standards, or something similar, would be applied to any hotel being built?

Mr. CANNON. That's correct. You also need to understand that in reality the vast majority of facilities in this country are already covered by state and local regulations and laws most of which incorporate the American National Standards Insitutute standard which is almost identical to the Federal standard which we enforce for Federally-financed buildings.

In reality, for the broad majority of cases, there would be no new requirements under the ADA. Those local buildings and hotels and whatever still have to conform to the local laws. In fact, California is one of those states that has a building code which is more stringent than the Federal standard. So California is already subject to, in terms of its building requirements, a law that is being applied with little or no problems throughout the state of California and a few others that actually require more, in terms of access, than does the federal standard.

Mr. MINETA. In later testimony, it will be suggested that the federal government develop design standards for wheel chairs which are compatible with workable safety restraints and which will work on transit vehicles and in transit facilities.

In view of the Access Board's research in the area of wheel chair securement, what is your reaction to this suggestion. Is such a standard for wheel chairs needed?

Mr. CANNON. First of all, there is already a process underway to develop some standards-in fact, international standards-through an organization called RESNA which I have been a part of in developing those standards. Those standards would refer to such things as the structural integrity of the wheel chair, how strong it is and so forth, so that if you grabbed onto it with a securement device, you would some reason to believe that it would, in fact, be held in place.

The match up of securement in wheel chair is a complicated issue. What is complicated is that while you can set certain standards about the structural integrity, structural tie points, and so forth, on the wheel chair, you can't, necessarily, define a standard wheel chair. All the wheel chairs are designed, like a set of clothing, to meet the individual needs of the individual.

So there isn't any such thing, really, as a "standard wheel chair" except that you can define certain points on the frame, for example, that would have structural integrity where a clamp of a particular design could grab onto. We think those things are very necessary, and we are working on them.

My understanding of the ADA-and, perhaps, a lawyer could better answer it-is that it does not cover that to the extent that we would be given any authority to write those kinds of standards. But, as I say, we have been working on the issue and we are more than happy to cooperate and work with the designers of chairs.

We also know that there are at least two transit systems that have designed their own securement system which, in their own words, "We can secure anything that has come along so far," including the three-wheel devices which are the largest expanding market, and many of the power chairs including the one that I am using.

So those systems do exist in the sense that they can be specified for purchase or the transit agency can modify existing systems. It is true that you can't go out to the wheel-chair securement store and buy one off the shelf yet. I expect that will change.

Mr. MINETA. In your statement, Mr. Roffee, you mentioned wheel-chair lifts for over-the-road coaches which cost between $7,000 and $10,000, which displace no luggage space and take two seats in contrast to more seats-I believe four seats-and taking luggage space and costing something like up to $35,000.

Using what you have described to achieve accessibility on overthe-road coaches would significantly lessen the financial burden on the inter-city bus industry of eventual compliance with the ADA bill after six or seven years. Could you provide the Subcommittee with additional information about this lift? For example, is it being used by any transportation provider in the United States, and do you know what their experience has been thus far with the lift as far as its reliability and cost to maintain?

Mr. CANNON. Currently, the one you are referring to is, really, the one being used in Denver and has been mentioned earlier. There is limited experience with that device which is why we support the provision of the study done by the Office of Technology Assessment to really determine what that device is.

I have seen the device. It was here in Washington in 1984, a prototype of it, at the Convention Center at the APTA show. It is very similar to the kinds of lifts that are used on private vehicles in that it is extremely simple. It is much simpler than the complicated so-called passive lifts used on urban buses, so it ought to be easy to maintain.

My lift on my van, which I just recently had to replace, I bought back in 1976. It was No. 19 on the production line. Except for some modifications and maintenance and one motor replaced, it has been extremely serviceable. Those kinds of things are very easy to maintain and relatively inexpensive.

Because this lift, essentially, operates on the outside of the vehicle, it does not take up a luggage bay and, therefore, it does not restrict the carrying of baggage express or package express on which, I believe, Greyhound depends a great deal for their income. Mr. MINETA. Are you going to be monitoring the experience there in Denver with regard to this Hubmatic lift?

Mr. CANNON. We are attempting to collect as much information as we can. According to the Senate version of the ADA, we would be involved, we would expect, with the study that the Office of Technology Assessment would do, and intend to keep a close watch on that.

Mr. MINETA. So you will be incorporating something of that Denver experience, so to speak, in your OTA report as provided under the ADA.

Mr. CANNON. That is correct.

Mr. MINETA. Very well. Mr. Shuster?

Mr. SHUSTER. Thank you, Mr. Chairman.

With regard to the Hubmatic lift, staff tells me that it is a prototype only, and they were installed on buses which were not typical over-the-road coaches, and that the cost of the lift, itself, was ac

companied with an additional $11,000 charge to make the bus compatible with the lift.

Is that a fair characterization of the situation as you understand it?

Mr. CANNON. My understanding is part of that additional cost had to do with a change order which would not, necessarily, incur on an initial purchase from another manufacturer, a new manufacturer, today. That is one of the uncertainties, however, that we hope to study. It is very difficult to nail down what is the real cost of that device versus what was caused by the change order which always adds additional costs that are not really attributable to the equipment.

Mr. SHUSTER. Thank you very much. Thank you, Mr. Chairman. Mr. MINETA. Mr. Roffee, Mr. Cannon and Mr. Raggio, thank you very much for being here. I look forward to our working together as we go down this path. Again, thank you very much.

[Mr. Roffee's prepared statement follows:]

Mr. Chairman, I am pleased to be here today on behalf of the

Architectural and Transportation Barriers Compliance Board to testify on the Americans With Disabilities Act. The Architectural and Transportation Barriers Compliance Board, or the Access Board as we are more commonly known, was established by Congress 16 years ago to ensure that buildings which are designed, constructed, altered or leased with Federal funds are readily accessible to, and usable by, persons with disabilities.

The Access Board has been responsible for developing and refining, through active research programs, the Minimum Guidelines and Requirements for Accessible Design (MGRAD). These guidelines represent the state-of-the-art in creating an environment usable by all people and serve as the model for the Uniform Federal Accessibility Standards (UFAS). Those standards are used to implement the Architectural Barriers Act of 1968 and are referenced in regulations used to implement Section 504 of the Rehabilitation Act of 1973 which apply to post offices, Government buildings, and Federally financed housing and transit facilities across the country.

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The Access Board has studied the many and various architectural,

transportation, communication, and attitudinal barriers which limit the full participation of disabled citizens in our society and has published a series of technical papers and staff reports on eliminating these barriers. For example, Lifts and Wheelchair Securement provides guidance on providing access to buses and paratransit vehicles. Aircraft Stowage Procedures and Battery Powered Wheelchairs explains how to stow power wheelchairs on aircraft in accord with hazardous materials regulations. Transit Facility Design for Persons with Visual Impairments gives guidance to transit facility designers and operators on making transit systems usably by persons with visual impairments. Through these and other activities, the Access Board has become a national resource and center of expertise on accessibility for persons with disabilities.

The Access Board, along with the President and the rest of the Administration, wholeheartedly support the broad goals of the Americans With Disabilities Act. This legislation would extend basic, civil rights guarantees to

over 36 million Americans with disabilities and eliminate discriminatory

barriers in public accommodations, places of employment, public