Strategy Guide to Enable and Promote the Use of Fixed-Route Transit by People with Disabilities (2014)

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23 C h a p t e r 4 Another important “first step” is to ensure that fixed-route transit services are accessible and usable by people with disabilities. The various strategies suggested in subsequent chapters will not work if the fixed-route transit system is not accessible. And it would be disingenuous to encourage people to attempt to use fixed-route transit services if these services are not really usable. First and foremost, having an accessible fixed-route service means com- plying with the requirements of the ADA and the regulations issued by the U.S.DOT implementing the transportation requirements of the law. Regarding fixed-route transit facilities and vehicles used by public transit agencies, the law and regulations require that: • All new transit facilities be constructed to be accessible—that is, they meet the accessibility standards included in the regulation. • Any alterations to existing facilities be made so that the altered areas, as well as paths of travel to primary function areas, are accessible to the maximum extent feasible. • All new vehicles purchased for use in fixed-route transit service be accessible. • A good faith effort, which includes a nationwide search, be made to obtain accessible used fixed-route vehicles. • All fixed-route vehicles that are remanufactured be made accessible. Beyond making facilities and vehicles accessible, the regulations contain several “provision of service” requirements related to how facilities and vehicles are operated. These include requirements to: • Keep accessibility equipment in good working condition and make prompt repairs to non- working equipment. • Provide alternative transportation to persons with disabilities if fixed-route vehicles cannot be used because of broken lifts or ramps and the headway to the next accessible vehicle is more than 30 minutes. • Use lifts, ramps, and securement systems to accommodate riders who use mobility devices and provide assistance with the use of this equipment. • Announce stops on fixed-route services. • Have a system in place to allow riders with disabilities to identify the fixed-route vehicle they need to use, or to allow drivers to identify riders seeking to use their vehicles. • Provide accessible information and communications about transit services. • Accommodate service animals and portable oxygen. • Allow adequate time for persons with disabilities to board and alight from vehicles. • Ensure that employees are trained to proficiency in the operation of accessible equipment, in assisting people with disabilities to use the service, and in treating people with disabilities in a respectful and courteous way. Operating Accessible and Usable Fixed-Route Transit Services Make sure that fixed-route transit services are accessible, meet all ADA requirements, and are usable by people with disabilities before implementing strategies to encourage greater use.

24 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities The regulations also contain several “general nondiscrimination” requirements. These include a general provision that “No agency shall discriminate against an individual with a disability in connection with the provision of transportation service.” It also includes specific requirements related to nondiscrimination, including: • Not denying people with disabilities the right to use the services available to the general public, rather than special services that may be provided. • Not requiring people with disabilities to travel with attendants. • Providing priority seating, but not requiring people with disabilities to use the seats if they choose to sit elsewhere. This chapter provides recommendations related to several requirements. Section 4.1 addresses keeping vehicles and accessibility equipment in good working condition. It also suggests some strategies that go above and beyond the minimum regulatory requirements to accommodate the greatest number of riders with various types of mobility devices and to maximize the usability of vehicles and equipment. Section 4.2 offers suggestions for implementing the requirements to make stop announce- ments and to identify routes. These requirements continue to challenge many public transit agencies. Section 4.3 provides suggestions for employee training, key to making fixed-route transit services accessible and usable. Effective implementation of policies and procedures, and proper use of accessibility equipment, depends on thorough employee training. Finally, Section 4.4 discusses service monitoring. A strong and effective service monitoring program is critical to ensuring that policies and procedures are actually implemented and that fixed-route transit service is accessible and usable in practice. More detailed information about these and all of the ADA regulatory require- ments are available on the Civil Rights and ADA page of the FTA website at http://www.fta.dot.gov/civil_rights.html. A significant amount of technical assistance information for understanding and implementing ADA transportation requirements has also been developed by Easter Seals Project ACTION (ESPA). For a listing of available resources, go to http://www.projectaction.org. The DREDF, with funding from FTA, developed a very helpful series of Topic Guides for understanding and implementing certain aspects of the transportation requirements of the ADA. A link to the Topic Guides is provided on the FTA webpage noted above. Direct access through DREDF is also available at http://www.dredf. org/ADAtg. Two particularly relevant Topic Guides to making fixed-route transit services accessible are “Equipment Maintenance” and “Stop Announcements and Route Identification.” FTA is also working on an ADA Circular. Portions of the circular are scheduled to be released throughout 2013 and 2014. The circular will contain detailed information on requirements and implementation.

Operating accessible and Usable Fixed-route transit Services 25 4.1 Accessible, Usable, and Reliable Vehicles and Equipment For people who use mobility devices, fixed-route transit must accommodate their devices so that they can effectively use the service. For these riders, accommodation is more than providing accessible transit information, calling out stops, and the various other activities that define accessible fixed-route transit service; it also means ensuring that the riders’ mobility devices, including manual and power wheelchairs and scooters, can safely and reliably be accommodated on fixed-route transit vehicles. ADA Requirements for Fixed-Route Transit Vehicle Accessibility The ADA requirements spell out accessibility specifications for new and used fixed-route buses and new and remanufactured rail cars. 49 CFR Part 38 provides specifications that must be met to make a vehicle accessible. 49 CFR Part 37 provides the conditions under which vehicles must be purchased as accessible, or made accessible. To provide boarding for riders using mobility devices, buses and vans can be equipped with a lift or ramp. The ADA requirements detail specifications for these as well. The regulations require that lifts and ramps accommodate a rider and mobility device that together weigh up to 600 pounds. This weight threshold corresponds to the ADA’s original definition of a “common wheelchair”—a mobility device of three or four wheels that does not exceed 30 inches in width and 48 inches in length and does not weigh more than 600 pounds when occupied. The definition originated as a design concept but was applied as an operational concept as well. Over the years since the ADA was enacted, many different types of larger wheelchairs and wheeled mobility devices were developed. The size and weight of Americans, on average, also increased. Transit agencies encountered riders and mobility devices that exceeded the minimum required design standards with increased frequency. In October 2011, the original definition of a common wheelchair was changed through amendments to 49 CFR Parts 37 and 38. A wheelchair is now defined as “a mobility aid belonging to any class of three- or more-wheeled devices, usable indoors, designed or modified for and used by individuals with mobility impairments, whether operated manually or powered.” According to the amendments, the operational role of the “common wheelchair” is deleted. The amendments recognized that some transit agencies operate fixed-route transit vehicles that can accommodate a higher weight threshold, for example, up to 800 pounds. Transit agencies are now required to transport any rider and mobility device that exceed the common wheel- chair definition if the vehicle and lift/ramp can physically accommodate them, unless doing so is inconsistent with legitimate safety requirements. It is important to recognize that accessibility standards for vehicles and transit systems may be revised or updated periodically, based on technological or other changes. The U.S. Access Board develops the guidelines that are then adopted as legal standards by implementation agencies such as the U.S.DOT. Additional accessibility features include the provision of securement areas and securement devices. Requirements for securement areas depend on the size of the vehicle. Those 22 feet or less must have at least one securement area, which can be either forward or rear facing. Those greater than 22 feet must have at least two securement areas, with one forward facing and the second either forward or rear facing. Requirements for securement devices are also provided in the regulations, for example, a seat belt and shoulder harness must be provided for each securement location and these must be separate from the securement system for the mobility device.

