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1.4. Accessible Fixed Route Service Observations
This section of the report addresses the maintenance and operation of stations and passenger equipment as related to provision of service that is accessible and usable by people who have disabilities. This section of the report is organized in three major areas:


  • Stations – this section focuses on the maintenance of station features necessary for independent use by people with disabilities. Elevator equipment and Public Address/Variable Message (PA/VMS) were specific areas of focus.

  • Vehicles – particular areas of focus were maintenance of lifts and ramps and operator training

  • Public Communication – three areas of communication were addressed in this section: the usefulness of public information materials in permitting people who have disabilities to independently use transit service, the adequacy of stop announcements and route identification at stops shared by multiple routes; and real time service information that affects the ability of people who have disabilities to effectively use transit service.

As applicable for each of these areas, this section of the report presents regulatory requirements, MBTA policies and procedures relative to the regulations and analysis of performance. These issues are more fully presented in Technical Memorandum #4 – Fixed Route Service Access, November 4, 2005.


The overarching requirements for system maintenance and operation are addressed in federal and state regulations as presented below.
USDOT ADA and Massachusetts Architectural Access Board (MAAB) Regulatory Requirements
The USDOT regulations implementing the Americans with Disabilities Act of 1990 (ADA) requires that all accessibility components of the transit system be maintained in operating condition. 49 CFR Part 37, Section 37.161 Maintenance of Accessible Features, states that:


  1. Public and private entities providing transportation services shall maintain in operative condition those features of facilities and vehicles that are required to make the vehicles and facilities readily accessible to and usable by individuals with disabilities. These features include, but are not limited to, lifts and other means of access to vehicles, securement devices, elevators, signage and systems to facilitate communications with persons with impaired vision or hearing.

The Massachusetts Architectural Access Board (AAB) has also adopted a number of regulations regarding accessibility to transit stations. The AAB is a regulatory agency within the Massachusetts Executive Office of Public Safety. Its legislative mandate states that it shall develop and enforce regulations designed to make public buildings accessible to, functional and safe for use by, persons with disabilities.


Stations
The discussion of station maintenance is organized with one section for each transit mode with elevators and PAVMS discussed separately.
Bus Rapid Transit (BRT)
The new Silver Line BRT system consists of 24 stations, three in subway, and 21 surface bus stops. All Silver Line service is provided using low floor buses equipped with ramps for wheelchair access. Vehicle ramps can be operated manually if the automated deployment fails. The Silver Line currently operates on two separate alignments. All stations on the southern section between Dudley Square in Roxbury and Downtown Boston are on surface streets. The northern section, from South Station to South Boston and Logan Airport has subway stations at South Station, Courthouse, and World Trade Center. The remaining stations in South Boston and at Logan Airport are surface stops.
The use of ramp equipped low floor vehicles should assure full station accessibility for people with mobility impairments at all of the 21 surface stops. Since ramps can be operated manually when there is a mechanical failure, people with mobility impairments should receive the same level of service as the general public. Access to the three subway stations is dependent on operation of the station’s elevators. Maintenance of elevators is addressed in a later section of this report.
Commuter Rail
The MBTA’s commuter rail system consists of 125 stations, 84 (67%) of which are accessible. Accessible stations allow people with disabilities to board with level boarding either via mini-high platforms or full length high platforms. Bridge plates are used at all accessible stations to span the gap between the station platform and the entry vestibule in the passenger car. Horizontal gaps that exceed three inches result from preserving clearance for freight cars which are wider than passenger cars. Excessive gaps can also result from stations on curves and wear to track and vehicle suspension systems. Bridge plates are stored on most coaches for use at stations with normal horizontal gaps between platforms and car vestibule of up to 6”. These bridge plates are 11” deep. For stations that have larger gaps, such as stations on curved track, the bridge plates are chained to the mini-high platform. Theses bridge plates can be up to 30 inches deep.
Stations that require elevators for access to passenger platforms are listed below. Lynn station is an elevated station accessible by one active elevator. Framingham also has two elevators that serve a bridge between the passenger platforms on either side of the tracks.
Table 1.9 - Commuter Rail Elevator Responsibility

(Editor’s note: Data in the table is presented in the following order:

Line; Station; Number of Elevators; Maintenance Responsibility)

