Text-Only Version Prepared by: TranSystems Corp. Medford, ma and: Planners Collaborative Boston, ma august 24, 2007 contents

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Portable Lifts on the Green Line: Currently, most accessible Light Rail stations require the use of portable lifts. Portable lifts at all accessible stations should be cycled daily by Transportation Inspectors to assure that they are in good operating order. Inoperable lifts should be recorded in daily station reports and reported to maintenance staff for repair or replacement in a timely manner. Portable lifts should be stored in designated areas at stations, with the areas selected to provide ease of use and to avoid blocking pathways.
Lifts on Buses: The procedures for inspection of vehicles appear to be effective in identifying problems. However, the reporting of information on use of buses with inoperable lifts in service appears insufficient to identify whether or not buses with inoperable lifts were used in service when other buses were available or whether buses with inoperable lifts were used in service for more than three days. Reporting information on use of buses with inoperable lifts will be further discussed later in this report.
Public Communications: A challenge in providing effective customer service is provision of accurate, clear and timely information on transit service. This challenge increases with the number of points of contact for obtaining service information. Of necessity, transportation staff on vehicles and in stations provide information including stop and route announcements, as an element of customer service. Other points of customer information include Operations Department PA Announcements, web site, the Customer Telephone Center and the Office for Transportation Access. Outside of the Operations Department the Marketing and Communications Department and the Public Affairs Department are responsible for customer communications. Consolidation of customer communications, other than field communications by transportation personnel, can provide customers with one point of contact for information and facilitate provision of accurate, clear and timely information on transit service.
To further enhance the timeliness and accuracy of public information it is further suggested that all public information that lends itself to reporting in electronic format (such as elevator status reports) be reported on the MBTA web site. Not only will this approach provide consistent, accurate real time information to customers with internet access but also will provide the same information to MBTA telephone operators and all customer information staff.
Because complaints are accepted by many different departments in the MBTA it is not clear that they are all recorded in the Marketing Communications Department log. It is recommended that all customers who have a service comment be directed to the Customer Relations in Marketing Communications to properly log the complaint. Alternatively, if others accept complaints, a mechanism (such as a form) should be provided to facilitate proper logging of the complaint. It does not appear that complaint data is specifically used to identify and correct service problems. It is recommended that complaint information be analyzed periodically by Customer Relations staff in Marketing Communications to identify service problems and/or trends.
Role of the Office for Transportation Access (OTA): As noted above, the OTA’s Fixed Route Office manages pass programs for seniors and riders with disabilities. It also manages the stop announcement monitoring program and is the MBTA’s primary liaison with the AACT on issues related to fixed route accessibility. OTA also handles customer comments and complaints that come directly through the MBTA’s web page (under “write to the top” and other routes). Typically, OTA will send a complaint involving a line department to that department for processing.
Given the organizational structure of the MBTA, OTA’s Fixed Route Office has little real authority to implement changes within the line departments or to affect changes in operations related to accessibility. This authority rests with the Supervisors in each of the line departments.
OTA is in a position to assist in monitoring compliance with accessibility standards and requirements across all modes. It also is in a position to assist and provide technical assistance to line department Supervisors on accessibility issues.
To clarify the responsibilities for meeting accessibility standards and requirements within the agency and the proper role of OTA, it is recommended that:

The MBTA General Manager make it clear that line department Supervisors are responsibility for meeting accessibility standards and requirements within their departments;
Line departments also should be responsible for the timely and thorough investigation and handling of customer complaints related to service provision within their department;
Line departments should be responsible for implementing systems and processes for ensuring that accessibility standards and policies are being implemented effectively;
OTA should serve as a resource to the line departments to provide technical assistance in addressing accessibility issues and in helping the agency set future directions regarding accessibility across all modes;
OTA should be given the responsibility to track and report on accessibility within each line department. Line department Supervisors should be directed to cooperate with OTA in gathering and reporting information necessary for this tracking to take place;
OTA also should serve an “external monitoring” function outside of the line departments. It should undertake monitoring activities to verify compliance with accessibility standards, such as the stop announcement program it now manages. Additional external monitoring activities suggested later in this memorandum should also be managed by OTA. This should include additional monitoring of lift, ramp, kneeler, and securement systems use, monitoring of the implementation of appropriate disciplinary actions by each line department, and random checks of elevator and escalator operation;
OTA should continue to be the primary liaison with the AACT. Line department Supervisors and staff should also be required to interact with the community, report to AACT as requested and respond to issued raised by AACT.

