Mid-Atlantic ADA Center



Slide 1

Accessibility in Rail Facilities

Kenneth Shiotani Senior Staff Attorney

National Disability Rights Network

820 First Street Suite 740 Washington, DC 20002

(202) 408-9514 x 126

Kenneth.shiotani@

September 2017

[Image: National Disability Rights Network logo]

Slide 2

ADA Transportation Provisions

Making Transportation Accessible was a major focus of the statutory provisions of the ADA

PART B -Actions Applicable to Public Transportation Provided by Public Entities Considered Discriminatory [Subtitle B]

SUBPART I -Public Transportation Other Than by Aircraft or Certain Rail Operations [Part I]

42 U.S.C. §12141 –12150

Definitions –fixed route and demand responsive, requirements for new, used and remanufactured vehicles, complementary paratransit, requirements in new facilities and alterations of existing facilities and key stations

SUBPART II -Public Transportation by Intercity and Commuter Rail [Part II]

42 U.S.C. §12161-12165

Detailed requirements for new, used and remanufactured rail cars for commuter and intercity service and requirements for new and altered stations and key stations

Slide 3

What Do the DOT ADA Regulations Require?

Accessible railcars

• Means for wheelchair users to board

• Clear path for wheelchair user in railcar

• Wheelchair space

• Handrails and stanchions that do create barriers for wheelchair users

• Public address systems

• Between-Car Barriers

• Accessible restrooms if restrooms are provided for passengers in commuter cars

• Additional mode-specific requirements for thresholds, steps, floor surfaces and lighting

Slide 4

What are the different ‘modes’ of passenger rail under the ADA?

• Rapid Rail (defined as “Subway-type,” full length, high level boarding) 49 C.F.R. Part 38 Subpart C-NYCTA, Boston T, Chicago “L,” D.C. Metro, Baltimore Metro, BART, MARTA

• Light Rail & Streetcars 49 C.F.R. Part 38 Subpart D -Older Systems -SEPTA, MBTA Green Line, Pittsburgh T; Newer Systems -Portland TriMetMAX, Charlotte Lynx, Minneapolis Metro, others

• Commuter Rail -49 C.F.R. Part 38 Subpart E -Older systems -Long Island Railroad (LIRR); Metro North (New York Central, Penn Central, Conrail), SEPTA (Reading RR & Pennsylvania RR), MBTA (Boston & Maine); Newer systems -MARC, VRE, Tri-Rail (Miami), UTA Front Runner (Salt Lake City), New Mexico Rail Runner (Albuquerque to Santa Fe), Metro Transit Northstar (Minneapolis)

• Intercity Rail 49 C.F.R. Part 38 Subpart F -National Railroad Passenger Corporation (Amtrak). Created in 1971, took over long distance (vs. commuter) passenger service from freight railroads with a limited nationwide system.

Slide 5

What do these different modes look like?

Rapid Rail(49 C.F.R. §38 Subpart C) Subways -provide full length platforms & level boarding from platforms onto railcars, can run underground, at grade or on elevated track.

[Images: photo of Washington Metropolitan Transit Authority D.C Metro Rail train at an underground station with passengers walking on the platform and traveling on an escalator. Photo of Chicago Transit Authority (CTA) El rapid rail car at an elevated station. Train operator is looking at passengers getting on and off train. Visible on platform is blue detectible warning (truncated domes) strip with narrow strip in yellow at very edge of platform. Also visible is a wide yellow section that may be where car doors are supposed to open though the wide yellow section does not line up at all with car door.]

Slide 6

Light Rail (49 C.F.R. §38 Subpart D)

Limited operation on streets, mostly operate on dedicated right-of-way, on grade, below grade, underground or elevated tracks. Older systems had high floor cars. Newer cars are usually low floor.

Portland TriMetMAX Bombardier Type I Light Rail car (Built mid 1980s) at low level platform (note steps inside car).

Newer TriMetMAX cars have low floors

Phoenix Valley Metro Kinkisharyolow floor Light Rail car built in 2008 provides level boarding from platforms about 14 inches Above Top of Rail.

[Images: photo of Portland TriMet MAX Bombardier Type I Light Rail car (built in the mid-1980s) at low level platform (note steps inside car to get to high floor of car). Photo of Phoenix Valley Metro Kinkisharyo low floor light rail car at station with woman with stroller waiting for car doors to open. Light Rail of two car train closer to photographer is "wrapped" in advertising with guitar player and text saying, "Hyped for Halftime" with picture of Pepsi can.]

