MORTH submission on draft accessibility framework

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Vaishnavi Jayakumar (Inclusive India)

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Aug 6, 2025, 10:05:13 AMAug 6
to GG - SAC : Transport Egroup
Apologies, have been unsuccessfully trying to get an accessible version of the submission, OCR is mixing content of 2 columns. 

Can't put it off any longer and have attached the OCRed document, but as initial feedback shared below shows, the submission is mostly echoing content of the  hyperlinked references with comment saying this is already there in the bus body code.
 


@⁨Harsh Prabhakar MORTH⁩ , this response has simply provided the content of what was already a hyperlinked reference in the framework standards linked above. 

It is incorrect in stating that AVAS warning for blind due to quiet electric vehicles is not covered under AIS, the reference is in fact not only provided in the framework but on a desktop the hyperlink will take you to the correct page.

[05/08, 16:09] Vaishnavi Jayakumar: In the E category, the claim is made of UNECE R107 - AIS bus body code compliance - if that were the case, we would have transited to low floor buses by now, like Europe did in the 1980s!

The deliberate omission of key words in the definition of low floor buses in the bus body code is not the only deviation, there are many more amendments which have diluted the bus body code , including a highly unsafe ramp gradient.

[05/08, 16:12] Vaishnavi Jayakumar: There is no phase 2 possible as has been optimistically stated for a chunk of the Category E non-negotiables. Also there is no comment on Type 3 long distance bus non-negotiable.

[05/08, 16:20] Vaishnavi Jayakumar: As is, the framework requires low floor as the only option for Type 1 & 2 buses. If MORTH is in accordance with this, then perhaps we can proceed with framing the accessibility component for an updated Urban Bus specifications.
OM dated 24.07.2025 - Draft List of Non-negotiable accessibility standards for the transport sector-ocr.pdf
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