FCC to establish minimum standards and guidelines. It would assure that any DPR center that is established would provide the highest quality service that technology allows.

As noted earlier, many states have already begun to face up to their responsibilities in this area. In addition to California, New York and Alabama, four states now provide for the funding of statewide DPR centers, which are staffed by private agencies. Altogether, some 15 states have adopted legislation calling for the establishment of such centers. 2 Legislation is pending in eight others.3 Whatever Congress and the federal government can do to help expedite a national DPR system would be most welcome.

By far, the majority of states accept the responsibility for providing DPR centers for their residents. In some cases, legislatures have authorized direct public funding of the DPR service.4 In other cases, the states have assigned the DPR operation to a public agency.5 In all cases, the states have prescribed a funding mechanism, typically a monthly surcharge on non

1Arizona, Minnesota, Oklahoma and Utah.

2Alabama, Arizona, California, Connecticut, Hawaii, Illinois, Louisiana, Maryland, Minnesota, North Carolina, Oklahoma, Oregon, South Dakota, Utah and Washington.

3Colorado, Georgia, Massachusetts, Montana, Nebraska, Tennessee, Texas and Virginia.

4Connecticut and possibly New Mexico.

5The Department of Public Service in the State of Maryland, for example, and the Department of Social Services in South Dakota. In California, Georgia, Illinois and North Carolina, the legislatures have delegated the service responsibility to public agencies which do not appear to be conventional agencies of the respective state governments.

competitive local-exchange lines, as a surrogate for general tax revenues.6

The funding for DPR in Alabama, for example, comes from two sources. First, customers pay a charge based on the tariffed rates for a point-topoint call between the disabled and non-disabled persons. The telephone companies, however, do not keep this charge. Instead, they remit it to the committee which administers the Alabama DPR. Also, each telephone subscriber in the State of Alabama pays 20 cents per month to support the relay center.

In conclusion, let me emphasize once again that AT&T strongly supports the goal of nationwide Dual Party Relay, and will continue to work with the federal government, state governments, other companies in the

telecommunications industry, private groups and associations--particularly those representing people with hearing or speech disabilities--and

individuals at all levels, to accomplish this objective.

AT&T is pleased to have the opportunity to present its views on this important matter.

6Surcharges per local-exchange line per month are imposed in Alabama ($0.20); Arizona ($0.03); Illinois ($0.03); Louisiana ($0.05); Minnesota ($0.10); Oklahoma ($0.05); Oregon ($0.10); South Dakota ($0.10); Utah ($0.10); and Washington ($0.10). Surcharges have been proposed in five states: Colorado ($0.10); Georgia (unspecified); Michigan ($0.10); Montana ($0.10); and Nebraska ($0.10). In many cases, the surcharge covers the cost of distributing TDD equipment as well as the cost of the DPR center. California's charges are indicated earlier in this testimony.

STATEMENT OF GREYHOUND LINES, INC. ON THE

AMERICANS WITH DISABILITIES ACT

The proposed Americans with Disabilities Act (ADA) has the potential

and

to destroy the private sector intercity bus industry and to deprive millions of people of affordable intercity public transportation thousands of rural communities of their only link to the outside world. Greyhound is firmly committed to providing accessibility of its service to the physically disabled and has undertaken a number of programs to accomplish that. However, those programs must be consistent with our ability to maintain a strong nationwide bus system. Passage of the ADA would deprive us of that ability.

The ADA appears to require full handicapped accessibility for all intercity buses purchased more than thirty days after its passage. This would include installation of wheelchair lifts; widening of the aisles; removal of seats; loss of baggage and package express space and redesigning of bus restrooms to accommodate wheelchair users.

At present, Greyhound has a nationwide bus fleet of approximately
In order to provide a cost-effective and attractive bus

4,000 buses.

fleet, it is desirable to replace 10% of the bus fleet, or approximately 400

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buses every year. Thus, the bus installation costs to Greyhound annually could be as high as $20 million (400 buses X $35,000 to $50,000 per bus). Greyhound simply could not afford that additional cost.

We are rebuilding and

The regular route bus industry has been declining for years, and that decline led the prior managements of both Greyhound and Trailways to disinvest from the bus industry. With the merger of Greyhound and Trailways in 1987, that process was reversed. hopefully, revitalizing intercity bus service. For 1989, we have a capital budget of $28 million to buy new buses and build and upgrade terminals. This is an extraordinary commitment for a company that lost $17 million last year; yet, over 70% of our capital budget would have to be spent on wheelchair accommodations if we were to buy the desired 10% replacement fleet. Clearly, the net result of the proposed ADA requirement would be that we would stop buying buses and rebuilding terminals, and the bus revitalization effort would end.

As bad as this cost analysis appears, this is only just the beginning of the problem. To accommodate the wheelchair lifts, we would have to remove at least 4 seats. Assuming full accessibility to the restroom, as many as an additional 12 seats would have to be removed. Thus the passenger carrying capacity of our buses would be diminished by between 10%-35%. This is a critical factor since the bus business is very much of a peak period business, we must have the capacity to handle passengers

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at peak periods.

Loss of even 10% of our capacity would deprive us of

that ability. We would be required to run additional equipment to provide the peak period service at an estimated additional cost of $20 million per

year.

An even more serious problem is the fact that wheelchair lifts presently being manufactured take up 32% of the capacity of the baggage and package express bins under the buses. Intercity bus service, particularly rural bus service, is viable only because we derive incremental revenue from carrying package express in our baggage bins. Last year, Greyhound derived $95 million from package express. Loss of any significant portion of this revenue would jeopardize all of our service, but particularly our rural service. It should also be noted that the loss of 40% of the baggage bin capacity falls disproportionately on package express because by law, baggage must be given priority. Since on many schedules, baggage takes up 50% or more of the present baggage bin space, there would be even less room for package express.

In addition, there is the added maintenance cost. It is difficult to estimate this with precision, but based on transit bus experience as well as other information we have obtained, we conservatively estimate $2,000.00 per bus in additional annual maintenance cost. would be another $8 million.

For us,

this