Slide 7

Streetcars, treated as Light Rail under ADA but considered somewhat different by the industry

Apply ADA Light rail requirements -Photo shows a Washington, D.C. Streetcar InekonTrio. Modern streetcars are low floor and often have slightly raised Platforms that provide level boarding.

Main differences between modern streetcars and modern light rail, is that streetcars are lighter and narrower, usually operate as single car trains, and can run on narrower public streets with sharper curves.

[Images: Washington D.C. Streetcar shown at a curbside stop with doors open. Streetcar vehicle is single car with three articulated sections. Photo of Portland Street car from inside car showing articulated car going around a relatively sharp curve near a sidewalk.]

Slide 8

Heritage Streetcars (49 C.F.R. §38 Subpart D)

Little Rock Arkansas River Line Heritage Streetcars (cars built mid 2000s) Exterior view above. On right, an interior view showing a wheelchair lift.

[Images: photo of Exterior view of Little Rock River Line "Heritage" Streetcar (cars built mid 2000s) but emulate design of streetcars from early 20th Century. Photo of Little Rock River Line "Heritage" Streetcar Interior view showing end of wooden bench seats and accordion doors emulating early 20th Century streetcars but with modern wheelchair lift on right]

Slide 9

Intercity Rail (Amtrak) (49 C.F.R. §38 Subpart F)

Amtrak Amfleet I single level cars, coach class, built 1975-78. (Pre-ADA). Car floor height is 48 inches Above Top of Rail.

Amtrak Superliner Bi-Level cars. Car #32038 is a sleeping car built in 1981. (Pre-ADA) Car floor height is 18 inches Above Top of Rail.

[Images: photo of Amtrak Amfleet I single level coach car with car floor 48" above the rail. Access to the car is up a set of steps at each end of the car and a doorway. Photo of Amtrak bi-level Superliner sleeping car. Access to the car is through as single low level center door. Car floor height is 18 inches Above Top of Rail.]

Slide 10

Commuter Rail (49 C.F.R. §38 Subpart E)

Cars can board from high 48” ATR platforms, low platforms or some intermediate height level boarding platforms

l SEPTA GE SilverlinerIV (Built 1973-1976) single level commuter car. Car floor is 48 inches Above Top of Rail (ATR). Newly constructed low platforms must be 8 inches Above Top of Rail. Existing platforms are often much lower

MARC III Kawasaki Bi-level (built 2000-2001) at Baltimore Penn Station that has a car floor and platform at 48 inches Above Top of Rail allowing level boarding.

[Images: photo of SEPTA GE Silverliner IV single level commuter car at Paoli station low level platform. Although car doors are closed, visible are 3 of 4 steps on car needed to board car from platform and get up to the floor of car which is about 48" above the top of the rails. Photo of MARC III Bi-level at Baltimore Penn Station. Car has a high level (48” Above Top of Rail) car floor and the high level platform at Baltimore allows level boarding though a bridgeplate, this will be needed to bridge the vertical and horizontal gaps between the car and the platform. Visible at edge of platform is dirty yellow detectible warning (truncated domes) strip.]

Slide 11

Commuter Rail -Gallery Cars (49 C.F.R. §38 Subpart E) can only board from low platforms

Virginia Railway Express (VRE) Nippon Sharyo Bi-level “Gallery” cars (2006-2008) with center entrance doors with steps up to car floor and equipped with car borne lifts. In photo on right, the left stairway bottom step says “Rincon” which is the maker of the lifts.

Gallery cars typically cannot be used at high level platforms. In addition to VRE, similar and older gallery cars are widely used by Metra Chicago suburban lines and Caltrain in San Francisco Peninsula service.

[Images: photo of Virginia Railway Express Nippon Sharyu Bi-level Gallery cars with center entrance doors with steps up to car floor. One Car is at what appears to be a grade crossing area, not a platform. One Car is shown at a low level platform (probably not 8 inches Above Top of Rail) with a yellow detectible warning (truncated domes) strip.]

Slide 12

Commuter Rail -Gallery Cars (49 C.F.R. §38 Subpart E) board from low platforms

Virginia Railway Express Nippon Sharyo Bi-level “Gallery” cars showing door open to restroom, stairs to galley seats, wheelchair space and priority seating and entrance stairs

Virginia Railway Express Nippon Sharyo Bi-level “Gallery” cars, view of upper gallery seating

[Images: Virginia Railway Express Nippon Sharyo Bi-level “Gallery” cars showing door open to restroom, stairs to galley seats, wheelchair space and priority seating and entrance stairs. Virginia Railway Express Nippon Sharyo Bi-level “Gallery” cars showing upper level gallery seating. Opening to lower space to permit conductors to check tickets from both upper and lower level passengers at the same time.]