26 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities Additionally, signage must be provided that states that the securement area is to be used by persons who use wheelchairs and mobility devices. Maintenance of Accessibility Features on Fixed-Route Transit Vehicles To ensure that accessible features and equipment are available for riders when needed, the ADA requires that transit agencies maintain those features in operable condition. This includes wheelchair lifts, ramps, kneeling mechanisms, automatic stop announcement annunciators, wheelchair securement devices on buses and vans as well as elevators and escalators, signage, fare payment equipment, public address systems, and other systems to facilitate communications with people with impaired vision or hearing. For fixed-route transit service, daily maintenance checks—pre-trip inspections—ensure that bus lifts and ramps are operating properly before entering service. On a routine basis, lifts and ramps should also be tested with a full load rather than without any weight. Pre-trip inspections are also the opportunity to check other accessibility equipment, such as wheelchair securement equipment and automatic stop announcement annunciators. When there are problems, accessibility features and equipment must be repaired promptly, with reasonable efforts to accommodate individuals with disabilities who would otherwise use the inoperable accessibility feature. Transit Agency Efforts to Accommodate Riders with Mobility Devices and Rider Feedback Since the passage of the ADA, transit agencies have undertaken efforts to improve how they accommodate riders with mobility devices. More than 60% of transit agencies completing the project’s survey have made specific equipment improvements. These include: • 38% of transit agencies provide riders with special straps they can permanently attach to their mobility device to improve on-board securement; • 15% worked with riders with disabilities to redesign the securement area and securement systems in the vehicles; • 18% worked with riders to improve the design of the lift or ramp; and • 25% have made “other” equipment improvements. The transit agencies believe that their equipment improvements have been effective, facilitating greater use of fixed-route transit by their riders with disabilities. Almost two-thirds rated their improvements as “effective” or “very effective.” Feedback from people with disabilities through the study’s survey efforts indicates that concerns about fixed-route transit’s ability to accommodate individuals’ mobility aids are not among the most important factors affecting decisions to use fixed-route transit, compared to other more important factors such as barriers in the pedestrian environment affecting access to bus stops and transit stations. However, those respondents who use only ADA paratransit and not fixed-route transit expressed more concerns about this issue than those who use fixed-route transit and those who use both fixed-route transit and ADA paratransit. These survey findings suggest that transit agencies might encourage greater fixed-route tran- sit ridership by ADA eligible riders by clearly showing how their fixed-route transit vehicles accommodate mobility devices. This might be done, for example, through marketing and informational materials targeted to people with disabilities; through a short video posted on

Operating accessible and Usable Fixed-route transit Services 27 the agency’s website; through “show and tell” presentations at locations frequented by people who use mobility devices; and through travel training that demonstrates how the fixed-route transit service can accommodate mobility devices. See Chapter 6 for suggestions on these types of efforts and programs. Trends in the Transit Industry and Mobility Device Manufacturers The accommodation of riders who use wheelchairs and other wheeled mobility devices is receiving greater attention as the types of mobility devices proliferate and as the size and weight of Americans, on average, increases. A Project ACTION report found that some improvements have been made in bus design to address issues associated with the farebox and other structures in the bus front that can impede wheelchair access. However, the trend toward low-floor buses with ramps rather than lifts can create space and maneuverability issues. (4) Large wheel- housings inside buses can restrict access to and from securement areas and make it more dif- ficult to turn around inside buses. Additionally, when ramps are deployed to the street, rather than to a sidewalk with a curb, the angle is steep and cannot be independently managed by some riders. (4) These and other related issues are being addressed in TCRP research through Project C-20, “Use of Mobility Devices on Paratransit Vehicles and Buses,” with research currently under review for publication. Some mobility device manufacturers have responded to the needs of people who use wheel- chairs and public transit with the provision of wheelchairs designed for use as a seat on a motor vehicle, including transit vehicles. These are known as WC19-compliant wheelchairs, built to specific safety standards for use on vehicles. However, these standards are voluntary and their adoption has been limited. (5) Ensuring Accessibility As noted above, the first step in ensuring accessibility is to meet the appli- cable ADA requirements for vehicles and equipment. But transit agencies can go further in ensuring that their equipment is usable for riders with mobility devices. Specifications Specifications for new vehicles and equipment should make clear the required accessibility features, rather than just stating that the vehicle must meet all ADA requirements in Part 38. Transit agencies might also consider whether they might exceed the ADA requirements for certain features. For example, a transit agency may find that specifying a longer ramp that mini- mizes slope may enable more riders with wheelchairs to use fixed-route transit rather than ADA paratransit. Obtain Public Input It is a good practice to seek input from riders with disabilities when determining the type of vehicle, or specific type of equipment, to procure. Some transit agencies have asked vehicle vendors to supply a “sample” bus or rail car that riders can test by actually boarding, maneuvering to the securement area, and using the securement system. Comments from riders can improve the design of vehicles and ultimately enable greater use of fixed-route transit. Specifications for vehicles and facilities should include detailed accessibility requirements rather than just stating they should be ADA compliant. To make fixed- route transit as usable as possible, consider exceeding minimum ADA requirements.

