Here I would like to add another thing here in Delhi now many Electric Busses are introduced which make no sound at all, when bus comes and stops in bus stop without sound VH persons are unable to recognize whether bus has come, so I request you to include Buzzer system whenever door of bus opens & closes so that VH person can easily recognize where the door is exact when the bus arrives in bus stop.
On 10/26/23, Vaishnavi Jayakumar <jayakumar.vaishn...@gmail.com> wrote: > Online hyperlinked version = > https://docs.google.com/document/d/15Pda9V4XyYxxbWslE0Ii4Oxg4T0hsVPwm5QxkuPlmzo/edit?usp=sharing > > ---------- Forwarded message --------- > From: *The Freedom of Movement Coalition* > Date: Thu, 26 Oct 2023 at 16:57 > Subject: Representation re PM E-Bus Sewa Scheme compliance concerns > To: <secyur...@nic.in> > > > 26 October 2023 > > Manoj Joshi, > > Secretary, Ministry of Housing & Urban Affairs > > 122-C Nirman Bhavan, > > New Delhi. > > Dear Mr Joshi, > > SUB : PM EBus Sewa Scheme to be made compliant with statutes > > The Freedom of Movement Coalition (FMC) is a pan-Indian group advocating > for equity in transport. > > Team FMC would like to draw your attention to the following aspects > of the Draft > RfP Technical Specifications (Volume III) for PM-eBus Sewa for comments > from stakeholders > <https://www.convergence.co.in/public/images/electric_bus/Tech%20Specs%20for%20stakeholder%20feedback.pdf> > released on 28 September 2023, which despite the professed claim to provide > buses with ‘easy passenger accessibility including for persons with > disabilities (PWDs)’ exclude disabled citizens and are in violation of The > 2016 Rights of Persons with Disabilities Act (RPDA) > <http://bit.ly/dralib-rpwd> (Sections 41 > <https://docs.google.com/document/d/e/2PACX-1vRDWYm51DFLMsQGHJh5EDlel3IWFo6Zn53abW6Q2jOZL25h5RKaO64cvAIBn1HgXjnw3JU9zOnlomhK/pub#h.ei5xpijb3duw> > & 46 > <https://docs.google.com/document/d/e/2PACX-1vRDWYm51DFLMsQGHJh5EDlel3IWFo6Zn53abW6Q2jOZL25h5RKaO64cvAIBn1HgXjnw3JU9zOnlomhK/pub#h.wtkxgdrocbq3>) > read with the 2017 RPDA Rules > <https://docs.google.com/document/d/e/2PACX-1vRDWYm51DFLMsQGHJh5EDlel3IWFo6Zn53abW6Q2jOZL25h5RKaO64cvAIBn1HgXjnw3JU9zOnlomhK/pub#h.ko2f56o4mt7i> > (Section 15B). > > In Table 1: Technical specifications of Type-I non-BRTS Electric bus, the > following categories are outlined in the introduction > > 1. 12m, 900 mm floor height AC Bus > 2. 9m, 900 mm floor height AC Bus > 3. 7m, 650 to 900 mm floor height AC Bus > > While 650 mm floor height buses have a single step after the footboard, 900 > mm floor height buses have 2 steps. Type-I buses proposed by the PM-eBus > Sewa scheme are vehicles designed and constructed for urban and suburban / > city transport with area for standing passengers, to allow quick and easy > movement of passengers (including standing passengers) and are associated > with frequent stops and short dwell times. > > This particular use case would be best served by step-free, level boarding > that benefits crutch users, pregnant persons, children, wheelchair users, > older persons etc alike. > > While a lift system could be explored for long distance journeys with fewer > stops and less stressful schedules, for Type-I intra-city buses, the lift > system proposed will benefit wheelchair users alone (albeit with > significantly increased dwell time - a low floor bus takes only 25% dwell > time of a lift operated bus), leaving out crutch / calliper users, pregnant > persons, stroke survivors etc. > > It is concerning that Item 16 in Table 1 ‘Provisions of for wheel chair of > Persons with Disability (PwD)’ specifies ‘As per AIS:153, in at least 10% > of the fleet (except for 7 m buses).’ This provision which fixes an > optional minimum proportion of universally accessible buses flies in face > of the universal requirement for any public transport vehicle. Not only is > this provision unethical, it is a violation of disability law, the bus body > code as well as the Central Motor Vehicle Rules. > > As per MoRTH GSR 797(E) > <https://morth.nic.in/sites/default/files/circulars_document/GSR%20797%28E%29%20ATS%20amendment%20rules.pdf> > dated 31.10.2022, Central Motor Vehicle Rules' No 189, Table D, serial > number 22 (v) requires all Type 1 buses to have space for at least 1 > wheelchair from 1 April 2023, barring which the buses will be declared > unfit. > > Though this has now been extended to October 2024 via GSR Notification > 233(E) > <https://morth.nic.in/sites/default/files/circulars_document/GSR%20233%28E%29%20dated%2029.03.2023.pdf> > dated 