Slide 13

Bombardier Bi-Level commuter cars (49 C.F.R. §38 Subpart E) unique (at time) car floor height

Metrolink (Los Angeles) Bombardier Bi-level commuter cars with unique octagonal car shape (First introduced in the early 1990s with subsequent orders in the early 2000s) have two doors on the low center floor of car which is 25 inches Above Top of Rail. Metrolink was first U.S. user of Bombardier Bi-level Commuter cars. Ten other U.S. commuter systems have since purchased Bombardier Bi-level commuter cars and similar non-octagonal shaped Bi-Level commuter cars built by Hyundai Rotem.

[Images: photo of Metrolink (Los Angeles) Bombardier Bi-level commuter cars with two low level double sliding doors accessing low center floor of car. Los Angeles Union Station platform in photo has yellow detectible warning (truncated domes) strip and appears a few inches below car floor level.]

Slide 14

Bi-level & Multilevel Commuter Railcars

Have doors for high level platform boarding and steps for boarding from low level platforms.

Maryland Area Regional Commuter (MARC) Bombardier Multilevel commuter cars first delivered in 2014 at Washington Union Station. Virtually identical cars were purchased earlier by New Jersey Transit. They have car floors and four sets of doors that allow level boarding from 48 inches Above Top of Rail platforms and have steps for boarding from low level platforms.

[Image: Maryland Area Regional Commuter (MARC) Bombardier Multi-level commuter car (newer design delivered in 2014) has four doors at 48 inch Above Top of Rail car floor height. The car doors at each end of the cars have steps to provide ambulatory access to low level platforms.]

Slide 15

2011 DOT Platform Rule

Federal Register Volume 76, Number 181 (Monday, September 19, 2011)

• Requires full-length, level-boarding platforms (where the platform surface is level with the floor of the train cars) in new and substantially reconstructed commuter and Amtrak stations.

• If the passenger railroad cannot provide full-length level-entry boarding because freight traffic uses the track adjacent to the platform, a passenger railroad can choose to meet the performance standard through use of car-borne lifts, station-based lifts, or mini-high platforms (with multiple stops if needed).

• The passenger railroad must provide a plan to FTA or FRA for approval explaining how its chosen means of meeting the performance standard will provide safe, reliable access.

• If two types of railcars with different car floor heights use the same platform, level boarding platform height should be coordinated with the lower car floor height

Slide 16

Why can’t intercity and commuter systems have full length level boarding platforms like rapid rail systems?

Most intercity and much commuter rail service in the U.S. operates on tracks owned and or used by freight railroads. Freight railroads occasionally move oversize loads, such as the industrial item shown on this car. Both the car and the load are wider than passenger railcars. To provide clearance for these wide loads, freight railroads insist that high level, level boarding platforms provide clearance or are “set back,” unlike platforms on rapid rail systems.

[Image: photo of depressed Center Freight Flat Car with large industrial load extending out over edge of rail car]

Slide 17

Incompatible Platform Heights

Cars built for lower level boarding heights cannot use 48 inch Above Top of Rail Platforms

Amtrak Bi-level Superliner Sleeping car with ramp to low level platform at Washington,

D.C. Union Station

Amtrak Bi-level Superliner car at a 48 inches Above Top of Rail platform at Washington, D.C. Union Station. Floor of car is about 30 inches below the platform

[Images: photo of Amtrak Bi-level Superliner Sleeping car (with car floor 18" Above Top of Rail) shown at D.C. Union Station with ramp to low level platform. Photo of Amtrak Bi-level Superliner car at a high level, 48 inches Above Top of Rail platform at Washington, D.C. Union Station. Floor of car is about 30 inches below the platform. Visible on the platform edge is a yellow detectible warning (truncated domes) strip.]

Slide 18

Boarding a commuter or intercity car with a 48” Above Top of Rail car floor by wheelchair users or individuals who cannot climb stairs

An Amtrak portable platform lift needed to get a wheelchair user or individual unable to climb railcar steps up to a 48 inch Above Top of Rail car floor from a low level platform. The lifts are deployed by the train or station crew.