28 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities Transit Agency Approaches to Accommodating Riders with Mobility Devices Several approaches to the accommodation of riders who use mobility devices are highlighted below, addressing different aspects of fixed-route transit service accessibility. Securement Areas on Fixed-Route Transit Vehicles Requirements for securement areas depend on the size of the transit vehicle. Those 22 feet or less must have at least one securement area and those greater than 22 feet must have at least two securement areas. CCRTA in Corpus Christi, TX, has gone beyond the requirements and procures transit buses with three wheelchair securement areas. Since 2008, each 35′ and 40′ transit coach purchased by CCRTA has been equipped with three wheelchair securement positions. This strategy was adopted to address demand that often exceeded supply for fixed-route transit service by riders who use wheelchairs—demand that can be attributed to successful CCRTA initiatives to increase utilization of fixed-route transit services by people with disabilities. CCRTA’s efforts to increase utilization of fixed-route transit services by people with dis- abilities began in 1999, when its ADA paratransit fares were increased; prior to this, para- transit fares were the same as fixed-route transit fares. CCRTA next began to focus on ADA paratransit eligibility and education/outreach on fixed-route services, including bus familiar- ization training and travel training. In 2006, more stringent eligibility certification require- ments were implemented. In 2009, CCRTA began constructing accessibility improvements at bus stops. As a result of increased utilization of fixed-route transit services by people with dis- abilities, vacant wheelchair securement areas were often unavailable in off-peak hours of service. The need for additional wheelchair capacity on fixed-route transit service came into focus when, during bus familiarization training, the trainer attempted to board a fixed-route bus with a new rider using a wheelchair, only to find the two securement positions already occupied. The strategy to add a third securement position to new bus purchases was chosen following considerable input from and discussion with CCRTA’s Committee on Accessible Transportation (an advisory board to the agency that includes perspectives of people with disabilities, human service agencies, and advocacy groups) as well as CCRTA’s Operations, Maintenance, and Safety Departments. Once the decision was made to pursue this strategy in 2008, the Maintenance Department approached the manufacturer of CCRTA buses (that were on order at that time), and worked with them to revise the interior seating configuration specifications. CCRTA also sent several operators to the manufacturing plant in California to offer input on the design, to maximize the ergonomics and operating effectiveness. The design ultimately accommodated the third position and 31 standard seats in a 40′ bus—the same number of seats as CCRTA has previously procured with two securement positions. This was a lengthy process but resulted in specifi- cations that CCRTA has continued to use with minor modifications. Two of the wheelchair positions are located on the roadside of the vehicle, while the third is on the curbside. The incremental cost to install the third securement position is approximately $1,200 with standard securement devices. As of December 2012, 31 of CCRTA’s 72 transit coaches accommodate three wheelchairs. In 2010, CCRTA began procuring an upgraded securement system in its new vehicles. The new system uses three-point securement, with features that include, among others, a

Operating accessible and Usable Fixed-route transit Services 29 remote release for the rear retractors and a stabilizing bumper designed to prevent tipping. Using this system, a wheelchair can be secured in about a minute and released in even less time. Upgrading to the new system costs an additional $5,000 total for the three securement areas. The additional cost is considered by CCRTA as a worthwhile investment. While installation of three of the new securement systems in a bus reduces the seating capacity by two, due to the structure of the new system, which must be installed forward facing, the buses can still accommodate the same total number of passengers including standees. The speed of using the upgraded system has proved to be very helpful in mitigating the one drawback experienced with the third securement position: an occasional need to “juggle” passengers using wheelchairs in situations when an oversized mobility device is secured on board and blocks the path for another wheelchair user between a securement position and the bus lift/ ramp. In such cases, it can be necessary to deboard the passenger in the oversized chair to allow another wheelchair user to get to or from another securement area. CCRTA has not identified a straightforward solution, since boarding and deboarding order varies with each passenger’s individual trip. When a passenger using a wheelchair boards, the operator asks where they are headed and tries to place them strategically (e.g., the largest wheelchair positioned furthest back), but this is not always feasible. Anecdotally, CCRTA continues to experience occasions when a fourth wheelchair user desires to board, although data are not currently tracked on such incidents. CCRTA feels, though, that a fourth securement position would not be viable within the dimensions of a 40′ transit coach with current exit door configuration. Overall, CCRTA feels that the benefits of the third wheelchair securement position and upgrading to the new securement system have completely outweighed any occasional draw- backs and financial considerations. While some operators initially found the third position to be onerous, the investment in the securement system technology has significantly improved operations in this regard. More passengers who use wheelchairs can now reliably access fixed-route transit—and they are doing so, as evidenced by the wheelchair ridership increases. Fixed-route wheelchair boardings have quadrupled since 2006 (when CCRTA began tracking this data), from 27,475 in 2006 to 110,961 in 2012. Overall system ridership grew from 5,536,958 unlinked passenger trips in 2006 to 6,011,403 in 2011. Securement Location U.S.DOT requirements for the securement locations specify that they must be located as close to the accessible entrance as possible, with a clear floor area 30 inches wide by 48 inches long. Rather than have securement areas that are in one designated space, some transit agencies have procured vehicles with a flexible design. While such vehicles may be more commonly used in paratransit operations, they may also be used in fixed-route transit service. Laketran, the regional transit authority serving Lake County in northeastern Ohio, has begun to use such vehicles in late night and weekend fixed-route transit service (as well as in demand responsive service). Laketran operates 77 cutaway vehicles, all of which have full-length secure- ment tracking—the tracks in which the securement devices are anchored have been installed the full length of the vehicle (see Figures 4-1 and 4-2). Vehicle seats can fold up to expose the full length track, which allows Laketran operators to position the securements in an infinite number of locations. This ability not only greatly eases the challenge that can be posed by the variety of mobility devices on the market, but also allows passengers with mobility devices to sit in any CCRTA in Corpus Christi, TX, has purchased buses with three secure- ment areas and state-of-the-art securement systems since 2008. As a result of these and other efforts, they have seen lift boarding on the fixed-route transit service increase from 27,475 per year in 2006 (prior to the efforts) to 110,961 in 2012.

