I ask your assistance in attempting to reach a compromise on this Bill which would increase services to the di sabled, yet maintain the economic survival of these services.

EXECUTIVE DIRECTOR

Ray A Mundy. PhD
Knornite. Tomesco

AGTA Statement on H.R. 2273
Page 2

As has been stated in previous testimony by representatives of the bus industry, equipping a 47 pa s senger bus with a wheelchair lift, widening the aisles, and installing a wheelchair accessible restroom would require a reduction of between 10 and 17 seats and the loss of baggage area. While this may sound absurd, it is what would be necessary to make a standard coach "fully accessible" to individuals in wheelchairs.

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worse yet would be the plight of a small fixed route van operators serving our nation's airports. In order to equip a 9 passenger van with an acceptable lift, two bench seats would have to be removed - 2/3 of the seating capacity. Fold-down seats could be used to replace 2 or 3 of these seats when wheelchairs were not in the vehicle; however, such seats are not passenger acceptable for rides of any significant distance. It is clear and predictible that these van and minibus services, of which there are hundreds across the nation, would simply cease to exist. Operators would turn to the one option left, and that would be to change their services to "demand responsive". I ar. concerned further that fixed-route scheduled service to many of our nation's small urban and rural communities would also cease to exist. Our disabled would therefore be left with no, fewer, alternatives to meet their very special needs.

we should not ask our nation's isolated citizens to pay for the unintended consequences of this bill. Rather, we might attempt to work with the small businessmen and women involved in the transportation industry to augment their present services through government grants for wheelchair-equipped vehicles. We night look also at new alternate solutions, perhaps some requiring no direct government intervention.

It is possible to provide service to our disabled without the ruinous expense and loss of capacity due to cumbersome wheelchair lifts on all fixed route bus and van-type vehicles. One such ir.novative solution can be found in Toronto, Canada. At Pearson International Airport, officials have permitted 5 additional vehicle permits for taxi/limo operators only if these vehicles are wheelchair compatible. The Toronto airport taxi/limo permits are attractive business ventures and operators willingly pay $5,000 or more per year for the privilege of operating at the airport. The 5 new vehicles are Chrysler minivans with adapted floors so wheel chairs can gain easy entry.

AGTA Statement on H.R. 2273
Page 3

These new wheelchair vehicles wait in the taxi/limo line as others, but are called to the head of the line when a wheelchair vehicle is requested. Thus far, this disabled service experiment at Pearson International Airport has been a rousing success. A supply of vehicles is always available to the di sabled at regular prices and the supplying operator earns as much or more than others in the system because the vehicle configuration may also be preferred by people travelling with a great deal of luggage. In addition, the back seat of the minivans are very comfortable, giving the passenger the feeling of riding in a limousine. I use this example to illustrate that there are innovative methods of accommodating the di sabled at our airports. However, requiring wheelchair lift devices on all fixed route vehicles is plainly not economically feasible for anyone.

There are also several technical problems with the Bill as stated, which would probably jeopardize its eventual applicatiore It would appear to me that the Bill could be construed as unconstitutionally va gue and/or discriminitory against fixed route ground transportation services. The language of the Bill refers to "over-the-road" coach, and "demand responsive" services, but there is no clear definition of these terms. There is no definition in the Bill no are there generally acceptec det initions for these terms in the industry. The Bill may be viewed as inherently discriminatory in that it singles out only fixed scheduled ground transportation operators. Many such operators compete with demand responsive services, which use the same type of vehicles, and commuter airlines - both of which are exempt from the provisions of this proposed bill.

Another problem relating to the Bill is its total reliance on current wheelchair lift technology. All such devices are not the same. Prices vary widely and not every kind of wheelchair can be accommodated by every model of lift. Many aspects of wheelchairs and lift devices have not been adequately considered. In fact, current Interstate commerce Commission regulations prohibit the transportation of acid batteries, a component of most electric-powered wheelchairs, in over-the-road vehicles. Further research needs to be conducted on these devices and alternatives to wheelchair lifts, such as ramps.

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