Many commuter rail stations served by railcars with 48 inch Above Top of Rail car floors often have “mini-highs.” The mini-highs will provide access into one or two cars of the train.

[Images: photo of Amtrak portable platform lift at San Antonio Texas train station platform. Looking closely, one can see a cable and lock securing the platform lift to a pillar. MBTA photo of a “Mini-High” Platform on Boston's MBTA showing a short small and narrow high level platform reached by a ramp at the far end of the station platform. In foreground is an at-grade asphalt crossing of the rack with just a yellow warning strip with the words "Look Before Crossing" painted in yellow capital letters in front of the yellow painted strip. There is no detectible warning (truncated domes).]

Slide 19

Portable platform lift in use

Used by Amtrak and a number of commuter systems

Amtrak personnel have deployed and are assisting an individual to board an Amtrak rail car (with a 48 inch Above Top of Rail car floor) at Raleigh, North Carolina station

[Images: photo of Amtrak platform lift in use at Raleigh, NC station. A woman stands on the raised platform of the lift waiting for Amtrak crewmember to open the car door. Another Amtrak work stands next to the lift. Photo of Amtrak platform lift in use Raleigh, NC. Amtrak conductor has opened car door and appears about ready to assist standing passenger to board train.]

Slide 20

Solutions for boarding high floor railcars where full length level boarding is not possible

Amtrak’s movable set back platform test in Ann Arbor, Michigan. On left, platform is retracted for freight trains clearance. On right, platform extended to provide level boarding onto two cars. Boarding time is shortened and passengers like it.

[Images: photo showing Amtrak Ann Arbor movable set back platform with movable section retracted. An Amtrak car is next to the platform.

Photo showing Amtrak Ann Arbor movable set back platform with movable section extended/deployed. An Amtrak car is next to the platform. Note while this shows virtually no vertical barrier, there is still a several inch horizontal gap.]

Slide 21

Solutions for boarding high floor railcars where full length level boarding is not possible

Photo above shows new platform at Hartford, Connecticut Amtrak and CT Rail Hartford Line (service planned to begin in 2018). Photo on rights shows platform edge (yellow section) is hinged to flip up to provide clearance for freight trains. Platform is not a full length platform, it is approximately 3 cars long.

[Images: photo of Hartford, CT 48 inch Above Top of Rail high level platform accessible from original low level platform via ramp and stairs. The high level platform is not the full length of the platform. It is approximately 3 cars long. Photo of Hartford, CT hinged flip up edge platform in the down level boarding position. Flip up portion is about 28 inches wide. Photo has tape measure showing height over the low level platform and also shows a gate that blocks access to the remaining low level portion of the platform.]

Slide 22

Rail cars with different car floor heights using the same station (Oakland, CA)

Amtrak California single level rebuilt former New Jersey Transit Comet 1B cars built by St. Louis Car Company for the Penn Central in the late 1960s. The car floor is 48 inches Above Top of Rail. The only means of wheelchair access is by use of a portable platform lift. See upcoming slide.

Amtrak California Bi-level California cars (this car built by Morrison-Knudsen in the mid-1990s) have a 15 inch Above Top of Rail lower car floor. Because station platforms are lower, they have carborne lifts on most cars

[Images: photo of Amtrak California single level rebuilt former New Jersey Transit Comet 1B cars. Photo of Amtrak California Capital Corridor train at Oakland California Jack London Square station. Amtrak Bi-level California cars (built by Morrison-Knudsen in the mid-1990s) have two low floor entrances. Amtrak Bi-Level California Car has carbornelifts.]

Slide 23

Amtrak Bi-Level California Car has Carborne lifts

Amtrak California cars have a 18 inch Above Top of Rail car floor. Most passenger platforms in California are no more than 8 inches Above Top Rail and some are at Top of Rail. So a carborne wheelchair lift is needed.

[Images: photo of wheelchair user on Amtrak California bi-level car carborne lift about to be lowered onto the platform. Photo of wheelchair user rolling away from train while train crew member folds up edge of carborne platform lift to get it ready to be moved to stored position in the Amtrak California bi-level car.]

Slide 24

Bridging the horizontal gap -

bridgeplatesor ramps still usually needed

Bridgeplatein use at Amtrak Ann Arbor, Michigan movable set back platform

Amtrak’s Lorton, VA station provides full length level boarding onto Superliner cars but a bridgeplateis still needed to span the horizontal gap.