30 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities Figure 4-1. Laketran vehicle with full-length securement tracking, looking forward from the rear (photo courtesy of Laketran). position they wish, unless another passenger already occupies the desired location. Laketran has put this into practice, allowing passengers this choice. Laketran tested the vehicles with this securement design in late night and weekend fixed- route transit service in late 2012 and early 2013 with positive results. As of February 2013, Laketran is considering use of small cutaways on fixed routes during times and in areas with low demand. The advantages identified include fuel savings (11.8 miles per gallon for cutaways as compared to 5.6 miles per gallon for transit coaches), potential labor cost savings (depending Figure 4-2. Laketran vehicle with full-length securement tracking, looking rearward from the front. (photo courtesy of Laketran).

Operating accessible and Usable Fixed-route transit Services 31 on pay structure for fixed-route cutaway operators), and favorable public perception (in that the smaller vehicles are more efficient and less expensive to operate). Laketran has also identified some drawbacks with use of cutaway-type vehicles for fixed- route transit. The vehicles have lifts in the “rear” of the bus—behind the rear axle on the curb side of the vehicles. Unlike full-sized transit coaches, the driver cannot deploy a rear lift while seated; he or she must exit the vehicle and walk to the rear of the vehicle to operate the lift. In the cutaways used by Laketran, the driver must exit on the street side rather than the curb side, which presents a safety hazard to the driver. Positioning the vehicle for rear lift deployment at fixed-route bus stops is also a challenge when passengers are waiting at the stop. Finally, the farebox in these vehicles is positioned behind the driver, which is not ideal for fixed-route transit service. The Utah Transit Authority (UTA) in Salt Lake City uses a similar continuous front-to-back securement track system for vehicles used in deviated fixed-route service (FLEX Bus). One addi- tional feature incorporated by UTA is a continuous track above the windows (see Figure 4-3) which allows for varied anchoring of the passenger shoulder belt, to match the position of the rider and wheelchair. Improving Driver Access to the Securement Location A driver’s ability to secure a passenger’s wheelchair is sometimes made difficult by space con- straints. Limited space to reach behind the wheelchair to grasp the securement device can mean that drivers must reach around the passenger, which can be uncomfortable for both individuals. Golden Empire Transit District (GET) in Bakersfield, CA, solved this problem by modifying the panel that the wheelchair backs into. With the modified panel, which was designed by GET’s Maintenance Manager more than a decade ago, drivers can access the wheelchair tie-down points from the seat behind the wheelchair area (see Figure 4-4). GET reports that drivers like the access from the rear. The change resulted in no added main- tenance costs, and the barriers were reported to be very durable. GET has considered adding padding to the bars for additional passenger protection in case of an accident, but GET has never had an injury claim involving the barriers (which have been in service for at least 10 years), and there would likely be higher maintenance costs in repairing foam that has been cut or picked at by seated passengers. Figure 4-3. Continuous track for anchoring passenger shoulder strap, UTA FLEX bus vehicles (photo courtesy of TranSystems).

32 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities Securement System The securement system includes a method to secure the mobility device in the vehicle and a passenger restraint system. The types of securement systems in fixed-route transit vehicles vary considerably, even while meeting the U.S.DOT requirements. Many transit agencies have wheelchair marking programs and/or use special straps that improve securement of the mobility device on the vehicle. With a marking program, typically a transit staff member meets with the rider and together they determine the best locations on the mobility device for attaching the tie-down equipment. These locations are then “marked” so that drivers will know where on the mobility device to attach the tie-down equipment when the person is riding transit. Special straps are also used to improve securement. These straps, called tether straps or sometimes Stokes straps (after a disability advocate who helped popularize the straps), may be affixed to the rider’s mobility device providing improved on-board securement (see Figure 4-5). Or the straps may be provided to the vehicle driver for his or her use in securing mobility devices on-board. The straps address the problem that many mobility devices lack clear attachment points, which can make it difficult for transit drivers to attach the tie-down equipment to the mobility device or to reach an appropriate part of the device for securement. As an alternative, the driver attaches the tie-downs to the strap. Tether straps are inexpensive. Intercity Transit in Olympia, WA, which uses the straps, reported in 2013 that they purchase the straps for less than $2 each. They then provide the straps to riders free of charge, so they can be permanently affixed to their wheelchairs. Securement of Scooters Another issue is the securement of scooters. Often, it is difficult to find a structural member of the scooter to which a securement strap can be attached. Lane Transit District (LTD) in Eugene, OR, addressed this issue by designing an additional strap that goes across the footrest, or “floor” of scooters (see Figure 4-6). The strap is laid across the floor of the scooter and cinched tight. This supplemental securement system was developed Figure 4-4. Modified “reach-through” panel behind securement area, designed by GET (photo courtesy of GET).

Operating accessible and Usable Fixed-route transit Services 33 in-house by LTD for use on its fixed-route transit vehicles. Note also in Figure 4-6 that LTD has installed hooks and cords on the wall of the vehicle to keep the wall-side seat belts and secure- ment straps up off the floor, which makes them easier to reach. Policies The ADA requires that the wheelchair securement locations on vehicles have signage that indicates that they are for persons with disabilities who use wheelchairs. If flip-down seats are provided in these areas, and if ambulatory riders (including ambulatory riders with disabilities) are using the seats, drivers must ask that they move to make the securement areas available for riders using wheelchairs. This is different than the requirement for priority seating, Figure 4-6. Supplemental strap used by LTD to secure scooters on fixed-route transit vehicles (photo courtesy of TranSystems). Figure 4-5. Tether strap attached to a wheelchair to assist with securement (photo courtesy of TranSystems).