29.03.2023, due to non-readiness of automated testing stations (ATS), > the disability related components of the fitness readings are based on > visual inspection parameters and therefore require no postponement in > compliance. > > Even if a vehicle is procured using loopholes, given that GSR 663(E) > <https://morth.nic.in/sites/default/files/circulars_document/1-GSR%20663(E)%20dated%2012.09.2023%20for%20extension%20of%20date%20for%20mandatory%20testing%20of%20Transport%20Vehicles.pdf> > dated 12.09.2023 requires testing every 2 years for vehicles less than 8 > years old, and yearly thereafter, a public transport vehicle without > wheelchair docking space will not get its fitness certificate renewed. > > No mention has been made of requirements of blind passengers - while the > IIT Delhi ITS ‘On Board’ homing system for blind passengers to correctly > identify their bus when multiple buses arrive at the same time, is not yet > part of the bus body code, the requirement of Acoustic Vehicle Alerting > System (AVAS) for electric / Quiet Road Transport Vehicles under AIS 173 > <https://morth.nic.in/sites/default/files/ASI/4-AIS-173-Requirements%20for%20Approval%20of%20Quiet.pdf> > has also been omitted despite evidence of quiet vehicles causing death or > bodily injuries of blind pedestrians unaware of their presence. > > It would be remiss on our part to not mention concerns that in a country > with an acute shortage of buses for even existing patrons, the choice of > procuring all 10000 buses planned under PM EBus Sewa as air-conditioned > buses, is costly in more ways than one and will potentially exclude current > passengers who rely on affordable, reliable, accessible public transport as > their only option. > > Item v in the introduction reads “Where there is conflict between the > requirement as per any applicable law in force and the requirement > emanating from these specifications whichever of these two is of superior/ > higher standard shall prevail. Also, any specifications superior to the > ones set out as Minimum Technical Specifications shall meet requirements of > the contract. “ > > In keeping with this provision, you are therefore requested to rectify the > technical specifications, remove contradictory provisions in favour of > superior inclusion parameters and ensure compliant procurement of > universally > designed, step-free, level boarding Type - I public transport that is > accessible to ALL. > > The Freedom of Movement Coalition’s Specifications for Disabled-Friendly > Bus Transport in India > <https://docs.google.com/document/d/1A-3w0cqISFZ1SH3k3Lnqnho4h5ubEwKtG0m21tM_iPo/edit?usp=sharing> > may be referenced to ensure legal and inclusive procurement. > > Regards, > > > THE FREEDOM OF MOVEMENT COALITION > > -- > Disclaimer: > 1. Contents of the mails, factual, or otherwise, reflect the thinking of the > person sending the mail and AI in no way relates itself to its veracity; > > 2. AI cannot be held liable for any commission/omission based on the mails > sent through this mailing list.. > > > Search for old postings at: > http://www.mail-archive.com/accessindia@accessindia.org.in/ > --- > You received this message because you are subscribed to the Google Groups > "AccessIndia" group. > To unsubscribe from this group and stop receiving emails from it, send an > email to accessindia+unsubscr...@accessindia.org.in. > To view this discussion on the web visit > https://groups.google.com/a/accessindia.org.in/d/msgid/accessindia/CAN7%2Bzvo-RGu-Gb1akK8qCSjCt5o%3Dii6yZENfW4Z26309oo4ZWQ%40mail.gmail.com. > -- Vivek Doddamani Ph-9868954833 & 7011740648 skype: vivek.doddamani, FB: vivek doddamani. 105, Lancer Road, Near Mall Road, Delhi-110054. -- Disclaimer: 1. Contents of the mails, factual, or otherwise, reflect the thinking of the person sending the mail and AI in no way relates itself to its veracity; 2. AI cannot be held liable for any commission/omission based on the mails sent through this mailing list.. Search for old postings at: http://www.mail-archive.com/accessindia@accessindia.org.in/ --- You received this message because you are subscribed to the Google Groups "AccessIndia" group. To unsubscribe from this group and stop receiving emails from it, send an email to accessindia+unsubscr...@accessindia.org.in. To view this discussion on the web visit https://groups.google.com/a/accessindia.org.in/d/msgid/accessindia/CANYGqbiC2kNPV1nx3q60ptyVnVYyxKUDF4%2Ber2nv_PJV8Fmgeg%40mail.gmail.com.