[Images: photo of Amtrak full length, level boarding platform at Lorton Virginia. Photo shows need for bridgeplate to span horizontal gap even where the platform provides level boarding. Platform has yellow detectible warning (truncated domes) strip for the length of the platform. Photo showing new Amtrak bridgeplate going into an Amtrak Horizon car on the Ann Arbor moveable set back platform. While the setback platform when extended provides level boarding, there is still a several inch horizontal gap that the bridgeplate fills. The new bridgeplate is black with a yellow center line and yellow edges and yellow edge protection.]

Slide 25

Boarding Bombardier Bi-level commuter cars

UTA Front Runner has full length level boarding at most stations

Utah Transit Authority (UTA) Front Runner Bombardier bi-level commuter car at FULL LENGTH LEVEL BOARDING platform in Salt Lake City. Car floors are 25 inches Above Top of Rail. Extended sill at car door appears to mitigate the need for a bridgeplate.

[Images: photos of Utah Transit Authority Front Runner Bombardier bi-level commuter car at full level boarding platform in Salt Lake City. The Utah Front Runner service is unique in having full level boarding platforms onto the Bombardier bi-level commuter cars which have a 25" Above Top of Rail car floor which different from Amtrak bi-level Superliners which are about 18" Above Top of Rail and Amtrak Amfleet and most commuter rail cars that provide for level boarding at 48" Above Top of Rail.]

Slide 26

New Mexico Rail Runner Raised Platform and Bridgeplates for boarding Bombardier Bi-level commuter cars

New Mexico Rail Runner Bombardier Bi-Level Commuter car showing raised level boarding platform and bridgeplate in Albuquerque in September 2016

New Mexico Rail Runner Bombardier Bi-Level Commuter car with wheelchair user boarding in Albuquerque from raised level boarding platform using bridgeplate in September 2016. Conductors deploy Bridgeplates at every station stop.

[Images: photo of New Mexico Rail Runner Bombardier Bi-Level Commuter car showing raised level boarding platform and bridgeplate in Albuquerque in September 2016.Photo of wheelchair user boarding in Albuquerque from raised level boarding platform using bridgeplate in September 2016.]

Slide 27

New Mexico Rail Runner Raised Platform and Bridgeplates

New Mexico Rail Runner Bombardier Bi-Level Commuter car with wheelchair user boarding in Albuquerque from wooden mini-high platform using bridgeplate in October 2011

New Mexico Rail Runner Bombardier Bi-Level Commuter car with all passengers boarding from large raised level boarding platform using bridgeplate in Albuquerque in September 2016

[Images: photo of New Mexico Rail Runner Bombardier Bi-Level Commuter car showing raised level boarding platform and bridgeplate in Albuquerque in September 2016. Photo with several ambulatory passengers boarding in Albuquerque from new level boarding platform using bridgeplate in September 2016.]

Slide 28

Metro Transit Northstar(Minneapolis) has raised platforms and bridgeplates AND carbornelifts to allow equal access to every car in a train

Above, Minnesota Northstar station, raised level boarding platform with bridgeplate deployed. On Right, interior view of car doors with car borne lift (in every car)

[Images: Minnesota Northstar Bombardier Bi-level car stopped at station with passengers walking up ramp to raised level boarding platform. Just barely visible behind male passenger walking up ramp are wheels of a rollator (walker with wheels) Conductor has deployed bridgeplate to permit level boarding. Also visible is variable message sign Interior view of Minnesota Northstar Bombardier bi-level commuter car. Shown are double sliding doors and carborne lift next to doorway.]

Slide 29

Metro Transit Northstar (Minnesota) has raised platforms and bridgeplates AND carbornelifts

Metro Transit Northstar Target Field Minneapolis station with raised level boarding platform providing access to Bombardier Bi-level commuter car at end of train.

Metro Transit Northstar station, raised level boarding platform

[Images: photo of Minnesota Northstar Bombardier bi-level commuter car at Minneapolis Target Field station. Visible is raised level boarding platform with railings and deployed bridgeplate. Yellow caution barrier are deployed with train crew members appear to be on a break. Photo of Minnesota Northstar raised level boarding platform. Visible are handrails and general configuration and size of the raised platform and its height above the low level platform. Also visible is the amount of setback of the raised platform edge from the edge of the low level platform.]

Slide 30

Boarding high floor Light Rail cars

Maryland MTA Light Rail “Mini-High” Platform to allow boarding by wheelchairs users and other unable to climb steps onto high floor light rail cars.