34 Strategy Guide to Enable and Promote the Use of Fixed-Route Transit by People with Disabilities which says that drivers must ask people to move, but doesn’t require drivers to make people move—although transit agencies can adopt stronger policies that require people to move from priority seating. Experience shows that riders with strollers or luggage sometimes occupy the securement areas when needed by riders using wheelchairs. Some transit agencies have adopted policies to address this; see examples below. Ensuring Availability of Priority Seats—New York City Transit Priority Seating Rule New York City established a rule on use of priority seating, among the rules governing the conduct and safety of the public in the use of the facilities of the New York City Transit Author- ity and Manhattan and Bronx Surface Transit Operating Authority, encoded in New York Codes, Rules and Regulations. The rule states: 5. No person shall refuse or fail to relinquish a seat on a conveyance which has been designated as “PRIORITY SEATING,” “WHEELCHAIR PRIORITY SEATING” or words of similar import, if requested to do so by or on behalf of a person with a disability, or occupying any location on a conveyance designated for use by persons using wheelchairs if such location is required to accommodate a person using a wheelchair. Further, passengers aboard buses equipped with wheelchair lift devices shall not conduct themselves in a manner which will impede the operation of such lifts, impede the securing of wheelchairs in the tie-down devices located on such buses or impede the exit of passengers using wheelchairs.1 In essence, the rule prohibits passengers from impeding access to priority seating and wheel- chair securement areas by people with disabilities, and empowers the transit agency to enforce this rule (rather than simply requesting that the seats be made available, as is the extent required by the ADA). Violation of this rule can have potential criminal or civil consequences. The current fine schedule posted by the Transit Adjudication Bureau indicates a $50 fine for “interference w/ wheelchair facilities/conveyances.”2 New York City Transit educated customers about this rule through a priority seating cam- paign that began in June 2009, including posting car cards on board buses (Figure 4.7).3 Washington, D.C., Circulator Stroller Guidelines The DC Circulator, a fixed-route bus service operated in downtown Washington, D.C., through a public/private partnership between the District of Columbia Department of Trans- portation, Washington Metropolitan Area Transit Authority and DC Surface Transit, Inc., 121 NYCRR Part 1050, Section 1050.6, http://www.mta.info/nyct/rules/rules.htm, as accessed 10/23/12. 2Rules of Conduct and Fines, http://www.mta.info/nyct/rules/TransitAdjudicationBureau/rules.htm, as accessed 1/2/13. 3NYCT press release dated June 19, 2009, http://www.mta.info/mta/news/releases/?en=090615-NYCT90, as accessed 1/2/13 © Metropolitan Transportation Authority. Used with Permission. Figure 4-7. New York City Transit priority seating education card.

Operating accessible and Usable Fixed-route transit Services 35 issued guidelines for boarding buses with strollers that clarify the use of accessible seating areas, with priority for people with disabilities, and set limits on the size of strollers allowed on board. The DC Circulator website states: “People using wheelchairs and motorized mobility aids have first priority for the accessible seating area. The second priority group includes persons with disabilities, seniors and people with walkers. Children in strollers are the third category of customers entitled to priority seating, but only if there are no higher priority customers on the bus.” Children in strollers will still be accommodated. However, parents may be asked to fold the stroller and move to another seat should a higher priority customer board the bus. The stroller will fit if it is small and can be stored in the seating area without extending into the aisle.”4 Drivers are empowered with the discretion to “direct the passenger to move the stroller to a safe location or to fold the stroller.” The DC Circulator permits use of the ramp for stroller boarding, limits on-board stroller size to no larger than 48" long by 24" wide, and prohibits “play buggies.” 4.2 Stop Announcements and Route Identification The ADA requires transit agencies to announce stops on the bus and the train, as well as to identify bus and train routes at stops that serve more than one route. Stop and route identification announcements have great value for many riders with disabilities. The lack of an effective stop announcement and route identification program can be a factor that prevents or discourages people with disabilities from using fixed-route transit. On fixed-route transit systems, the ADA requires transit agencies to announce stops, at least, at: • Transfer points with other fixed routes. • Other major intersections and destination points. • Intervals along a route sufficient to permit individuals who are blind or have vision impairments or other disabilities to be oriented to their location. • Any requested stop. These requirements apply to all forms of fixed-route bus and passenger rail service, including Amtrak and light, rapid, and commuter rail. At stops that serve more than one route, the transit agency must provide a means by which an individual who is blind or has a vision impairment or other disability can identify the proper vehicle to enter, or be identified to the vehicle operator as a person seeking a ride on a particular route. As an example, the Chicago Transit Authority (CTA) is installing shelters with visual and audio “next bus” information—the audio button makes a ticking sound for riders with vision impairments so they can locate the bus. Route identification assists riders who may not be able to recognize the bus route or destination to know when the desired bus has arrived. This requirement applies both to buses and to all forms of passenger rail. Tips for Transit Agencies on Both Stop Announcements and Route Identification High-level management support is necessary for stop announcement and route identification efforts to be effective. Management support includes committing adequate resources and sup- porting a comprehensive training program, monitoring effort, and discipline/incentives program. 4http://www.dccirculator.com/Home/RiderInformation/StrollersonBus.aspx, as accessed 1/2/13.

