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Buses USDOT ADA Regulatory Requirements The USDOT ADA regulations further specify requirements for buses to be considered accessible. These requirements address:
Current MBTA Program Table 1.5 below summarizes the accessibility features of MBTA’s existing bus and trackless trolley fleet. The MBTA bus fleet is now 100% accessible. All buses are equipped either with lifts, or with ramps on low floor vehicles and trolleys. The fleet consists of 991 buses with 595 (60%) ramp equipped and 396 (40%) lift equipped. The 396 older RTS buses purchased between 1994 and 2004 are equipped with lifts. An overhaul program is underway for the 396 RTS buses. One hundred and twenty-five (125) buses are undergoing a major overhaul, and the remaining 271 are undergoing a less intensive overhaul. Lifts are being replaced on the 125 buses and reconditioned on the 271 buses. As of December 31, 2004, lifts had been rebuilt or replaced on 365 of the buses. As of mid-2005, seven hundred and fifteen (715) of the buses were equipped with, or were being equipped with Public Address Variable Message Signs (PAVMS) systems. These systems provide the capacity for audible and visual automated stop announcements, automated route announcements at stops serving more than one route, and confirming stop requests inside of the vehicle. All of the buses purchased since 1999 plus 125 RTS buses undergoing a major overhaul are, or will be, equipped with the PAVMS system. All buses are accessible and have PA systems as required by the regulations. Specific design elements have not been reviewed because they have not been cited as problems and are normally addressed in all bus design specifications as standard requirements. Additionally, information on private carrier contract service providers was not included in this review. For service reliability low floor buses equipped with ramps are preferable to lifts as a level change device. Lifts are a more complex device and as such are more prone to mechanical failure. Ramps, with their simpler operation, can be deployed manually and should work with the exception of being damaged. The MBTA should continue its program of replacing older buses with low-floor buses equipped with ramps and PAVMS. Table 1.5 – MBTA Bus Fleet (Editor’s note: Data about buses is first presented in this table. Then, data about trackless trolleys is presented. Next, data about the Silver Line is presented. Subtotals are provided for each type of vehicle. Finally, total data is given. For each type of vehicle, data is presented in the following order: Year of Manufacture; Make; Type; Series; Number of vehicles; Number with Boarding Ramp; Number with Boarding Lift) Footnotes to Table: CNG stands for Compressed Natural Gas ECD stands for Emission Control Diesel Bus: 1994-1996; RTS; Diesel; 0001-0400; 396; 0; 396 2003-2004; ABI; CNG; 2000; 299; 299; 0 1999; New Flyer; CNG; 6000-6001; 2; 2; 0 2002; New Flyer; CNG; 6002-6016; 15; 15; 0 2003-2004; Neoplan; 60 foot CNG; 1018-1044; 27; 27; 0 2004; Neoplan; ECD; 0401-0575; 175; 175; 0 Total number of Buses in Fleet; 914; 518; 396 Trackless Trolley: 2004; Neoplan; 4100; 28; 28; 0 Total number of Trolley’s in Fleet; 28; With Ramp; 28; With Lift: 0 Silver Line: 2003; Neoplan; 60 Foot CNG; 1001-1017; 17; 17; 0 2003-2004; Neoplan; 60 Foot Dual Mode; 1101-1132; 32; 32; 0 Total number in Silver Line; 49; With Ramps; 49; With Lifts: 0 Total Combined: 991; With Ramps: 595; With Lifts: 396 Commuter Rail USDOT ADA Regulatory Requirements The regulations require that commuter rail vehicles either comply with design requirements for level boarding or shall provide other means of vehicle access, such as lifts or ramps or wayside mini-high platforms or portable lifts. Other requirements for commuter rail passenger vehicles are:
Current MBTA Program Commuter rail passenger vehicles are not equipped with level change devices for people who use wheel chairs. Vehicle access is provided by level entry at high platform stations. At accessible low platform stations, vehicle access is by means of mini-high platforms and manually deployed bridge plates used to span the gap between the platform and the vestibule of the rail coach. In addition to accommodating level entry, all commuter rail passenger vehicles are equipped with steps for general boarding at low platform station areas. The MBTA commuter rail fleet consists of 377 passenger vehicles. The oldest vehicles are 27 years old, but these were overhauled in 1995 to 1996. In mid-2005, the 15 year-old Kawasaki vehicles were programmed for an overhaul. This overhaul is scheduled to take place during the period 2008-2010 