36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

Comment. Specifications in 810.2 for bus stops applied to "bus stop pads" in the proposed rule. Comments noted that this reference has been misinterpreted as applying to the vehicle space for buses which are sometimes provided with concrete pads, instead of to adjacent boarding areas.

Response. For clarity, the Board has applied requirements to "bus stop boarding and alighting areas" instead of to "bus stop pads."

Comment. Bus stop boarding and alighting areas are required to be at least 96 inches long and 60 inches wide. The proposed rule specified that these dimensions were required to "the maximum extent allowed by legal or site constraints" (1002.2.2). Comments considered this language unclear or unnecessary.

Response. The reference to legal or site constraints was intended to cover existing conditions that would effectively preclude sizing boarding and alighting areas to the minimum dimensions specified, such as narrow sidewalks. The Board has removed this language in section 810.2.2 in favor of a general scoping provision for alterations (202.3) which recognizes instances where compliance is not technically feasible. In such cases, compliance is required to the maximum extent feasible. Section 810.3 addresses bus shelters, which are required to provide wheelchair space. The Board has included clarification that this space be located "entirely within the shelter" so that persons occupying the space can be adequately sheltered from the elements.