36 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities Support from any labor unions or other recognized employee associations is also a key to a successful program. A unified message to drivers from both management and labor is best. Proactive monitoring and progressive discipline programs are also vital to the successful implementation of both on-board stop announcement and route identification policies. Monitoring should be combined with progres- sive discipline. The level of discipline needs to be on par with other safety violations, since it can be a safety risk if a rider with a cognitive disability, or who is blind or has a vision impairment, disembarks at a wrong stop. Intentionally disabling the automated announcement or public address (PA) system equipment (except in cases of malfunction) should be elevated to the highest level of discipline. Recognition and other incentives should also be considered when drivers achieve good per- formance. Programs such as employee of the month, pins and badges, public recognition, and financial incentives can be a useful component of an effective stop announcement and route identification program. Some transit agencies have posted notices in all buses stating the ADA requirements to announce stops and routes, and providing contact information for reporting problems with stop and route announcements. This is a low-cost best practice that can engage the commu- nity in assisting the transit agency to improve its stop announcement and route identification program. The thorough investigation of all complaints related to the use of accessible fixed-route transit service is an important part of monitoring and compliance for stop announcements and route identification. Transit agencies will ideally ensure that all rider complaints are recorded and investigated and provide timely responses to riders with information about the outcome of investigations. Transit agencies will also ideally then use information obtained from investigations to address any performance issues and improve service. Tips for Transit Agencies on Stop Announcements Rider involvement is vital to a successful stop announcement program. Riders can provide valuable input on many issues including what stops to announce, how to announce them, employee training, and monitoring via secret rider programs. In developing stop announcements, transit agencies will first determine what stops should be announced on each route. Some of the ADA requirements make it clear which stops to include, such as the requirement to announce transfer points with other fixed routes. Other requirements must be applied locally, such as determining major intersections and destination points. Destination points include, for example, shopping centers, hospitals, and the end points of the bus or train route. It is a best practice for transit agencies to work with the disability community to define the stops to announce on each bus route. Bus drivers should also be consulted. Sometimes transit agencies implement the requirements for transfer points, major intersections, and destination points, yet neglect the requirement for orientation announcements. The ADA requires transit agencies to announce stops at “intervals along a route sufficient to permit individu- als with disabilities . . . to be oriented to their location.” If there is a stretch along a route with no major intersection, destination point, or transfer point where a stop announcement is otherwise required, a stop announcement Input from riders with disabilities and drivers is important for ensur- ing that stop announcements are appropriate, clear, and helpful. High-level management support, labor union support, proactive monitoring, and progressive discipline programs are all vital to ensuring that stop announcements are made as required.

Operating accessible and Usable Fixed-route transit Services 37 may be needed for orientation. It is also common to underestimate how often such orientation announcements should be made. More frequent announcements provide better orientation than less frequent ones. It is a best practice for a transit agency to develop consistent ways of making stop announcements, so that the information is clear and is not misunderstood. For example: • First, naming the street the bus is on, and second, naming the cross street, or vice versa. • Giving the street name only (such as Market and Taylor) or including street or avenue (such as “Market Street at Taylor Avenue”). • Describing major landmarks, destinations, and transfer points. Once these decisions are made, they will ideally be implemented consistently throughout the transit system. Lists of stop announcements for each route need to be prepared to indicate what stops should be announced and detail how each required stop announcement should be made. Ideally, these lists should be developed with disability community and driver input and be readily available to all vehicle operators, especially extraboard drivers. It is best that transit agencies have procedures on the timing of stop announcements and that drivers know when to announce stops (e.g., how long before the approaching stop) so that riders have time to indicate their wish to disembark. Another key to successful stop announcements is the technology used to make them. Except on small vehicles (22 feet and under), a PA system is necessary for amplification of stop announcements and other passenger information. Automated systems can help ensure that announcements are made, and made consistently. Even with automated technology, it is very important for transit agencies to ensure that drivers are prepared to make stop announcements themselves when the automated system is malfunctioning. Stop announcements need adequate sound quality. It is recommended that transit agencies obtain advanced amplification technology that can sense ambient background noise and automatically adjust the volume. Keeping the equipment for stop announcements in working order is vital. The PA and automated announcement systems should be included on pre-trip inspection forms, and checked during pre-trip inspections. The annunciators should be checked and monitored for synchronization with the stops. The checks should include the working condition of the PA system and a check to ensure the volume is at a proper level. The PA and automated announce- ment systems should also appear on preventive maintenance forms and should be inspected and tested regularly. Tips for Transit Agencies on Route Identification Conducting route identification properly requires an announcement any time passengers are waiting at a stop that serves more than one route. Policies need to direct drivers always to stop if there are waiting passengers, regardless of whether or not they signal for the bus. Vehicle operators need to come to a complete stop, open the door, and make a route announcement, unless it is automatic. A good practice is to purchase vehicles with external route identification announcement systems. If automated external announcement technology is not being used, drivers need to call

38 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities out route information after pulling up to stops and opening the door, if there are any waiting passengers. The announcement should be loud enough for waiting passengers to hear. Both the route and the destination need to be announced, so a rider with a disability can determine whether he or she is going in the correct direction. An external PA speaker is helpful to ensure that announcements are audible. Even with automated external announcement systems, drivers must always be trained and ready to make route announcements themselves in the event of an equipment failure. As with stop announcement equipment, external PA or automated route announcement technologies need to be maintained. Many of the practices suggested for stop announcement technology are suggested for route identification technology as well, such as including the devices on pre-trip and preventive maintenance checklists and exploring advanced technology to adjust the volume for ambient background noise. 4.3 Employee Training Another critical aspect of making fixed-route transit systems fully usable for riders with disabilities is thorough and effective employee training. High-level management support is necessary for ADA implementation efforts to be effective. Management support includes committing adequate resources and supporting a comprehensive training program, thorough monitoring effort, and a discipline/incentives program. Support from any labor unions or other recognized employee associations is also a key to a successful program. A unified message to drivers and other employees from both management and labor is best. Transit agencies are encouraged to convene a broad-based interdepart- mental working group to develop and implement thorough employee train- ing, as well as policies for ADA implementation that include many different parts of the organization such as equipment procurement, maintenance, monitoring, public information, and marketing. Training will ideally include detailed, written policies and procedures that address each of the ADA requirements. A lack of written policies on the part of transit agencies can contribute to inconsistent compliance. The policies need to be covered thoroughly in employee training. All important proce- dures should be part of the final detailed policy guidebook that is distributed to employees and made a part of training and retraining materials. In addition to conveying ADA requirements and policies, training ought to stress the impor- tance of the actual performance of each function (such as making stop announcements, cycling lifts and ramps, etc.). Rider involvement is also vital. Riders with disabilities will ideally be involved in training. They can put a human face to the importance of passenger assistance, stop announcements, and other key aspects of fixed-route transit service for people with disabilities. Participation by people with disabilities can bring about discussion of both disability sensitivity and common problems for people with disabilities using transit. They can stress the serious safety issues involved. In the area of stop announcements, riders can provide valuable input on many issues including what stops to announce, how to announce them, and monitoring via secret rider programs. Including people with disabilities in employee training puts a human face to the importance of rider assistance, stop announcements, route identification, and equipment maintenance.