Whereas OTA fixed route staff’s primary functions relate to customer service, it is recommended that the MBTA consider moving the fixed route portion of this office from operations and placing it in either the Customer Service Support Center or the Office for Systemwide Accessibility. This would permit OTA to pursue service improvements on behalf of customers with, but independently of, operating departments.

Additional Monitoring Plan Recommendations
In addition to the organizational observations and recommendations above, the Plan contained several recommendations for strengthening the monitoring of stations and elevators, bus lifts, ramps, kneelers and wheelchair securement systems, and customer service and information. The major recommendations are summarized below. The full discussion of monitoring in each of these areas is contained in the Monitoring Plan (Technical memorandum #6).
Stations & Elevators
In order to assure that preventive maintenance is performed on schedule, the Monitoring Plan recommends that all scheduled and actual elevator PM inspections and service be entered into MCRS, or other tracking system, by the appropriate Operations Support Manager. For clear and accurate public communication, the day of scheduled maintenance should be entered and the period within which the PM will occur should be entered. When the PM is completed and verified by the Operations Support Manager the date of performance should be entered. The Operations Support Manager should include random field inspections of the elevator repairs as they are being performed by the elevator maintenance technicians as part of the verification process. The results of these random inspections should be recorded. (paragraph 67) If an elevator is removed from operation during service hours the time of removal and time of return to service should be entered by the Transportation Inspector or other responsible field personnel. (paragraph 61) A possible means of tracking PM performance is a monthly report. A sample report is presented in Technical Memorandum #6. If PM is not performed on a monthly basis as required by the contract appropriate penalties can be assessed the elevator maintenance contractor.
To more precisely monitor performance and more quickly identify delays in response which, when addressed, can help minimize elevator down time or other problems, the Monitoring Plan recommends that more accurate and detailed monitoring and tracking of elevator status be performed and recorded. Recorded information should include times and dates of each action from initial reports of inoperable elevators to restoration of operation in MCRS. This can be accomplished by more closely tracking reported elevator problems. It is recommended that for each reported problem the following information be entered into MCRS or other central data base for tracking elevator status:

Elevator identification
ID of reporter
Date and time of report
Date and time of field confirmation by Transportation Inspector or Railroad Operations Oversight staff
Date and time of service request
Date and time work order issued
Date and time work order closed
Date and time operation of elevator confirmed by Transportation Inspector or Railroad Operations Oversight staff.

A monthly report such as the suggested elevator repair log presented in Technical Memorandum #6 should be generated from MCRS or other tracking system data to more precisely identify time elevators are out of service; help to identify any delays in response times for inspection and repair, and identify problem elevators.

To further reduce service interruptions, PM inspections and service should be scheduled in a manner to minimize the impact of any gaps in service and should occur when alternative accessible transportation is available to passengers needing to use elevators. (paragraph 53)
To consistently measure facility maintenance against performance objectives for all MBTA rail services, the Monitoring Plan also recommends that a standard inspection form be developed for general inspections for use in all MBTA rapid rail, light rail and commuter rail stations. A two part form would be helpful in assuring consistency of reporting while also addressing custom elements of stations. Part 1 of the form would include all station elements common to all stations and part 2 would be customized to include elements unique to specific stations. It is further recommended that this form be used for all general inspections and contract oversight inspections thereby facilitating consistent measurement of performance between rapid and light rail and railroad operations as well as contractors and MBTA oversight staff.
To readily track and report performance, the form should be structured to be compatible with the MBTA’s Maintenance Control and Reporting System (MCRS) and the Commuter Rail Directorate’s counterpart to MCRS. This should facilitate entry of inspection results into these systems.
For clarity of communication and tracking of needed repairs, the form should also be structured to directly correspond to departmental responsibilities for maintenance of each station element such as elevators and communications systems.
For stations with elevators and or portable lifts, the Monitoring Plan recommends that the following elements be added to the inspections:

Elevators – In addition to operation, lighting, cleanliness and emergency communication it is recommended that elevator communication elements needed by people who have vision or hearing disabilities be inspected. These elements include call buttons and elevator arrival and direction indicators.
Portable lifts – Provision for recording the results of cycling portable lifts should be added to the form.