Sacramento Regional Transit light rail car stopped by boarding platform to allow boarding by wheelchairs users and others unable to climb steps onto high floor light rail cars.

[Images: photo of Maryland MTA light rail "Mini-High" platform, a very small platform reached by inclined ramps at Glen Burnie Maryland. The car floor level section of the mini-high for the wheelchair user is only big enough to accommodate one wheelchair user and probably an ambulatory companion. This particular "Mini-High" is also ACROSS THE TRACKS from the main platform used by all other passengers. Photo of Sacramento Regional Transit light rail car stopped by boarding platform to allow boarding by wheelchairs users and others unable to climb steps onto high floor light rail cars.]

Slide 31

Full length level boarding on newer low floor light rail cars

Charlotte Area Transit System (CATS) LYNX Blue Line Siemens S70 light rail cars with full length level boarding platform

Minneapolis, Minnesota Metro Transit Bombardier Flexity Swift light rail cars with full length level boarding platform

[Images: photo of Minneapolis, Minnesota Metro Transit Bombardier Flexity Swift light rail cars (at least two different cars are visible) with full length level boarding platform with door open. Platform has yellow detectible warning (truncated domes) strip at edge of platform. Photo of Charlotte Area Transit System (CATS) LYNX Blue Line Siemens S70 light rail cars at station with full length level boarding platform. Platform edge has white detectible warning (truncated domes) strip.]

Slide 32

ADA Between-Car Barrier Requirement

Rapid Rail§38.63 Between-car barriers.

(a)Requirement. Suitable devices or systems shall be provided to prevent, deter or warn individuals from inadvertently stepping off the platform between cars. Acceptable solutions include, but are not limited to, pantograph gates, chains, motion detectors or similar devices.

(b)Exception. Between-car barriers are not required where platform screens are provided which close off the platform edge and open only when trains are correctly aligned with the doors.

Light Rail

§38.85 Between-car barriers.

Where vehicles operate in a high-platform, level-boarding mode, devices or systems shall be provided to prevent, deter or warn individuals from inadvertently stepping off the platform between cars. Appropriate devices include, but are not limited to, pantograph gates, chains, motion detectors or other suitable devices.

Commuter Rail

§38.109 Between-car barriers.

Where vehicles operate in a high-platform, level-boarding mode, and where between-car bellows are not provided, devices or systems shall be provided to prevent, deter or warn individuals from inadvertently stepping off the platform between cars. Appropriate devices include, but are not limited to, pantograph gates, chains, motion detectors or other suitable devices.

Slide 33

Examples of Between-Car Barriers

Between-Car Barriers on San Francisco Muni Light Rail cars at a high level boarding subway station platform, installed in 2014.



Between-Car Barriers on new Washington DC Metro 7000 series rapid rail (subway) car.

[Images: photo of Washington D.C. Metro 7000 series cars, Between Car Barriers which are two spring chains. Photo of between-car barrier on San Francisco Muni Light Rail cars at a high level boarding subway station platform. The between-car barriers are three diagonally striped in yellow and black retractable belt barriers similar to those used to direct people waiting on airport screening lines, movies and fast food restaurant lines.]

Slide 34

“See Something, Say Something” Lack of Between-Car Barriers on Baltimore Metro

Maryland MTA Metro rapid rail/ subway cars cab end do not have any between car barrier.

Maryland MTA Metro rapid rail/ subway cars non-cab ends do not have any between car barrier.

[Images: photo of two MTA Metro rapid rail/subway cars showing two facing cab ends that lack any pantographs, chains, retractable belt barriers or platform based between car barriers and just have space between cars that a person could fall between. Photo of two MTA Metro rapid rail/subway cars showing two facing non-cab ends that lack any pantographs, chains, retractable belt barriers or platform based between car barriers and just have space between cars that a person could fall between.]

Slide 35

Emerging issue -lack of Between-Car Barriers on level boarding light rail systems 49 C.F.R.§38.85

Phoenix Valley Metro light rail car front view

Phoenix Valley Metro, note lack of Between Car Barrier

[Images: Phoenix Valley Metro light rail cars exterior showing no between car barrier and space where an individual could step off the platform and fall.]

