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Memorandum - NHTSA

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VI-4<br />

averaged 35,000 units per year, of which 16 percent are estimated to be small, Type-A school<br />

buses and 84 percent are estimated to be large Type B, C and D school buses. Based on 1993<br />

School Bus Fleet magazine data, it is estimated that between 18 to 20 percent of the Type-A<br />

school buses are lift-equipped or 1,008 - 1,120 [(.16)(.18 to .20)(35,000)] units per year. Fort ie<br />

large, Type-B, C and D buses, it is estimated from the same School Bus Fleet magazine report<br />

that 5 to7.8 percent are lift-equipped or 1,470-2,293 [(.84)(.05 to .078)(35,000)] units per year ’<br />

Therefore, combining the Type A, B, C and D lift-equipped school bus estimates together yielc Is<br />

2,478-3,413 total lift-equipped units per year. The Access Board’s guidelines apply to school<br />

buses implicitly due to the Rehabilitation Act of 1973, which mirrors the ADA. <strong>NHTSA</strong> is not<br />

mandating that school buses be equipped with lifts. But if they are voluntarily equipped with<br />

lifts they must meet FMVSS No. 404 and install an FMVSS No. 403 compliant lift.<br />

Over-the-Road Buses (OTRBs)<br />

The ADA accessibility requirements do apply to OTRBs or what are commonly called intersta1.e<br />

buses or motor coaches. A recent departmental final rule requires that 50 percent of the OTREI;<br />

fleet be accessible by 2006 and 100 percent by 2012.’ It is expected that accessibility would b8:<br />

accomplished by a level change device - primarily WC lifts. <strong>NHTSA</strong>’s FMVSS Nos. 403/404<br />

standards would apply to OTRBs. According to the OST Regulatory Analysis (PRA) September<br />

28, 1998,3,000 units are sold annually of which 400 are exported and 400 are converted to<br />

7 School Bus Fleet, DecembedJanuary 1993 issue, Bobit Research Department, Bobit Publications, 25 1 !<br />

Artesia Blvd., Redondo Beach, CA. 90278-3296.<br />

* Transportation of Individuals with Disabilities; Accessibility of Over-the-Road Buses, Final Rulemaki ig,<br />

Regulatory Analysis (PRA), September, 1998. Also see 63 FR 51670. September 28, 1998, ATBCB 36 CFR Pz rt<br />

1192, 49 CFR Part 38, Americans with Disabilities Act Accessibility Guidelines for Transportation Vehicles, 0v.xthe-Road-Buses;<br />

Joint Final Rule.

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