Rockport; Lynn; 1; MBTA

Lowell; Lowell; 0; Lowell RTA

Lowell; Anderson; 0; Mass Port Authority

Worcester; Worcester; 0; Worcester RTA

Worcester; Framingham; 2; MBTA

Providence; Route 128; 2, Amtrak

Providence; Providence; 0; Amtrak


Public Address (PA) systems are provided at North Station, South Station and Back Bay Stations. According to MBTA managers these PA systems are not operational. Variable message signs (VMS) are provided at all but several stations that have low passenger volumes. The VMS at North and South Stations are controlled by station personnel. The signs on the north side of Boston are centrally controlled by north side Commuter Rail dispatchers. Signs on the south side are controlled by a south side dispatcher.
Inspections and Maintenance
Principal responsibility for station inspections belongs to the MBTA’s commuter rail service contractor. Contractor personnel inspect each station at intervals of approximately two weeks. In addition if there is a complaint regarding station conditions, the contractor will inspect the station. The contractor uses forms to record the results of inspections. The inspections include checks of elevators and VMS equipment. If an elevator deficiency is identified the contractor will notify the cognizant party as listed in Table 1.9. For MBTA maintained elevators, the contractor will notify the MBTA’s Maintenance Control Center (MCC). MBTA Commuter Rail Transportation staff will also inspect stations as an element of contract oversight. Oversight inspections focus on stations where construction work is being performed, stations that have had maintenance problems and heavily used stations. These stations are inspected about once a month. Other stations are sampled randomly about twice a year. Although less structured than contractor reviews, the MBTA reviews do include cursory inspections of elevators and VMS. Problems with stations are also identified and reported by train personnel and by the public. It is recommended that station inspections conducted by the MBTA be scheduled at regular intervals with observations recorded on a form that is compatible with that of its operating contractor.
The accessible commuter rail stations are generally not subject to mechanical failure (preventing boarding) due to few elevators in the system and level boarding via mini-highs or full length platforms. Vehicle access via level boarding and mini-high platforms with bridge plates provides a reliable method of train boarding.
When problems are identified with elevators and other elements that are the responsibility of others to repair, there appears to be no mechanism for tracking the repair. The MBTA should consider a methodical tiered inspection of stations with major stations (North, South, Back Bay and Route 128 inspected daily), and medium and small stations inspected at greater intervals. Also, if MBTA staff used the same station inspection forms used by the contractor that would permit a comparison with the contractor’s most recent inspection form and serve as a better evaluation tool than notes on the condition of the station.
Procedures for snow removal are addressed in the MBTA’s Railroad Operations Snow Management Plan. The MBTA goal for the commuter rail system is to have all stations and parking lots clear within 24 hours after the cessation of snowfall.
Snow removal begins when a snow emergency is declared (when 2 inches have accumulated and 4 inches are forecast or in icy conditions). Platforms are treated first and parking lot driveways second. The plan makes no reference to paths leading to/from platforms. The plan includes crew assignments for each of the MBTA stations and commuter parking lots. The crews are a combination of MBTA Commuter Rail contractor staff, parking lot tenants, town public works departments, other public agencies, MBTA facilities staff and private companies. The commuter rail contractor has principal responsibility for stations, while parking lots are usually the responsibility of others. Within 48 hours of the storm the MBTA section chiefs and their counterparts for the contractor meet to review, among other things, the general conditions of station platforms and parking lots.
It is recommended that the Railroad Operations Snow Removal Plan be revised to specifically mention clearing paths of travel between platforms and the public way (streets, sidewalks, parking lots).
Light Rail
The light rail system consists of the Green Line with four branches and the Mattapan Trolley which operates from the Ashmont Red Line Station to Mattapan Square using Presidential Conference Committee (PCC) cars manufactured in 1945-1946.
The Green Line has 70 stations, of which 25 (36%) are accessible. Accessible stations have low platforms, raised (mid-level) platforms or mini-high platforms. Currently both high floor and low floor vehicles operate on the Green Line. At most accessible stations with low level and raised platforms, access to high floor light rail vehicles by people who use wheel chairs is provided using portable lifts. All accessible stations have portable lifts. In addition Lechmere, Brookline Village and Heath Street Stations have mini-high platforms. At stations with mini-high platforms bridge plates are used to span the gap between platform and the entrance of the high floor car. The raised platforms are designed for use with ramp-equipped low floor vehicles. Low floor vehicles (Type 8 cars) have ramps that extend out from the vehicles to the raised (mid level) platforms. The ramp slope is too steep for use at stations with low-level platforms.