Slide 36

Platform-based Between Car Barriers on a level boarding light rail system49 C.F.R.§38.85

Charlotte Area Transit System (CATS) LYNX Blue Line light rail trains use platform-based Between Car Barriers

[Images: photo of two CATS LYNX Blue Line light rail cars with set of yellow vertical stanchions about 18 to 24 inches tall affixed to platform and form a Between Car Barrier. Photo of Charlotte Area Transit System (CATS) Lynx Blue line light rail train cars with yellow vertical stanchion Between Car Barriers far down the platform between two cars.]

Slide 37

September 15, 2016 FTA Dear Colleague Letter on Between-Car Barriers



[Images: page 1 of DOT dear colleague letter on between car barriers. Text is available at this link: . Page 2 of DOT dear colleague letter on between car barriers.]

Slide 38

Questionable between Car Barriers on Rapid Rail -D.C. Metro 7000 series cars49 C.F.R. §38.63

Washington Area Metropolitan Transit Authority D.C. Metro Rail Kawasaki 7000 series cars, rubber flap Between Car Barriers which has gap

[Images: photo of Washington D.C. Metro Rail 7000 series rapid rail cars with rubber flap Between Car Barriers that leave and open unprotected space between the flaps. Photo of Washington D.C. Metro Rail 7000 series rapid rail cars with rubber flap Between Car Barriers that leave and open unprotected space between the flaps. High view shows an individual’s hand with fingers spread out between the rubber flaps. Photo also shows that the rubber flaps are attached at a location set back several inches from the outer edge of the railcar.]

Slide 39

WMATA/D.C. Metro September 28, 2016 letter to FTA on Between-Car Barriers on 7000 series cars



[Images: three page letter from WMATA D.C. Metro to FTA on the Between car barriers on 7000 series cars.]

Slide 40

ADA Rapid Rail interior circulation, handrails, and stanchions requirements (49 C.F.R. §38.57)

§38.57 Interior circulation, handrails and stanchions.

(a) Handrails and stanchions shall be provided to assist safe boarding, on-board circulation, seating and standing assistance, and alighting by persons with disabilities.

(b) Handrails, stanchions, and seats shall allow a route at least 32 inches wide so that at least two wheelchair or mobility aid users can enter the vehicle and position the wheelchairs or mobility aids in areas, each having a minimum clear space of 48 inches by 30 inches, which do not unduly restrict movement of other passengers. Space to accommodate wheelchairs and mobility aids may be provided within the normal area used by standees and designation of specific spaces is not required. Particular attention shall be given to ensuring maximum maneuverability immediately inside doors. Ample vertical stanchions from ceiling to seat-back rails shall be provided. Vertical stanchions from ceiling to floor shall not interfere with wheelchair or mobility aid user circulation and shall be kept to a minimum in the vicinity of doors.

(c) The diameter or width of the gripping surface of handrails and stanchions shall be 1 1/4 inches to 1 1/2 inches or provide an equivalent gripping surface and shall provide a minimum 1 1/2 inches knuckle clearance from the nearest adjacent surface.

Slide 41

ADA Rapid Rail interior circulation, handrails and stanchions requirements (49 C.F.R. §38.57)

Above, WMATA/D.C. Metro Rail car showing wheelchair space & some floor to ceiling stanchions (poles).

Right, WMATA/D.C. Metro Rail CAF built 5000 series car delivered in 2000 showing high view of wheelchair space with seat folded and one floor to ceiling stanchion.

[Images: Washington Metropolitan Area Transit Authority, D.C. Metro Rail rapid rail car showing wheelchair space and two floor to ceiling stanchions (poles). Washington Metropolitan Area Transit Authority D.C. Metro Rail 5000 series car showing wheelchair space with folded up seat and one floor to ceiling stanchion (pole) and dirty carpeted floor.]

Slide 42

ADA Rapid Rail interior circulation, handrails and stanchions requirements (49 C.F.R. §38.57)

WMATA/D.C. Metro Rail Kawasaki 7000 series car delivery began in 2014. Photo shows with open circulation space, wheelchair space that has handholds and handholds attached to seat backs and windscreens and no floor to ceiling stanchions

WMATA/D.C. Metro Rail Breda 3000 series car delivered in 1987 (pre-ADA) showing floor to ceiling stanchions (poles) (which are 30 inches apart rather than providing a route 32 inches wide required under the ADA)

[Images: photos of interior of Washington Metropolitan Area Transit Authority D.C. Metro Rail Breda 3000 series car delivered in 1987 (pre-ADA). Note floor to ceiling stanchions]

Slide 43

“See Something, Say Something” Lack of wheelchair spaces on Baltimore Metro Rapid Rail/Subway cars

Maryland MTA Metro Rapid Rail/Subway Car Interior.

