Step 4 Letter to the Salt Lake City Attorney Russell Weeks

December 16, 2010 at 5:54  p.m.

Dear Mr. Weeks,

Thank you for your notice on the suspension of the enforcement of the 350,000 mile limit.  The City ordinance allows a 2 year grace period for coming into compliance on age limits of the vehicles, but is silent on the mileage.  I am glad to see the suspension of the enforcement of the mileage limit rule.

When I went to the City Council and used my two minute public comment time, I was able to make only one of my three points:  we need realistic grace periods to get in compliance with the new ordinance if vehicles can be knocked off the road at the inspection.

But my problem remains:  There is no such thing as a grace period if the vehicles can be knocked off the road at inspection.  I have two different inspection reports for the same vehicle, Nov. 30 and Dec. 8.  They are so dramatically different that there are obviously two standards  for inspection–the tougher one triggered by the year of the vehicle.  This van passed on November 30, 2010, all but for a right rear brake/turn lens which had a hole in it.  The inspectors put a sticker on the window which makes it impossible to drive even in the county.  It is PR suicide to drive something  declared it out of service by a government entity.  But the chip was not removed.  That has never happened to us.  We were told to make a 15 minute appointment and bring it back to prove the lens was replaced.  Otherwise it had passed and would not be re-inspected.

It went straight to the body shop, but and stayed there until the part was in, installed, and we had the 15 minute appointment for re-inspection.

I am a little clumsy with my laptop. Here is the rest.

I was telling you that a week after the van needed only the lens replaced to pass, the van was thrown back to square one and reinspected. The talk was of years and miles, and the first item on the comments list was: “mileage as of 12/8/2010 = 369,731” followed by thousands of dollars worth of cosmetic issues. The van was actually eligible for appeal on the miles because it is a wheelchair van, but the new to-do list buries it as a practical matter. Same van that only needed a plastic lens from Dodge a week earlier. And it not only got red stickered, but they took the computer chip off it. First time ever experienced that. Which I took to mean that no matter how much I spend fixing it, it would never get through inspection.

If there are two standards for inspections, grace periods mean nothing. I am happy to correct anything safety related, but I want the City to let this van go through based on the November 30th inspection. The cosmetic issues were not disqualifying then.

2. I did not have time to explain to the City Council that the estimated cost to fix the van was $5,000.00 to $10,000.00, open ended. I will send you a copy of the preliminary estimate. And a new van costs around $45,000.00. The cost is so high because all ADA vans are aftermarket custom conversions. This one was built on a Dodge truck chassis, and sold by Dodge as a windowless van with no interior panels. A custom conversion company did the cosmetics, with parts of unknown origin. How to get parts? Even if you are dealing with a Dodge part, they quit making vans that big in 2000, and now with the recession have discontinued some parts.

The inch and half gap in the metal trim on the bottom of the back door window is not a simple fix. The door is custom, replacing two smaller doors. The window, rubber gasket, and metal trim are all one custom piece. You cannot deal with the trim without breaking the seal on the gasket, loosening the window. It would cost easily a $1000.00 to custom cut and fabricate a new window: glass, gasket, trim.

The interior trim is all custom. You cannot just order a vinyl door panel from Dodge to get rid of an inch long tear inside the big back door, because Dodge put two small doors there. The back bench seat is not from Dodge. The side doors are also customized to the ADA required height, above the original roof line.

3. I did not have time to explain to the City Council what is special about this van. The ADA was passed in 1992 and phased in by 2002. The regulations were made in the decade of the 90’s vans and based on the 90’s vans. It is the perfect ADA van. Dodge quit making a van this big in 2000. So the necessary $10,000 of aftermarket customization on a new van does not give this much interior space. Vans are close quarters for wheelchairs. This van has room behind the back bench seat to stash a courtesy wheelchair. (The metal wheelchairs probably caused the 1 inch tear in the vinyl in the back door behind the seat.)

The big side doors and the big, wide, steel, custom fold-down ramp operated by the driver makes this van especially useful. The commercial power lifts are built to the ADA legal minimums. This van can handle weight, and wheelchair wheelbases, and seat widths, beyond those legal minimums. Handi Van Inc. gets referrals from UTA and other companies using commercial power lifts. Handi Van Inc. can do runs no other transportation provider can.

Obviously the van will need to be phased out. All my vans are over age or miles or both, and will have to be phased out in the next two years. My vehicles replace new for $40,000.00 to $100,000.00. I hope the City respects Handi Van Inc.’s experience, record, and service enough to let me work my way through the transition.


Lee Anne Walker

p.s. If the City building was a van, should it flunk? There are tears in the quilted material hung inside the elevators. And like the blanket over the van’s back bench seat, it obviously hides something. Would be it fair to lift up it up and note any small scratches, tears, stains, or dings in the paint underneath?

on Thursday, Dec 16, 2010 at 3:13 PM, Weeks, Russell wrote:

Randy and Lee Anne:consideration of phasing in a different deadline. It is my belief that the requirement is now suspended until the issue is addressed.

I should note that the Department of Airports indicates that there “have been a handful of vehicles that were rejected due to mileage.” According to the department, those companies have been contacted and told that if they don’t have any other rejected offenses, the Department of Airports will re-inspect the vehicles and issue a new sticker and AVI tag so they can operate until the City Council makes any amendment to the ordinance.


Russell Weeks.

Russell Weeks

Public Policy Analyst

Salt Lake City Council


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