Use of raised platforms with ramp equipped low floor vehicles (the Type 8 car) should reduce time for boarding and alighting passengers and facilitate Green Line access for people who use wheelchairs.
The MBTA operates train sets of one, two or three cars. The eventual goal is that at least one Type 8 car per train will provide accessibility by way of the vehicle mounted ramp. As of mid-2005, 40 out of the 210 light rail vehicles (LRV) in service were low floor. Use of portable lifts, or mini-high platforms was still needed to board most trains at accessible stations. Even after one car per train is accessible with ramps and low floors, the portable lifts, mini-high platforms or other means will have to be maintained at accessible stations served by the 20 Type 7 cars built in 1997. Access to those vehicles may be needed in the event that there are no available positions for wheelchairs on the Type 8 car/s on the same train.
The Mattapan Trolley operates with 10 restored PCC cars. The two terminal stations, Ashmont and Mattapan, are accessible using portable lifts. The other stations on the Mattapan Line are not accessible.
Inspection, Maintenance and Operation
Portable lifts and mini-high platforms are the principal accessibility features at surface stations. PA systems at the surface stations on the Green Line are currently disabled.
MBTA Inspectors inspect Green Line central subway stations (Lechmere to Prudential and Kenmore) daily. The procedures for inspection and maintenance of stations, including accessibility features are the same as described in the Rapid Rail discussion below.
If not currently done, portable lifts should be cycled daily at all accessible stations during station inspections to assure that they are in good operating order.
Outdoor pathways at stations must be kept clear of snow and ice to be accessible and usable by people with disabilities. MBTA procedures for snow removal are addressed in its “Snow Plan.” The most recent version of the plan is for the years 2004 to 2005.
Removal of snow and ice at leased MBTA parking facilities on the rapid and light rail systems is the responsibility of the facility operator. During snow emergencies, supervisors for each line (Blue, Green, Orange and Red) are to communicate directly with the MBTA Superintendent of System Services.
Snow removal is activated by a National Weather Service “storm watch” or prediction of two or more inches of snow. If the snow plan is activated between 6:00 PM and 12:00 midnight the parking operator’s equipment and crews are required to report on site by midnight. At all other times the crews are required to report on site when the plan is activated. The crews are to remain on site until all snow, slush and ice has been removed. Crews are to clear all travel lanes and to apply salt as needed.
The MBTA’s cleaning contractors are responsible for snow removal at stations platforms, public walk ways and out door areas of rapid rail stations, the Mattapan Line, Riverside Line and Green Line subway. The MBTA’s Maintenance of Way Department is responsible for snow removal at surface Green Line stations on the Beacon Street, Commonwealth Avenue and Huntington Avenue Lines.
Rapid Rail
The rapid rail system has 53 stations: 22 Red Line (not including Mattapan high-speed line), 19 Orange Line, and 12 Blue Line. Currently, 47 (85%) of these stations are accessible.
All Orange Line stations are accessible. Nineteen Red Line stations are accessible. The three inaccessible stations are: Fields Corner, Shawmut, and Wollaston and all but Wollaston are currently being modified to provide full accessibility.
Eight of the Blue Line stations are accessible. The four inaccessible stations are Bowdoin, Government Center, Maverick, and State. Bowdoin will be closed permanently with the reconstruction of a new Government Center Station. Accessibility improvements at State and Maverick are currently under construction. As per the MBTA 2006-2011 Capital Investment Program, Government Center is scheduled for construction between 2005 and 2008.
Almost all rapid rail stations have elevators to provide access to train platforms. Many of the subway stations have mezzanines requiring a passenger to take two elevators: one from street to mezzanine and one from mezzanine to the train platforms.
The MBTA provides audio announcements at stations at approximately 175 rapid rail, light rail and bus way locations with more than 300 audio amplifiers, and 2,000 loud speakers. The MBTA is installing coordinated public address-variable message signs (PAVMS), which permit both auditory and visual communication of service messages, at North, Airport, Aquarium, Porter Square, Downtown Crossing and Back Bay Stations. The MBTA is in the process of replacing the existing signs with new signs compatible with the new system, which includes Head End equipment. Future plans include installation of PAVMS at other stations as they are modernized and funding becomes available.
Inspection & Maintenance
Inspection of PAVMS equipment and other station features are among the duties of Inspector’s. Inspectors are also responsible for responding to incidents in assigned stations, addressing unsafe conditions that may arise, assisting with service problems, and overseeing handling of station revenue. Inspectors, who work in the transportation department, report to the Supervisor of the transit line to which they are assigned. Inspectors are assigned to two to four stations with the number varying based upon proximity of stations to each other and time of day, with evening Inspectors covering more stations than day time Inspectors.
