January 20, 2009
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-11111
Re: Comments to Access Board Docket No. 2007-1
36 C.F.R. Part 1192
American with Disabilities Act (ADA) Accessibility Guidelines for Transportation
Dear Chairman Justesen and Members of the Board:
The Metropolitan Transportation Authority (“MTA”), a New York State public benefit corporation and its subsidiary and affiliated transportation operating agencies (collectively “MTA Agencies”), submit these comments to the Architectural and Transportation Barriers Compliance Board (hereinafter the “Access Board”) in response to the request for comments on the draft revisions to subparts A & B of 36 C.F.R. Part 1192, which provides accessibility guidelines for transportation vehicles, including buses and vans.
The MTA Agencies
The MTA is a public-benefit corporation chartered by the New York State Legislature in 1965. Through its operating agencies, the MTA coordinates the planning and general policy direction of most of the public transportation serving the New York City metropolitan region. The MTA approves operating and capital budgets and performance plans, carries out the financing of capital programs, and monitors financial and operating activities. Six of the agencies serve the public by providing transportation services and implementing capital construction projects. The seventh, MTA Capital Construction, oversees construction of MTA security projects, manages major capital expansion and downtown Manhattan transit infrastructure projects.
The MTA operates its services through the following affiliated and subsidiary agencies:
• MTA New York City Transit (“NYC Transit”)
• MTA Long Island Rail Road (“LIRR”)
• MTA Long Island Bus (“LIB”)
• MTA Metro-North Railroad (“MNR”)
• MTA Bridges and Tunnels (“B&T”)
• MTA Bus Company (“MTA Bus”)
• MTA Capital Construction (“MTA CC”)
The MTA’s vast transportation network, North America's largest, serves a population of 14.8 million people in the 5,000-square-mile area from New York City through Long Island, southeastern New York State, and Connecticut. Through its operating agencies, the MTA moves more than 2.5 billion passengers a year - about one in every three users of mass transit in the United States and two-thirds of the nation's rail riders. In addition to operating the largest commuter rail and subway systems in the country, MTA’s bus fleet is comprised of 5,000 local and express buses as well as 1,700 paratransit vehicles, most of which are vans or small buses.
The MTA Agencies appreciate the opportunity to comment on the draft revisions to the Access Board guidelines in advance of the issuance of a notice of proposed rulemaking. Of particular concern to the MTA Agencies are the following issues: (1) the removal of the definition of “common wheelchair,” (2) decreasing the allowable slope of ramps to 1:6 when deployed, and (3) timing of implementation of automated stop announcement systems. As explained in further detail below, these changes are either not technically feasible or simply do not take into account the practical realities transit entities such as the MTA Agencies face in urban transit settings. In some cases, the proposed revisions simply ignore the essentially fixed dimensions of buses.
A. Definition of “Common Wheelchair” Should Not Be Removed From the Accessibility Guidelines
As MTA discussed in its initial letter, dated June 11, 2007, submitted to Mr. Dennis Cannon of the Access Board, MTA disagrees with the proposal to remove the definition of “common wheelchair” from the accessibility guidelines. This definition is useful because it provides transportation agencies with parameters to facilitate design and also provides guidance to customers who purchase mobility devices with the intention of using them on public transportation. There is currently limited guidance for transit agencies, wheelchair and mobility-aid users, as well as manufacturers, regarding the kinds and sizes of wheelchairs that are appropriate for public transit vehicles. This lack of guidance has resulted in the manufacture of larger and heavier powered wheelchairs and other mobility aids which, in many cases, cannot be boarded or safely secured on transit vehicles. For these reasons, MTA urges the Access Board to retain the definition at least until there is another way of ensuring that manufacturers of mobility devices and the riding public are provided adequate guidance on the types of mobility devices that are appropriate to use on mass transit vehicles.
B. Most Manufacturers Are Incapable of Meeting the Proposed Change in Ramp Slope
Revised Section T303.8.1 proposes a change to the ramp slope from 1:4 to 1:6. While this proposal is more manageable to meet than the original proposal of 1:8, MTA is aware of only two manufacturers of ramps that can currently meet this specification, but these are structurally more complex than current ramp configurations and, for that reason, have the potential of compromising transit operations. The existing ramp configuration, as detailed in MTA’s earlier submission, is a relatively simple and easy to maintain system that ensures a high degree of reliability. By contrast, MTA is aware of only two manufacturers able to meet the proposed ramp slope of 1:6. Both utilize a dual ramp configuration which in our view would be less reliable and more cumbersome to deploy and which may additionally lead to increased maintenance costs.
