FEB 22 1995

The Honorable Roscoe G. Bartlett Member, U.S. House of Representatives 15 East Main Street, Suite 110 Westminster, Maryland 21157 Dear Congressman Bartlett: This letter is in response to your inquiry on behalf of XX inquired whether rental car companies must provide vehicles equipped with steering knobs upon request under the Americans with Disabilities Act ("ADA"). Title III of the ADA requires rental car companies to remove transportation barriers that prevent persons with disabilities from being able to use rental cars, when doing so is readily achievable. An act of barrier removal is readily achievable when it is easily accomplishable and able to be carried out without much difficulty or expense. This analysis depends on several factors, including the nature and cost of the action, the overall financial resources available, and legitimate safety requirements needed for safe operation of the vehicle. Rental car agencies have argued that some types of mounting hardware used to attach spinner knobs to steering wheels damage the steering wheels, rendering the cars less valuable upon resale. Others have argued that some mounting devices interfere with the proper deployment of drivers side air bags which are installed inside the steering column. Please refer to the enclosed Consumer Advisory, released on September 15, 1994, by the National Highway Traffic Safety Administration. In either case, it would not be readily achievable to equip a rental vehicle with a spinner knob. To the extent that mounting devices are available that do not damage the steering wheel or interfere with air bag deployment, however, rental car agencies are generally required to provide spinner knobs for persons with disabilities, when

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-2provided with sufficient notice. Spinner knobs are relatively inexpensive, easily installed, and transportable. Where spinner knobs are required by title III, companies cannot impose a surcharge for their use. Instead, the cost should be treated as an overhead expense. I hope this information is useful to you in responding to your constituent. Sincerely,

Deval L. Patrick Assistant Attorney General Civil Rights Division


Congress of the United States House of Representatives Washington DC 20515-2006 January 12, 1995 U.S. Department of Justice Civil Disabilities Act Public Access Department P.O. Box 66738 Washington, D.C. 20035-6738 Dear Public Access Department: Please find enclosed a copy of a letter from XX regarding steering knob access from rental car agencies. As you can see from the enclosures, XX was involved in an accident, and needed to rent a car. According to XX , he was denied access because the rental agencies did not have a vehicle with steering knobs. He has asked that I bring this matter to your attention. Any assistance you may provide XX would be greatly appreciated. Please reply to 15 E. Main Street, Suite 110, Westminster, MD 21157, Attention: Deborah Hamrick. Sincerely,

Roscoe G. Bartlett Member of Congress RGB:dlh Enclosure 01-03643​ 12-7-94 Dear Mr. Bartlett On Saturday, November 26 I was coming down 140 from Westminster. I turned left onto Gorsuch Rd. at McDonald's. It was about eight o'clock and pitch black. After going 200-300 yds, a large doe decided to cross the road and hit my car. My insurance paid for the damage but trying to get a rental car with a steering knob was a real predicament. Rental car agencies have cars for the disabled but they only deal with the ignition and brakes. Medically I'm classified as a walking quadraplegic. I walk with 2 canes. Both legs were broke (left leg shattered from knee down.) I took Driver's Education at Easy Method and the instructor recommended the steering knob. This feature allows me to make all my turns with the right arm. I really appreciate your consideration and help. Thanks XX