Inspectors inspect stations, including elevators, elevator components, escalators, public address system, lighting, other safety features and all station areas. The report is used to guide the inspection and report the results. Problems not specified on the report form, such as snow and ice on pedestrian paths or vandalism, are reported in the Additional Comments Section of the report. Procedures for snow and ice removal are also addressed in the MBTA’s Snow Plan. One daily report is completed for each station. The report is temporarily stored in the Inspector’s office, or safe area. The Inspector for each shift uses the same report, entering the time of each inspection and the Inspector’s badge number and signature. Inspectors turn in completed Station Reports to the Line Supervisor at the end of the work day; and the reports are stored at the Supervisor’ facility. Each Inspector is assigned a portable radio for communications.
When the Inspector reports to work before the beginning of the service day, he/she inspects all of the assigned stations. The inspection is completed before the station is opened for service. If the Inspector identifies a problem he/she notifies the Maintenance Control Center (MCC) by portable radio. The MCC is a seven day per week, twenty-four hour per day communications control, receiving, and dispatch center for all transit system maintenance functions. For some problems, including elevators out of service, MCC provides the Inspector with a work order number, which the Inspector records in the Station Report. In addition to the initial daily inspection the Inspector’s procedure is to spot check the station, including elevators, each hour during the service day, if he/she is available to do so. In practice, spot checks are often made less frequently than hourly since the Inspector gives priority to addressing incidents, safety problems, service issues, etc. Any time a problem is observed during the hourly checks, the Inspector reports the problem to MCC by radio. During such checks if the elevator is off and the Inspector discovers, upon calling MCC, that it had not been reported as out of service, the Inspector will test the elevator and, if it is working return it to service. Inspectors, beginning shifts later in the day, inspect each of their assigned stations, as was done by the morning Inspectors, update the Station Report information and enter the time, badge number and date. Through the day, two or three Inspectors may be assigned to one station.
Collection and reporting of information gathered through inspections requires multiple handling of information to enter station defects into the MCRS system. The Inspector observes the station, enters the information onto the station report, reports the information to MCC by radio, and MCC enters the information into MCRS. It may be worth considering the use of personal data assistants (PDA) to more methodically capture the inspection results and reduce the amount of communication. The Inspector would record the inspection results on a Daily Station Report in the PDA and transmit the report directly to a module in the MCRS system either with a wireless transmission or through a hard wire connection within the transit system. Use of personal data assistants (PDA) by station inspectors to record and report the results of station and elevator inspections directly into maintenance system software could reduce potential error caused by multiple handling of information and expedite reporting of elevator status. The direct data entry would also reduce the labor effort of recording it more than once. Additionally, the electronic PDA reports will provide a record affirming station elements that pass inspection rather than limiting the reports in MCRS to exceptions, or station elements in need of attention thereby providing more complete reporting.
When facility and station equipment problems are reported to the MCC they are entered into a Maintenance Control and Reporting System (MCRS). Through the use of this system, maintenance supervisors issue work orders assigning staff to inspect and repair each identified deficiency.
Snow removal procedures for rapid rail stations are addressed in the paragraphs on Light Rail station maintenance. Elevator inspection and maintenance is more fully discussed later in this section.
Elevators
The MBTA operates a total of 114 elevators at all rapid rail, light rail, and Silver Line stations, including all elevators at joint commuter rail stations in Boston. Additionally there are elevators at 7 other commuter rail stations. Six of the commuter rail stations and their elevators are maintained by parties other than the MBTA. The MBTA maintains the active elevator at Lynn Commuter Rail Station.
Maintenance of most elevators less than one year old is the responsibility of the manufacturer under warranty. For all other subway system elevators, the MBTA contracts for elevator and escalator maintenance services. The elevator maintenance contractor is responsible for maintenance of all MBTA subway system (light rail subway and rapid rail stations) and the commuter rail stations as identified above.
Inspection, Maintenance and Operations – As discussed in the Rapid Rail Facilities section of this report, the MBTA Inspector has primary responsibility for inspecting and reporting inoperable elevators. If the Inspector identifies a problem, he notifies the MCC by portable radio and MCC enters the information on the inoperable elevator into the MCRS system. During the day anyone, including the general public, can report a broken elevator by calling a number listed at each elevator.
In addition to MBTA Inspectors, the MBTA maintenance contractor is required to thoroughly inspect all ADA fixtures, appliances, devices, components and equipment and perform repairs
