Memorandum - NHTSA

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VIII-3 manufacturers offer optional lift equipment and, in some cases, lifts are standard equipment. Similarly, for personal MPVshans, trucks, truck tractors and motor homes, <strong>NHTSA</strong> is not mandating or requiring lift equipment. However, if these vehicles are lift-equipped they must meet FMVSS No. 403. The SBA defines New and Used Car Dealers (NAICS 441 1 10 and 441 120) with less than $21IM and $17M in receipts respectively as small businesses. The SBA also defines All Other Motoi Vehicle Dealers (NAICS 441229) with less than $5M in receipts as a small business. There ai e approximately 465 school bus dealers and distributors in the United States. During the last 6 years, about 35,000 (avg.) school buses were sold annually, or about 75 buses per dealer on average. In order to achieve $5M in sales receipts, the average dealer would have to sell abou 83 buses annually assuming a cost of $60,000 per Thus, most bus dealers probably are small businesses. Although some federal funds were initially made available via FTA (formerly UMTA) demonstration projects to implement the lift provisions of the ADA, public transit municipalities and paratransit companies across the U.S. will bear the economic burden of the Final Rule. TI ieir annual revenues are made up of passenger fares, state and local resources, Federal resources ai id other earnings. Depending on the future level of State and Federal subsidies, passenger fare increases may be necessary to implement the wheelchair accessibility requirements of the ADA. Per the definitions of the Regulatory Flexibility Act, it is believed that many transit authorities and many paratransit operators are considered small organizationshusinesses. There are also
VIII-4 many private transit bus operators which provide public transportation. The American Public Transit Association indicates that there are over 6,000 transit and paratransit bus operations in the U.S. which provide public/private transportation. DOT regulation requires that over-the-road buses required by public entites (or a contractor to a public entity) must also provide a level change mechanism or boarding device for wheelchair I other mobility aid users. <strong>NHTSA</strong> is requiring that lift-equipped over-the-road buses meet the FMVSS No. 403/404 requirements of the Final Rule. .The Regulatory Flexibility Act of 1980 (Public Law 96-354) requires agencies to evaluate the potential effects of their proposed rules on small businesses, small organizations and small governmental entities. Section 603 of the Act requires agencies to prepare and make availabk for public comment an initial Regulatory Flexibility Analysis (RFA) describing the impact of rules on small entities. Section 603(b) of the Act specifies the following content for the RFA: o A description of the reasons why action by the agency is being taken; o A succinct statement of the objectives of, and legal basis for, the Final Rule; o A description of and, where feasible, an estimate of the number of small entities to which th.: Final Rule will apply; o A description of the reporting, record keeping and other compliance requirements of the Final Rule including an estimate of the classes of small entities which will be subject to the requirement and the types of professional skills necessary for preparation of the report or reco d; o An identification, to the extent practicable, of all relevant Federal rules which may duplicatc:, overlap, or conflict with the Final Rule; md
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Subject: From: To: U.S.Department o
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TABLE OF CONTENTS Summary..........
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s-2 The annual number of persons in
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11. BACKGROUND 11- 1 Guidelines per
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11-3 and strength; control panel le
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111-2 Generally, there is very litt
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111-4 Table 111-1 Preliminary Natio
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111-6 The NEISS database lacks the
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111-8 Public Transit & Paratransit
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w-2 identifying the relevant lift c
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IV-4 MEASURE RED FLASHING BEACON OR
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IV-6 Acceleration is to be measured
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IV-8 FIGURE IV-2 :i a la Y t Permir
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IV-10 and vehicle size. This requir
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v-12 7. Prepare test block fnction
Page 31 and 32: IV-14 Gaps, Transitions and Opening
Page 33 and 34: Figure m-3 Allowable transition dim
Page 35 and 36: IV-18 sliding or being driven over
Page 37 and 38: v-20 traveling too fast, in the for
Page 39 and 40: WC Retention Overload Test 67.13) I
Page 41 and 42: IV-24 The lift is raised to the flo
Page 43 and 44: N-26 (2 square inches) applicator a
Page 45 and 46: N-28 sufficient to adequately illum
Page 47 and 48: IV-30 lack of follow-up training. N
Page 49 and 50: IV-32 16. Backup Operation (S6.9) -
Page 51 and 52: IV-34 This “looked but did not se
Page 53 and 54: W-36 e Clearance test block (S7.1.3
Page 55 and 56: IV-38 Structural Integrity, to iden
Page 57 and 58: IV-40 NHTSA assumes that the large,
Page 59 and 60: V. BENEFITS v-1 Serious injuries an
Page 61 and 62: v-3 retention strength test, CG and
Page 63 and 64: v-5 objective terms which should le
Page 65 and 66: VI-2 subject to the ADA requirement
Page 67 and 68: VI-4 averaged 35,000 units per year
Page 69 and 70: VI-6 In order to make an estimate o
Page 71 and 72: Cost Estimates VI-8 New Lift Hardwa
Page 73 and 74: VI- 10 close a circuit and send a s
Page 75 and 76: VI-12 FMVSS No. 141 Lift Certificat
Page 77 and 78: VI- 14 Total Cost for Public-Use Li
Page 79 and 80: VII. LEADTIME VII-1 Since the lift-
Page 81: VIII-2 Table VIII-1 SUMMARY OF SBA
Page 85 and 86: VIII-6 Many hundreds of small busin
Page 87 and 88: VIII-8 adaptive driving equipment f
Page 89 and 90: VIII-10 Facts Book, 7.2 percent of
Page 91 and 92: A- 1 REFERENCES 1. Americans with D
Page 93 and 94: A-3 25. A Directory of UMTA-Funded
Page 95 and 96: Figure 1 Dirgm Showing the Part8 of
Page 97 and 98: 5 Figure 2. Isometric View of Platf
Page 99 and 100: PLATFORM DEFLECTION ANGLE DEFLECTIO
Page 101 and 102: .. Lln UP, OUTER BARRIER UP LIFT MI
Page 103 and 104: i I i I I I I i 1 i I ! j I I ~ __
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Memorandum - NHTSA

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