As addressed in the general observations it is recommended that all information on elevator status come from, or be confirmed by, responsible MBTA field personnel (Transportation Inspectors and Railroad Operations oversight personnel, Customer Service Agents, or others). Accuracy of information in MCRS on elevator status can further be enhanced by direct data entry by Transportation Inspectors using PDAs. Similarly, consistent communication of elevator status data could be improved by uploading automated elevator status report updates from MCRS or other central database onto the MBTA web site and, in turn, using the web site data for all other public communications. (paragraph 61) A sample format for public information on the website is provided in Technical Memorandum #6. Railroad elevator outages should be reported through MCRS, or by similar means, to the web site staff. (paragraph 61)

To facilitate tracking and reporting progress on the status of corrective actions it is recommended that inquiry access to the MCRS be provided customer service staff and the MBTA’s Accessibility Specialist. Such access will provide real time information needed by customer service staff and save staff time by avoiding phone calls e-mails or other inter-departmental communication to obtain the needed information.
Bus Lifts, Ramps, Kneelers and Wheelchair Securements
In order to better monitor compliance with the requirement that buses with inoperable lifts and ramps be used when other vehicles are not available and that in no circumstances should buses with inoperable lifts/ramps be used in service for more than 3 days, the Monitoring Plan recommends that the MBTA consider developing reports that identify the reported request date for lift/ramp service and use of the vehicle (mileage) for each day from the service request. Sample suggested reports are provided in Technical Memorandum #6.
Although it is the MBTA’s practice to check the PA system during pull-out, this information is not included on the “Vehicle Condition Report.” The Plan recommends that PAs specifically be added to the report to reinforce the importance of their inspection. Also, a potential impediment to the use of buses by people who use wheelchairs is broken wheelchair securements on the buses. The Plan recommends that securement systems also be added to the Vehicle Condition Report to emphasize its importance to accessible service.
The Monitoring Plan also recommends that the Vehicle Condition Report be modified to include the odometer reading at the time of the vehicle inspection by the driver. It also recommends that PA and VMS be added to the “First Seat Check.” (paragraph 36)
To assist the Maintenance Supervisor in assigning vehicles with inoperable lifts for use in service, the Plan recommends an MCRS real time report that identifies vehicles with open service requests, or work orders, by date and the date a lift is reported as inoperable, and service is requested, the date of repair and the date & times that a work order was issued and the vehicle was dispatched into passenger service. This report should be developed for each garage. Miles traveled or odometer readings could be used as a proxy for use in service. (paragraph 6)
The Plan also recommends that the MCRS monthly report on wheelchair lift service requests be revised to include a column identifying the days that buses with open service requests are used in service prior to repair. (paragraph 7) Monthly reports identifying buses with disabled lifts/ramps and the days they were used in service should be provided managers to identify and correct problems with inoperable lifts/ramps.
It is also recommended that a monthly performance report be prepared to identify use of vehicles with inoperable lifts/ramps in service. Each garage should use the report daily to report peak vehicle requirements, vehicles available for service, vehicles not available for service, including those with inoperable lifts, vehicles with inoperable lifts and the number of vehicles with inoperable lifts used in service.
To ensure that buses with inoperable lifts be used in service only if no other bus is available, the Monitoring Plan recommends that daily reports that identify buses with inoperable lifts and buses with inoperable lifts/ramps that have been used in service should be provided to pull-out dispatchers. With this information the dispatcher can seek buses with operating lifts/ramps and withhold buses that have been used for more than 3 days from service.
To ensure that lifts, ramps, kneelers, securement systems and other accessibility features are used appropriately in service, the Monitoring Plan recommends that the MBTA Bus Operations Vehicle Operations Manual be updated to explicitly include requirements with respect to driver assistance to passengers who need to use lifts or ramps to board a bus, including the following:

Drivers always kneel the low-floor buses when deploying ramps;
Drivers always curb buses whenever possible when boarding or alighting riders who are using the lifts or ramps;
Drivers be alert for passengers waiting at bus stops who use wheelchairs who may be located near, but maybe not right at the stop;
Drivers assist riders getting on and off lifts or up and down ramps when requested or when the assistance appears to be needed. Before providing this assistance, drivers should be instructed to ask the passenger if they would like assistance;
Drivers always manually deploy ramps if the automatic deployment feature fails; and
Drivers always notify BCC when lifts fail in service or when they are otherwise unable to serve a rider using a wheelchair who is waiting at a stop.

Once these new policies have been adopted, the MBTA should implement a retraining program to insure that drivers understand what needs to be done to serve customers needing lifts, ramps or kneelers. Also, due to the number of complaints about the lack of professionalism of the drivers, retraining should also emphasize appropriate behavior towards customers with disabilities.

It also is recommended that the MBTA develop a progressive disciplinary policy related to compliance with these policies.
In addition, the Monitoring Plan recommends that the stop announcement “secret rider” program be expanded to monitor appropriate use of lifts, ramps, kneelers, bridge plates and securement systems. Riders who use wheelchairs and who regularly use the system should be hired as monitors to supplement the monitors currently working on the stop announcement program. These monitors should be tasked to observe aspects of driver performance related to lift, ramp, kneeler, and securement system use. This includes observing whether drivers stop for passengers with disabilities waiting at stops, whether the bus is pulled to the curb, whether the lift or ramp is properly deployed, whether the passenger is properly secured, and whether the driver is professional and polite in dealing with passengers with disabilities. It is suggested that the monitoring program focus on fixed route bus accessibility for a week out of each quarter (¶ 13, 39). A suggested form to be used for this monitoring is provided in Technical Memorandum #6.
The Plan also recommends that the MBTA undertake a monitoring program of the progressive disciplinary actions taken to insure proper service to customers needing lifts, ramps or the kneeler. This could be included as part of the monitoring program for disciplinary actions regarding stop and route announcements to be discussed later.
Finally, the Plan recommends that the MBTA consider adding safety and surveillance camera systems to its buses that can observe both inside and at the curb. Cameras would not only provide better security for the buses, but would also be able to provide documentation on the use of vehicles by people with disabilities. If there were a dispute as to whether a bus bypassed a wheelchair at the stop, the cameras would be able to document the truth. Such camera systems also could help with overall safety and security. They also could be used in accident investigations and to monitor safe driving skills.
Customer Service & Information
Public information is a large concern for riders with disabilities. As seen by the input from analysis of complaints and from the public meetings, inconsistent stop and route announcements and inaccurate information on elevator outages are of particular concern. The following recommendations were made to address issues in these two areas.
Stop & Route Announcements
The Monitoring Plan notes that the MBTA’s stop and route announcement program provides good information to the MBTA on how it is doing in meeting the ADA requirement that there be stop and route announcements. However, the major improvement in bus announcements has resulted from the use of automated announcement systems, which for the first time have allowed one garage to exceed 90 percent performance of announcements. The MBTA should reconsider its performance goal for stop announcements. A goal of 100 percent with an objective of 97 percent performance is suggested.
A problem with the monitoring of drivers with poor performance is that as the PAVMS systems are added to the fleet, the monitoring program is not able to gauge driver performance efficiently. If a particular poor performing driver is being tracked, the observation will have to be repeated until the driver is assigned a vehicle without a PAVMS.
Instead of focusing the monitoring program, therefore, on poor performing drivers, the Monitoring Plan recommends that the MBTA emphasize the random selection of routes for monitoring, so that comparisons by garage and by rail line can be made more representative.