identified during these inspections, as required. Contractor inspections are performed on a monthly basis (Systematic Preventative Maintenance, Service, Repair, Inspection and Testing Work III.A.1. and B.1). Preventative maintenance (PM) inspection and repair is conducted only during regular MBTA service hours. Regular PM requires the elevator to be out of service for several hours. According to MBTA managers the PM inspections are also performed during service calls. At most accessible stations removing an elevator from service makes the station unusable for people who use wheelchairs. Consideration should be given to performing preventive maintenance during non-service hours in order to avoid disruption to customers.
The contractor’s maintenance data for the month of June 2005 was reviewed to identify the pattern of maintenance on MBTA station elevators. MBTA managers indicate that the reported information is not fully reliable and does not include all service performed. The MBTA is working with the contractor to more reliably record and report maintenance activities. Although the information in the contractor’s report is not perfectly accurate it does provide some indication of performance. Of the total number MBTA elevators approximately 10 % were under warranty and not the responsibility of the maintenance contractor. According to the contractor’s report, of the remainder approximately 80% received service and approximately 20% of the elevators did not receive PM service during the month of June.
Based on the contractor’s report, for each elevator serviced there was an average of more than 3 service calls. Approximately 67 % of the service calls were repeat calls to the same elevator with three or more service calls made to 40% of the elevators serviced. It appears that based upon this limited review maintenance efforts are weighted to servicing problem elevators and away from regular preventive maintenance inspections. Aggressive preventive maintenance can often avoid problems that result in elevator outages. Accordingly it is suggested that the MBTA emphasize preventive maintenance to minimize potential problems, particularly with an older complement of elevators.
Among the most serviced elevators were Back Bay (17 days), Park (11 days), Lynn (10 days), Quincy Adams, Quincy, JFK-UMass, Mass Ave., Forest Hills, and Wood Island.
Other PMs are not reported to the MCC and accordingly not entered into MCRS. Because of the time lag from initiation of PMs to publicly announcing the elevator as out of service the PM would often be completed before the public announcement is made. Additionally, elevators may be available for public use for some of the period that PMs are being performed. Since PMs are not reported to MCC, there is no record of them in the MCRS reports.
The elevator maintenance contractor is required to coordinate all work efforts with MCC. The contractor has direct access to the MCRS module for elevators. The contractor frequently reviews MCRS for work orders for elevator repairs entered by the MCC. Work orders effectively instruct the contractor to inspect and repair elevator defects. The contractor has 24 hours to complete repairs to elevators from the time the contractor is notified.
The contractor performs the repair and documents any and all contract service work into MCRS. This includes closing the work order in MCRS within 15 minutes of completion of the repair.
Maintaining the inventory of elevator parts for the MBTA elevators presents a challenge. The elevators have been manufactured by 15 different makers, and some of the elevator models are quite old. Stock items do not typically cause a delay in returning elevators to service. However obtaining special order parts can cause a delay in returning an elevator to service. Because of the age and uniqueness of the elevators, parts are sometimes difficult to find. Also, street elevators generally have a greater maintenance needs than weather protected interior elevators.
There is no official policy or procedure to provide alternative service when an elevator is inoperable. However, OCC staff indicated that when a customer, who uses a wheelchair, requests assistance from a station employee, and a reasonable alternative route is not available, the MBTA would dispatch a full size bus to transport the customer. Additionally, during long term elevator outages the MBTA provides alternate transit service. The practice for providing alternate service when an elevator is unavailable should be incorporated into a formal procedure to avoid miscommunication and expedite provision of alternative transportation service when appropriate. This procedure should address how information about alternate service will be effectively communicated to riders.
Elevator availability rate for the subway system as reported by the MBTA for the first calendar quarter of 2005 (January 1 through March 31) is presented in Table 1.10. The report presents the status of the elevators at 6:00 AM each day, presumably after they have been inspected by the MBTA Inspector. The reports don’t reflect elevators that may be removed from service and returned to service during the day for preventive maintenance, as discussed above. During this period overall elevator availability was 90% with weekly averages ranging from 86% to 95%.

The best availability was on the Blue Line at 97% with a weekly range from 91% to 100%. The worst performance was on the Red Line with an overall availability of 83% and a weekly range of 74% to 97%.

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