in the MBTA’s 2006-2011 Capital Improvement Program. In addition to the vehicles listed, the MBTA is in the process of purchasing an additional 33 Kawasaki coaches. Twenty-eight will provide capacity for service expansion on the Greenbush Line and 5 are being purchased with Rhode Island Public Transit Authority funds to provide capacity for service to T.F. Green Airport in Rhode Island. According to MBTA Stop Announcement Progress reports to FTA, the new commuter rail coaches are being purchased with interior PA systems that adjust the volume of the announcement based upon the ambient, or background, noise level in the vehicle. The 67 MBB cars are equipped with rest rooms. These restrooms and other standard dimensional requirements have not been reviewed for compliance with ADA as part of this effort. Table 1.6 provides a summary inventory of the MBTA’s commuter rail fleet. Table 1.6 - Commuter Rail Fleet (Editor’s note: Data in the table is presented in the following order: Year Manufactured; Year Overhauled; Make; Model; Series; Number of vehicles) 1987; Bombardier; A Cars; 300; 40 1989-1990; Bombardier; B Cars; 600; 106 1978-1979; Year Overhauled; 1995-1996; Pullman; 200; 57 1987-1988: MBB; 500; 67 1990-1991; Year Overhauled: 2005; Kawasaki; Bi-level; 700-749; 75 1997; Kawasaki; Bi-level; 750-766; 17 2001; Kawasaki; Bi-level; 767-78; 15 Total in Commuter Rail Fleet is 377
The MBTA Light Rail fleet consists of four vehicle types: the PCC cars operated on the Mattapan High Speed Line; Boeing-Vertol LRVs, Kinki Sharyo LRVs and the newly purchased Breda low-floor cars are used on the Green Line. The SLRVs, Type 7 and PCC cars have stairs for boarding. They are not equipped with lifts or other means for boarding and alighting by people who use wheel chairs. These vehicles require mini-high platforms and portable lifts at stations for access by people who use wheel chairs. The Type 8 (Breda) cars are low floor vehicles equipped with ramps to accommodate boarding and alighting passengers who have mobility impairments. In mid-2005, there were approximately 41 out of a total order of 100 Type 8 cars in service on the Green Line. The 115 Type 7 cars were being modified for operation in trains with the Type 8 cars. This will permit one accessible Type 8 car to be operated in two or three car trains with Type 7 cars. The Type 8 cars are equipped with internal VMS signs and automated stop announcement technology. The same technology was being purchased for the Type 7 Green Line LRVs. Upon completion of the program, all but the PCCs assigned to the Mattapan High Speed Line and the Breda LRVs will be equipped with automated PAVMS systems. The Type 8 Green Line LRVs also have PA systems that adjust volume to ambient noise levels. Table 1.7 lists the existing light rail fleet by car type. Table 1.7 - Light Rail Fleet (Editor’s note: Data is first presented for the Green Line and then for the Red Line. Total light rail fleet information is then provided. Data in the table is presented in the following order: Line: Year Manufactured; Make; Model; Series; Number of Vehicles; Number with Access Ramps; Number with Steps) Green; 1976-1983; Boeing-Vertol; SLRV; 55; 0; 55 Green; 1986-1988; Kinki-Scharyo; Type 7; 3600; 95;0; 95 Green; 1997; Kinki-Scharyo; Type 7 (2);: 3700; 20; 0; 20 Green; 1998-2004; Breda; Type 8; 3800; 41; 41; 40 Total in Green Line fleet: 211, Access to Ramps: 41, Access to Steps: 210 Red; 1945-1946; Pullman Standard; PCC; 3000-3200; 10; 0; 10 Total in Fleet: 221, Access to Ramps: 41, Access to Steps: 220 The Type 8 cars with low floors and ramps used at elevated station platforms appear to comply with the USDOT ADA requirements for vehicles used in street operation. A Type 8 car on all trains operating to accessible Green Line Stations provides access to trains for people who use wheel chairs, and for these vehicles appears to comply with the requirements that at least one car per train be accessible. Twenty of the Type 7(2) cars were manufactured in 1997 and must be readily accessible and usable by individuals with disabilities, including individuals who use wheelchairs in accordance with the USDOT ADA regulations. Use of these vehicles by people who use wheelchairs would be required if all wheelchair positions in the Type 8 cars are occupied. Since these vehicles have high floors, an alternative means of access, such as lifts or mini-high platforms is required at accessible stations. Rapid Rail USDOT ADA Regulatory Requirements Rapid rail vehicle requirements are similar to those for buses:
Current MBTA Program The Rapid rail fleet serving the Blue, Orange and Red Lines provides vehicle access by level entry. Table 1.8 lists the existing rapid rail fleet by car type. Much of the rapid rail fleet is about 25 years old, with 24 Red Line cars over 35 years old. Ninety-four Blue Line cars are being purchased to replace the current fleet of 70 cars built in 1979. The additional equipment will permit operation of six-car trains and result in increased Blue Line capacity. In addition to the Blue Line investment, the MBTA is implementing programs to overhaul and or upgrade components of the remainder of the rapid rail fleet. Future plans call for replacement of the Red Line #1 vehicles and the Orange Line #12 cars. Table 1.8 - Rapid Rail Fleet (Editor’s note: Data in the table is presented in the following order: Line: Year Manufactured; Make; Model; Series; Number of Vehicles) Blue; 1979; Hawker-Siddeley; #4; 600; 70 Orange; 1981; Hawker-Siddeley; #l2; 01200-01319; 120 Red; 1969; Pullman Standard; #1; 01500; 24 Red; 1970, Make: Pullman Standard, #1, 01600, 50 Red: 1988, Make: UTDC, #2, 01700, 58 Red: 1994, Make: Bombardier, #3, 01800, 86 Total Red Line; 218 Total All Lines; 408 The Number 3 Red Line cars and the Blue Line cars that are being purchased are equipped with PAVMS systems which provide coordinated visual and audible automated announcements. Orange Line cars are equipped with hand held microphones with amplifiers to increase volume as needed. Given the age of the MBTA system, and due to track curvature, track settlement, wheel wear, uneven vehicle suspension or other conditions, there may be locations where the gap between the passenger door and the platform do not meet ADA requirements. Due to a lawsuit, information on this issue was not available during this review. Use of sacrificial rubber bumpers to extend the station platform, as used by WMATA in Washington, DC, is one potential means of addressing this problem to the extent that it may exist. 1.3. Public Input Regarding Fixed Route Service As part of the evaluation, public input on fixed route service accessibility was obtained from several sources. These included:
Affidavits Affidavits from a total of 100 persons with disabilities were received at the meeting in Boston. A review of these statements indicated that many were signed in 2003 and 2004 and described incidents that occurred between 2000 and 2004. To get a better sense of recent issues, we identified 40 affidavits that described service issues from late 2004 through 2005. The majority of these statements described issues related to using the fixed route system. They detailed problems with elevators, bus lifts, and employee attitude and assistance. Several other issues were also noted. Each of the 40 statements described numerous incidents and problems. A summary of the fixed route issues noted in these affidavits is provided in Attachment B. Public Meetings A series of six public meetings throughout the MBTA service area were held in the fall of 2005. The main objective of these public meetings was to get feedback on the effectiveness of accessible fixed route and paratransit services and to identify the major accessibility issues in each mode. Meetings were held in each of four suburban regions – Lynn (North), Newton (Northwest), Norwood (Southwest), and Quincy (South) – as well as in downtown Boston. A mix of meeting times was used to allow for input from riders who work during the day as well as from seniors and other riders who might be less likely to attend an evening meeting. One meeting was held in the evening (6-8 pm), two during the late afternoon (4-6 pm), and two during the mid-afternoon (2-4 pm). Following the five planned public meetings, one additional meeting was held with agency staff and riders on the North Shore. This meeting was held at the request of the Independent Living Center of the North Shore and Cape Ann (ILCNSCA), which contacted project staff and noted that some riders in the area had been unable to attend the meeting in Lynn. This additional meeting was held on December 13, 2005. A total of 152 people attended the six meetings. A summary of the comments received at these meeting regarding fixed route service accessibility is provided in Attachment B. A brief two page questionnaire was distributed to all attendees of the public meetings. The questionnaire asked attendees to rate their experience with six general areas of fixed route service. Sixty-seven attendees turned in a questionnaire. The results of the survey are summarized in Figure 1.1. Figure 1.1 - Fixed Route Access Issues Identified by Public Meeting Attendees (Editor’s note: For each possible issue, this chart shows the number of people who either responded “A lot of problems,” “Some problems,” “No