C. The Guidelines Should Permit a Phased Implementation of Automated Stop Announcement Systems for Major Intersections and Transfer Points
Sections T704, T705 and T706 (Automated Route Announcement Systems, Automated Stop Announcement Systems and Stop Request Systems) do not explicitly provide for a phased implementation, which is required. NYC Transit is conducting a pilot test which might satisfy MTA’s requirements in these areas. However, MTA continues to research alternative solutions and examine new products.
The final regulations should explicitly allow for a phased implementation timetable for meeting requirements, particularly for an operation the size of the MTA’s combined bus operation. Combined, NYC Transit, and MTA Bus Company have more than 6,100 buses and over 300 individual bus routes. The phased implementation could take several years, due to the need for the following:
§ Securing capital funding to equip buses.
§ RFP development, competitive bid and award, which may be in phases.
Implementation, preferably in smaller units, whether by depot, BRT corridors, etc. typically involves installing equipment on buses and at the affected depots, driving each bus route to be equipped, geo-coding stops in the field and testing and confirming the system’s performance.
§ Establishing a protocol for keeping bus stop locations up to date at a level required by this technology.
In addition, other large systems have not implemented such systems “all at once.” Rather, the systems are implemented as new buses are placed into service. The new buses are already equipped with GPS equipment and/or other hardware/software to easily accommodate automated bus stop and route announcement systems. Immediate compliance in these areas could be a major challenge for a majority of larger transit properties across the country and the concept of phased implementation should be given significant consideration.
D. Responses to Additional Questions:
In addition to the general MTA comments to the proposed revisions, the Access Board requested information regarding automated bus stop and route announcement systems. MTA provides the following responses to those questions applicable to MTA’s operations:
Question #2: How do MTA Agencies gather and store locations of bus stops (for internal or traveler information use)?
Answer: Staff enter each bus stop change that will be in effect for more than six months into a computer database. In the New York City area bus stops are changed routinely to meet various operational requirements.
NYC Transit issues schedules and prepares an electronic file containing bus schedules for every route and day of operation (weekday school open, weekday school closed, Saturday, Sunday). This file includes the bus schedule for each day and the bus stops in each direction. The bus stops are incorporated into an electronic file generated by the industry standard HASTUS scheduling package from GIRO in Montreal, Canada.
Bus stop changes are geo-coded onto a computer map using HASTUS GEO. The geo-coding is a desk exercise that ensures each bus stop is placed on the correct portion of the block-face on each side of the street — nearside, midblock or farside. There is no regular field survey on the street with GPS equipment to ensure that the nearside stop is in fact 50-feet or 100-feet from the cross-street line, although the HASTUS GEO software has the capability to insert a stop exactly where a geographic field survey would so indicate. At this time, changes to bus stop locations that relocate a stop from the nearside to the farside of the same intersection are also not reflected in the database. Long Island Bus has a similar database maintained in Trapeze software.
Once bus schedules and bus stops are completed in HASTUS, a customized software program generates an electronic file of bus schedules and stops (approximately 12,700 stops for NYC Transit) that can be distributed to other data consumers. The electronic NYCT bus schedule files are loaded into NYC Transit’s proprietary Trip Planner software. Data on MTA Bus’ 3,400 bus stops are maintained by NYC Transit’s Corporate Communications/Travel Information Center (TIC) for use in NYCT’s Trip Planner.
The NYCT Trip Planner is available on the web and is used by NYCT’s Call Center. Data for all three bus operations is also made available to MTA customers through Trips123 or other web-based third party applications that provide trip planning services.
Question #2.1: Does MTA have any experience building geo-located stop databases using off-the-shelf consumer equipment or free web-based solutions?
Answer: No, The MTA response to Question #2 details how geo-located stop databases are developed for customer and telephone information agent using proprietary software.
Question #2.2: Has MTA tested the data gathered this way to gauge its accuracy?
Answer: A detailed sample audit of the accuracy of the source bus stop data maintained by NYC Transit’s Bus Service Planning unit was completed in 2006. The results indicated that NYC Transit’s 12,700 bus stops are 98% correctly located. This database has formed the foundation of the data used by HASTUS GEO and ultimately by the Trip Planner software used by telephone information agents and on the Web by customers.
NYC Transit’s Corporate Communications/Travel Information Center Division also logs and categorizes customer complaints related to the roughly 300,000 monthly Trip Planner visits. In 2008, the Travel Information Center received 945 Trip Planner customer comments, of which, about 5 were complaints about inaccurate/nonexistent bus stop locations. MTA considers this to be a good indicator that inaccurate/nonexistent bus stops are not a major problem.
Question #2.3: Has there been any attempt to gather these data already for traveler information reasons?
Answer: The response to Question #2 above details how bus stop data are compiled for use in traveler information systems.
Christopher P. Boylan