Although it is recommended that the MBTA focus less on drivers who are poor performers, the MBTA should ensure that its progressive disciplinary program is being properly applied. It is recommended that the OTA or another customer service department at the MBTA undertake an independent quarterly assessment of disciplinary actions taken as a result of the prior quarter’s monitoring program, including both stop and route announcements and proper deployment of lifts, ramps and kneelers. First, a random sample of those drivers who failed in the monitoring program should be taken. The personnel records for these drivers should be checked to determine if they were appropriately disciplined as a result of the monitoring program, and a report made of the degree to which the disciplinary process is being applied. (paragraph 35)
Service Announcements
The Monitoring Plan notes that a key issue with regard to accessible path of travel interruptions is inoperable elevators. When elevators are inoperable, current information on elevator status and alternative routes is essential for customers who are dependent on elevators to complete their trip. Accordingly, accurate and timely information on elevator availability is necessary for the transit system to be accessible and usable by many people who have disabilities.
The Plan identifies two issues for improving the elevator maintenance communication. The more critical is to insure that accurate information on elevator outages gets to the phone Update Line and the Web pages. The missing information may have occurred because the elevator went out just before the 10:00AM inspection, so that the Web and phone line were not updated. Alternatively, there could have been a breakdown in communications some where between the Inspector and the PA Announcer and SmartRoutes employee. The MBTA’s plan for the PA Announcer to initiate more frequent updates should reduce the number of times that the customer information is inaccurate due to a delay in reporting of outages.
To the extent that the MBTA can use technology to improve communication, that should provide more real-time information for updating elevator status. For example, if inspectors can use a portable device such as a PDA to record problems with elevators, and immediately upload the information to the MCRS, inaccuracies due to the need to recopy information would be eliminated.
The second issue is for the MBTA to establish a procedure to update the phone Update line and the Web when an elevator is repaired.
The Monitoring Plan notes that the MBTA is planning to implement a revised program to notify customers of out of service elevators. The Operations Control Center (OCC) proposes to have the PA Announcer review the MCRS every half-hour during the service day to check for changes in the status of elevators and incorporate those changes into elevator PA announcements, hot line lists and websites as is currently done. To minimize potential for communication error, the Monitoring Plan recommends that the MBTA update the information on elevator outages on its web site directly from MCRS information. The information on the web site could in turn be used by customers accessing the web site, the PA announcer for making announcements and updating the elevator Update Line, and by station attendants and telephone operators in providing information to customers. Initially the SmartRoutes contractor could review MCRS every half hour and manually update the MBTA web site. In the long term the web site could be programmed to provide automated real time data by uploading reports from MCRS. (paragraph 61)
The MBTA plan is to notify field personnel and customers by updating the “flip” signs currently located next to each elevator and providing lists of out of service elevators at each fare collection area. The flip signs currently notify customers when elevators are out of service. The flip signs should be locked in place to avoid tampering. The MBTA proposes to add information on alternate routes to the sign and provide a phone number for customer assistance. (paragraph 61)
The out-of-service elevator list would be printed at “Hub” stations and distributed from there to all subway stations. The list would include a number to call for customer assistance. The lists would be updated, printed and distributed 3 times a day. Lists would be posted so they can be read by customers before they pass through turn styles and exposure to vandalism and weather is minimized. (paragraph 64, 65)
The MBTA has/is installing coordinated PA VMS at the “Hub” stations. This will permit both auditory and visual communication of service messages.
To assist in identifying alternate routes, the Monitoring Plan recommends that the MBTA trip planner be programmed to remove/add links when elevators are removed from or added to service. With this feature when an accessible trip is needed the trip planner could be used to alternate routes which reflects the current availability of elevators. The modified trip planner could then be used by customers with web access, and by public information staff to advise customers of alternate routes to reach their destinations. (paragraph 61) In addition to the MBTA web site and telephone information lines, call boxes located in stations at a point before the customer enters an elevator or station could be linked to MBTA information officers who could advise the customer of routes around out of service elevators or, if needed, provide for alternative service. (paragraph 62, 63, 65)

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