problems,” and “Not Sure.”) Bus driver/train attendant assistance; 11 A lot of problems; 17 Some Problems; 7 No Problems; 2 Not Sure Finding Bus Stops; 6 A lot of problems; 17 Some Problems; 11 No Problems; 3 Not Sure Getting on and off bus; 5 A lot of problems; 17 Some Problems; 13 No Problems; 3 Not Sure Getting on and off Trains; 7 A lot of problems; 11 Some Problems; 15 No Problems; 2 Not Sure Getting in and out of Train Stations; 5 A lot of problems; 21 Some Problems; 8 No Problems; 1 Not Sure Getting information about services; 8 A lot of problems; 21 Some Problems; 10 No Problems; 2 Not Sure The service areas identified as most problematic were getting information about service; driver train attendant assistance and getting in and out of stations. Twenty-nine of the 41 attendees who completed this part of the questionnaire indicated either a lot of problems or some problems with getting information about services. Twenty-eight attendees cited some or a lot of problems with driver/train attendant assistance. The third most common problem was getting in and out of train stations, followed by locating bus stops and getting on and off of buses. Summary of Public Input Received Many of the comments received from riders and the public reinforced earlier understandings. Several comments, though, raised additional issues that were not previously identified Comments confirmed that elevator condition and reliability, and public information about elevator outages, were major issues. There were many comments related to elevator outages, cleanliness, inaccurate public information about elevator outages, or difficulty getting information about outages and alternative routes. Elevator reliability was one of the most common areas of concern identified at the public meetings. This suggests that elevator reliability, cleanliness and information should remain a high priority of future monitoring and service improvement efforts. There were also a number of comments about issues related to elevator use. There were concerns about the path-of-travel to elevators - the major issue being that elevators were in remote, isolated locations that were hard to locate and a security concern. Several people with vision disabilities said they had difficulty using the elevator buttons and controls. More standardization of button and control layouts was suggested. Riders also commented that some elevators did not adequately signal or identify the floor levels served, making it difficult to use the elevators. These additional issues should be considered in future design and construction. One rider with limited fine-motor skills suggested that the elevator hotline have a voice activation option to give riders with this type of disability an easier option for getting information. Options on the hotline could be accessed by either pressing a certain phone button or saying a particular word. There were also a number of comments on poor reliability of escalators. One suggestion was made to repair and service escalators during hours when stations are closed. Reliability of bus lifts and ramps was another common topic of comment. There were a large number of comments on broken lifts, malfunctions of lifts that caused serious safety problems, and operation of buses with inoperable lifts on routes that were designated as accessible. Commenters generally felt the new low-floor ramp-equipped buses were a better option, but three people commented on the limited space on the low-floor buses, and several noted issues with using low-floor buses if drivers did not kneel the bus to lessen the slope of the ramp. The need for improved entrance hand-rails on these buses was also noted. One person with a vision disability said that the outer-edge of the ramps is not detectable. This input seems to support continuation of the MBTA’s program to replace lift equipped buses with low-floor, ramp-equipped buses. Comments also indicate a need for additional attention to bus design, including interior space. While the working condition of accessibility equipment was a major concern, driver performance, assistance, and sensitivity was a more significant issue. The most common specific concerns were that drivers did not adequately secure riders who use wheelchairs; that drivers did not kneel buses when requested; drivers did not curb buses even though there appeared to be space to do so; drivers did not properly enforce the priority seating policy and request other riders to move; drivers pulled away from stops before riders were seated or drove too fast; and drivers did not appear to notify dispatchers when they told waiting riders that the lift did not work. Driver related issues