Operating accessible and Usable Fixed-route transit Services 39 General Vehicle Maintenance Training Employee training efforts related to overall vehicle maintenance should include: • Keeping equipment in working order, starting with preventive maintenance. Transit agen- cies should conduct periodic reviews of in-house or contractor compliance with required inspections and preventive maintenance procedures. • Pre-trip inspections that include accessibility equipment such as automatic stop announce- ment annunciators, PA systems, wheelchair securement devices, and bus kneeling mecha- nisms. Inspections should also include checks that all of the necessary securement and restraint system components are on board and functioning. Inspections should check any other on-board technology for stop announcements and route identification, the stop request activators in the securement areas, and the vehicle signage, particularly the lighting for destination signs. • Before pullouts, making immediate repairs or removing vehicles from service and assigning a spare bus with working equipment. Some transit agencies have found it effective to assign a mechanic to the pullout area during major pullouts in order to address problems quickly. • Training for dispatchers and vehicle operators to handle failures at pullout and in service properly and arrange alternate transportation when appropriate (see more about training for vehicle operators below). • Conducting an immediate maintenance check at the end of each bus run or shift of all accessibility equipment that is reported to fail in service, including lifts and ramps. Records should be maintained of instances in which failures are reported and no problems are found. If this becomes a pattern for a particular bus, more extensive diagnostics should be run on that lift or ramp. If it is shown to be a pattern for a particular driver, a “spotter” check of the performance of that driver should be scheduled. • A system of regular and frequent maintenance checks of bus lifts and ramps. They must be carried out frequently enough to determine if the equipment is operative. Daily cycling of lifts/ramps at each pullout is a best practice. Vehicle Operator (Driver) Training Vehicle operators will ideally be trained to conduct pre-trip vehicle inspections themselves. Drivers should fully cycle lifts and ramps before pulling out at the beginning of their shifts. In addition to providing a check on the equipment’s working condition, pre-trip inspections by drivers ensure that drivers are familiar with how to work each piece of equipment before leaving the yard. This is particularly important when a bus fleet includes multiple models of lifts, ramps, securement systems, and PA systems. Other important points of training include: • Hands-on training in using the equipment, including demonstrating the ability to correctly operate it, and learning how to resolve common problems that can cause failures, such as deploying lifts and ramps where the ground is uneven. • Using the equipment to simulate what it is like for a rider to board, be secured, ride, and disembark using the lift or ramp. • Reporting immediately any malfunction in lifts, ramps, and other equipment. • Thorough training in stop announcement procedures (see more below about stop announcement training). Many training programs include a period of time when trainees ride with and learn from experienced driver trainers. Transit agencies should be sure Make sure that drivers selected to be driver-trainers have an exemplary ADA compliance record so they reinforce the policies, requirements, and training goals.

40 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities that the experienced drivers assigned to any new vehicle operators are drivers who excel at per- forming their stop announcements and other ADA-related actions correctly. Teaming trainees with drivers who do not perform properly or who are not committed to following established policies and procedures can undermine prior training. Driver trainers should have a docu- mented track record of exemplary performance. Stop Announcement Training Employee training for vehicle operators related to stop announcements will ideally include making the announcements properly as well as the following: • When announcements are to be made (i.e., in advance of the stop, but not too far in advance). • How to handle rider requests. • How to use the PA system. • How to use any automated system that may be available. • What to do in case the automated system malfunctions or fails. Another issue to cover regarding stop announcement training is that bus drivers sometimes think they needn’t make stop announcements if they do not notice any riders with disabilities on the bus, or if they know all the riders and believe the riders do not need announcements. However, this is a misunderstanding of the ADA requirement. Stop announcements are important for many riders with hidden disabilities, and they are helpful to other riders as well. They should be made for any and all riders, as a feature of universal design. Transit agencies should also train drivers to respond to riders who might complain about the presence of stop announcements. 4.4 Service Monitoring Service monitoring is important for ensuring that accessible fixed-route transit service is in fact being provided on a day-to-day basis and enabling riders with disabilities to effectively and safely use the service. Service monitoring includes the more formal, regular review of performance and operational reports and periodic planning studies as well as day-to-day observation, assessments, and monitoring. These latter efforts can be achieved through: • Road supervision, where supervisors periodically check whether drivers are following procedures for serving riders with disabilities. This can be in the form of both observed and unobserved checks. • Review of and response to rider feedback through the comment and complaint process. • An active rider advisory board that includes riders with disabilities. • A “mystery rider” program in which designated riders report on driver performance and ADA compliance issues, for example, checking to make sure drivers do not pass by a waiting rider using a wheelchair. • Review of on-board camera video and audio, to check driver performance. Several industry reports stress the importance of effective service monitoring, including the ADA Topic Guides that recommend monitoring to ensure that accessibility features on vehicles are in proper working order and that vehicle operators are making stop announcements as required. (6) In Washington State, transit agencies can participate in a reciprocal service monitoring program, called the Guest Rider Program: a transit agency agrees to conduct observations of another agency’s service with experienced operating staff in return for that agency conducting Service monitoring is important for ensuring that policies and procedures are implemented in day-to-day operations and that fixed-route transit services are actually accessible and usable.

