# 160


III-4.4200
III-4.1400                         February 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
XXXXXXXXXXXXXX.  XXXXXXXXX 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 
provided 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