mentioned less frequency included: drivers passed by customers who use wheelchairs; did not provide assistance up and down the ramps, and refused to deploy lifts for riders who had an ambulatory disability but did not use a wheelchair. Riders who are blind noted issues with drivers not pulling up to designated stops (making orientation difficult) and leaving them off in the street in an unsafe setting. General comments about driver sensitivity and attitude were received from a significant number of commenters. While several people noted that most drivers were very good, and two people commended drivers’ general performance, there were a substantial number of comments on rude or insensitive treatment by drivers. The comments on drivers suggest that increased efforts to monitor driver performance and to provide additional training, retraining or other remediation are needed. Comments on gaps between passenger platforms and train entrances, confirms that this is a problem for many customers. Several commenters noted other, less obvious difficulties using rapid rail and light rail services. People who had issues with balance said that train operators, particularly on the Green Line, close doors too soon and that having doors close on them is a real concern. Other issues included inoperable wayside lifts on the Green Line, doors that only open half way on rapid rail cars and Green Line operators passing customers waiting on raised platforms. These comments suggest a need for monitoring of wayside lift condition and train operator performance, particularly on the Green Line. Several people commented on difficulties related to commuter rail mini-high platforms. Most people were concerned about the long walking distances are at some stations. One person also said that he has difficulty knowing which car to board at North Station to then have access to the mini-high platform where he disembarks. There were a large number of customer comments on public announcements including on-board stop announcements, external bus announcements at bus stops identifying the bus route, and in-station announcements. Several commenters noted that stop announcements had been improving and specifically cited the new automated announcement systems as an improvement. Many people indicated, at the time of the public meetings, that announcements were still inconsistent and sometimes inaudible or unclear. All of these comments support continuation of the MBTA’s program to install automatic Public Address (PA)/ Variable message sign (VMS) systems on buses and trains. Comments appear to suggest that continued monitoring of announcements is needed. Additional comments related to stop announcements that should be considered further include: the need to announce, at certain stations, which side of the train to exit to get to elevators; increased attention to in-station platform announcements, particularly on the Red Line; checks of PA systems (including the volume) by bus drivers and train operators; and in-station and on-vehicle announcements about elevator outages. Several people raised concerns related to bus stop accessibility. Riders who are blind noted problems with bus stop detectability. It was suggested that a simple, inexpensive and uniquely textured item be attached to bus stop poles (at a standardized height) so people who are blind could identify a stop. Riders also noted the need for more benches and shelters at bus stops. Others noted that bus stop signs were sometimes missing. The most common general comment concerned the complaint process and resolution of fixed route issues. Several people noted a lack of response or inadequate responses to complaints. Some people also mentioned difficulties in settling issues that involved damage to their wheelchairs. Other access issues raised in the public meetings, included: a need for more obvious priority seating signage on rapid rail cars; concerns about the accessibility of the new fare system for people who have vision disabilities; the possible impact of the new fare system on staffing at stations (a lack of staffing being a particular issue for riders with disabilities who may need to seek assistance); and a need to do more in the way of general public information and announcements. Several people indicated a need for better public information in general, while two people suggested more frequent general announcements concerning policies related to serving riders with disabilities. It was felt that this might serve to educate the public about the needs of riders with disabilities and improve public understanding of stop announcements, lift and ramp use, and other policies and practices. |