Operating accessible and Usable Fixed-route transit Services 41 observations of its own operations. (6) A similar reciprocal monitoring program operates in Ohio, called the Ghost Rider Program, with transit agencies arranging for service monitors from other agencies to conduct performance reviews. (7) Using staff of another transit agency to monitor service provides anonymity that is not always possible when an agency has its own staff monitor performance. Transit Industry Practices According to the project’s survey of transit agencies, two-thirds of agencies (68%) assign road supervisors to conduct regular monitoring of the service, with specific checks of ADA accessibility requirements. Somewhat more than one-fourth of transit agencies (28%) have a mystery rider program (also called a secret rider, ghost rider, or secret shopper program), where designated persons take fixed-route transit trips and report on driver and service performance. According to the survey responses, transit agencies may use a rider with a disability, a contractor, or, according to one transit agency operating in a university town, students to function as the mystery riders. Additionally, 39% of transit agencies reported “other efforts” for monitoring their service to ensure accessibility. Among these “other efforts” reported by transit agencies, one of the most frequently identified was an on-board video surveillance system to monitor drivers (and riders). Transit agencies reported their monitoring efforts as “very effective” (17%) or “effective” (42%) in monitoring fixed-route transit service delivery to riders with disabilities. Highlighted Service Monitoring Efforts The service monitoring efforts of two transit agencies are highlighted below. Nashville Metropolitan Transit Authority The Nashville Metropolitan Transit Authority (MTA) has had a Quality Assurance Program (QAP) in place since the fall of 2011, through which MTA employees and board members monitor service. MTA requires each administrative employee to ride a bus route at least once each month and then complete a web-based survey to report their observations of such items as: • Politeness of the operator; • Smoothness of operation of the vehicle; • Safety habits of the operator; • Missing, defaced, or damaged passenger amenities; • ADA-required stop announcements (automated if operable; by driver if not); • Passenger assistance by the operator for passengers with disabilities; • Cleanliness of the vehicle; • Schedules and passenger information flashes available and up to date; and • Working condition of the vehicle (air conditioning, heat, etc.). Many of MTA’s employees connect to the web-based survey using their smartphones (using a browser shortcut placed on their phones), and fill out the survey while on the bus. Responses are tracked and sent to the departments responsible for further investigation, cor- rection of issues, and/or sharing of compliments. To date, MTA has found the QAP has been an effective source of feedback about the system and subsequent correction of problems.

42 Strategy Guide to enable and promote the Use of Fixed-route transit by people with Disabilities The QAP was developed as an initiative to get its approximately 116 administrative employees more involved in the core of the MTA’s business. A committee was convened with diverse rep- resentation of individuals from throughout the agency. The committee put together a survey that could be used by each employee when they rode the bus. When the ride requirement was first implemented, management discovered that some of the administrative employees had never ridden a bus. To help some individuals overcome fear and plan their trips without getting lost, MTA provided bus familiarization training to staff. What was initially a challenge for those staff new to riding transit has become routine, and many staff members look forward to their monthly ride. They also use the bus more often for lunch trips or trips to meetings. Many departments make it a group outing and try a different route each time. Overall, participating in the QAP has made many employees more empa- thetic to MTA passengers and has given them a better sense of how their job affects the overall operation. To encourage and recognize QAP participation, MTA provides incentives. During the first month, giveaways were provided to all employees who completed their rides. To celebrate the first year anniversary of the program, a contest was conducted for the most rides taken in a month. While at this time only administrative employees are required to participate in the QAP, MTA has also invited others in the organization to provide feedback using the survey after riding. In the spring of 2012, MTA invited its board members, who often ride the bus, to participate in the program. One board member has participated in the QAP survey on multiple occasions. In August 2012, the program was opened to union employees as well, on an optional basis. Management knew that getting union personnel to participate would be a bigger challenge and worked hard to ensure the union employees would feel comfortable with the process and not feel as though they were spying or telling on their peers. In the last quarter of 2012, nine union employees participated in the QAP program. MTA continues to come up with incentives to encourage more union employees to participate, and is optimistic that all employees will wish to participate in the program. The intent is to eventually roll this program out to MTA passengers as well. Washington Metropolitan Area Transit Authority The Washington Metropolitan Area Transit Authority (WMATA) instituted two evaluation programs in 2012 that assess the quality of fixed-route transit service for people with disabilities: a “mystery rider” program and a MetroAccess Knowledge and Usage Study. “Mystery Rider” Program. WMATA contracts with an outside firm that hires, trains, and supervises paid mystery riders. The mystery riders include people with visual impairments and wheelchair users. They monitor all aspects of fixed-route bus and rail operations (not just acces- sibility), including conditions at bus stops, functionality of equipment such as fare machines and customer service provided at rail stations. Mystery rider assignments are based on a carefully calculated random sampling method to allow for system-wide coverage on varying days and times of the week. On average, rail stations are surveyed three times per quarter, while each bus route is surveyed annually, and the system’s approximately 12,000 bus stops are randomly assessed. One method of evaluating customer service is through mystery riders being issued “dead” smart trip cards. When the card doesn’t work, they ask for help and evaluate the helpfulness of responding WMATA staff. Mystery riders use a mobile device such as a smartphone or tablet to submit feedback using an electronic form. Responses are automatically uploaded to a database.

Operating accessible and Usable Fixed-route transit Services 43 Critical problems submitted by the mystery riders (such as a ramp that doesn’t deploy or nonfunctioning automated next-stop information) automatically create an alert that is sent to the Office of Customer Research; this office then relays the alert to the appropriate opera- tions division so that corrective actions can be taken as quickly as possible (repair, service adjustment, etc.). The contractor prepares a quarterly report card from the data submitted. WMATA staff also are provided the ability to query the database of completed “rides” to review specific reports. ADA Paratransit Knowledge and Usage Study. WMATA conducts a Knowledge and Usage study with riders of its ADA paratransit service, MetroAccess. One component of this study is a questionnaire for MetroAccess riders with conditional eligibility, which includes questions on knowledge and usage of fixed-route transit services, such as: • How often do they use fixed-route transit? • Has their fixed-route transit usage increased or decreased in past 12 months? • Do they use the free pass (conditionally eligible MetroAccess riders are provided free passes for bus and rail)? • If riders don’t use the fixed-route transit system, why not? • How much do they pay to ride the fixed-route transit system? • Are they familiar with travel training? Have they used it, and, if so, have they changed their travel behavior? Each quarter, 400 MetroAccess riders are surveyed by telephone, and approximately 120 of these have conditional eligibility. From the first two quarters of survey data, early findings suggest that many conditionally eligible individuals consistently self-select MetroAccess over fixed-route transit, and a lack of understanding of fixed-route transit services and information is common. For example, feedback indicated that few riders are aware of the availability of e-alerts on elevator outages. The feedback is being addressed by WMATA’s travel training pro- gram. WMATA’s Rider Accessibility bus/rail subcommittee is also looking at ways to improve outreach/education about fixed-route transit.