Norwegian Public Roads Administration

Norwegian Public Roads Administration

Directorate of Public Roads

1.

Stop signal knobs should also be allowed in the roof above individual seats acoording to the Bus Directive. Today the requirement is maximum 1200 mm in class I and II. The height limitation poses no particular problems in a city bus with sufficient amount of handrails and vertical tubes, but is limiting the possible locations for mounting stop signal knobs in a typical intercity bus with no such handrails. Then the only place available is on the seats, and there is not many types of seats which allow the placement of stop signal knobs. The consequence is very scarcely occurence and distribution of stop signal knobs (minimum allowed according to the Directive). It is possible to have one over every seat placed on the ventilation channel (that is, plenty of communication devices nearby every passenger), but these do not count according to the Directive, because they are placed higher than the 1200 mm limitation from the floor level.

2.

There should be one common location of opening devices for emergency doors placed maximum 1300 mm above floor level (as in Annex 7): In Annex 1 the minimum required height for opening devices for such doors must be at least 1600 mm above floor level. In Annex 7 the requirement for the same opening devices is "maximum 1300 mm", when there is wheelchair users in the bus. Those two contradictary requirements makes it impossible to standardize the placement of the emergency opening devices. In some cases a bus is prepared to sometimes allow wheelchair users, and sometimes not. Then we need two different but identical opening devices for the same door, which makes nonsense. We feel the sensible solution is to require that the opening device should be placed no higher than 1300 mm in either case, making it available for all groups of people to operate it in an emergency.

3.

Wheelchair places should not be limited by the bus class.

We have experienced that a class 2 bus can have no more than 1

wheelchair space. This is a matter of interpreting the Directive in a

way that not limits accessibility for disabled persons and wheelchair users. The problem arises when there are more than one wheelchair

space in a class 2 vehicle. Then the (available) area for standing

passengers exceeds "the place equal to 2 double seats", wich can lead

to the conclusion that the bus is no longer a class 2 vehicle, but

should be interpreted as a class 1 vehicle (city bus). The problem

only exist if one define the open free space when there is not a

wheelchair in place, as "area for standing passengers". We think that

there should be room for the manufacturer to choose if the area should

be considered as area for standing passengers or not. To redefine the

bus into class 1 (and thereby full Annex 7 compliance) leads to

problems with respect to clearance to ground (maximum allowable first

step from ground) and conflict with interior solutions that would make

the bus less interesting for the owner. His conclusion could be to

only allow 1 wheelchair space in his class 2 bus. The number of

wheelchairs should be unlimited in every bus class and not

automatically put the bus in class 1. One should consequently be free

to choose if an open area should count as area for staning persons or

not.

4.

A wheelchair should relase relevant Annex 7 requirements, a pram should not.

The "wide interpretation" of the Bus Directive tend to include a very wide group of people being in need for th Annex 7 requirents. Our understanding of the Bus Directive is that the existence of a wheelchair onboard the bus releases the RELEVANT requirements of Annex 7. For example ramp width, fastening of wheelchair, wheelchair space -BUT NOT the complete volume of Annex 7. However, a bus owner may want to improve accessibility in a class 2 bus by including a ramp for trams and trolleys. This is a cheap and simple solution that improves accessibilty for many people. Should however Annex 7 requirements apply in this case, it would imply the extra cost of a fastening safety system and extra space for the wheelchair. The system would have to be tested and approved, so refit would be an expensive option. The simple solution for the bus owner to this requirement would consequently lead to REMOVAL OF THE RAMP. That is, demanding Annex 7 if there is a ramp (for prams), a space for prams (not wheelchairs), would lead to aggravated accessibility, and NOT IMPROVED accessibility.