36 CFR Part 1192 Americans with Disabilities Act (ADA) Accessibility Guidelines for Transportation Vehicles (2016 Non-Rail Vehicle Guidelines) - Preamble

T304 Operable Parts

The technical requirements for operable parts in the 2016 Non-Rail Vehicle Guidelines remain the same as in the proposed rule; however, they have been slightly reorganized so that all requirements are consolidated into a single section, T304. The technical requirements for operable parts include provisions on height, location, and operation. Operable parts on fare collection devices serving passenger access routes, stop request systems, wheelchair spaces, and priority seats must comply with these technical requirements.

In the 2010 NPRM, the Access Board proposed to raise the minimum height of operable parts in non-rail vehicles from 15 inches to 24 inches. See 2010 NPRM, Section T805.2. A commenter to the 2008 Draft Revised Vehicle Guidelines noted that some operable parts—such as those on stop request devices—are small and difficult to reach for some transit users. To address the problem, the commenter suggested raising the specified minimum height for operable parts. No commenters objected to the revised minimum height (24 inches) for operable parts in the proposed rule. A transit agency did note that, based on a survey of its existing bus fleet, all operable parts on its buses were already mounted higher than 24 inches. Accordingly, the Access Board believes that compliance with this revised minimum height for operable parts—which has been retained in the final rule (see T304.2)—is unlikely to cause transit agencies to incur new costs or significantly alter existing practices.