What’s missing? Is there a wheelchair space? Was/is a wheelchair space required?

[Image: Photo of empty Maryland MTA Metro subway car interior that has no specific space for a wheelchair user.]

Slide 44

Likely configuration of future rapid rail (subway) cars

Bombardier TORONTO Rocket, TORONTO, CANADA (not covered by the ADA) but a similar design with full width gangways is specified for next NYC subway order

[Image: photo of interior of Bombardier Toronto Rocket rapid rail car. Car design includes open gangways between cars providing more space for passengers and easy movement between cars even for wheelchair users. Seats provide clear floor space underneath and have open design with ample handrails and stanchions that all are secured to rail car walls at the height just below bottom of seats.]

Slide 45

ADA Light Rail interior circulation, handrails and stanchions requirements (49 C.F.R. §38.77)

§38.77 -Interior circulation, handrails and stanchions.

(a) Handrails and stanchions shall be sufficient to permit safe boarding, on-board circulation, seating and standing assistance, and alighting by persons with disabilities.

(b) At entrances equipped with steps, handrails and stanchions shall be provided in the entrance to the vehicle in a configuration which allows passengers to grasp such assists from outside the vehicle while starting to board, and to continue using such handrails or stanchions throughout the boarding process. Handrails shall have a cross-sectional diameter between 1 1/4 inches and 1 1/2 inches or shall provide an equivalent grasping surface, and have eased edges with corner radii of not less than 1/8 inch. Handrails shall be placed to provide a minimum 1 1/2 inches knuckle clearance from the nearest adjacent surface. Where on-board fare collection devices are used, a horizontal passenger assist shall be located between boarding passengers and the fare collection device and shall prevent passengers from sustaining injuries on the fare collection device or windshield in the event of a sudden deceleration. Without restricting the vestibule space, the assist shall provide support for a boarding passenger from the door through the boarding procedure. Passengers shall be able to lean against the assist for security while paying fares.

(c) At all doors on level-entry vehicles, and at each entrance accessible by lift, ramp, bridge plate or other suitable means, handrails, stanchions, passenger seats, vehicle driver seat platforms, and fare boxes, if applicable, shall be located so as to allow a route at least 32 inches wide so that at least two wheelchair or mobility aid users can enter the vehicle and position the wheelchairs or mobility aids in areas, each having a minimum clear space of 48 inches by 30 inches, which do not unduly restrict movement of other passengers. Space to accommodate wheelchairs and mobility aids may be provided within the normal area used by standees and designation of specific spaces is not required. Particular attention shall be given to ensuring maximum maneuverability immediately inside doors. Ample vertical stanchions from ceiling to seat-back rails shall be provided. Vertical stanchions from ceiling to floor shall not interfere with wheelchair or mobility aid circulation and shall be kept to a minimum in the vicinity of accessible doors.

Slide 46

ADA Light Rail interior circulation, handrails and stanchions requirements (49 C.F.R. §38.77)

Portland Tri-Met Siemens SD660 light rail car showing two wheelchair spaces and priority seating.

Phoenix Valley Metro Kinkisharyo light rail car showing two wheelchair spaces & priority seating.

[Images: photo of interior of Kinkisharyo Phoenix Valley Metro light rail car showing long view down length of car and showing two wheelchair spaces and two sets of three longitudinal priority seats. Also shown are floor to ceiling stanchions withhold windscreens by the door and other stanchion curve onto wall providing clear knee and toe space. Also shown are handrails on seatbacks. Photo of Portland Tri-Met Siemens SD660 light rail car interior showing how two wheelchair spaces are marked with the International Symbol of Accessibility on the floor with the long dimension parallel to the car. Photo also show two sets of two priority seats facing the end of the car with one set folded up and the other set down and an additional set of longitudinal priority seats folded up.]

Slide 47

Light Rail interior circulation, handrails and stanchions requirements (49 C.F.R. §38.77)

On left, Minneapolis Metro Transit Bombardier Flexity Swift light rail car wheelchair space.

Above, Minneapolis Metro Transit Siemens S70 light rail car wheelchair space & priority seating

[Images: photo of interior of Minneapolis Metro Transit Bombardier Flexity Swift low floor light rail car showing wheelchair space and signage, other seats with grabs on top of seat, stanchions and wheelchair user in the aisle. Photo of interior of Minneapolis Metro Transit Siemens S70 low floor light rail car showing wheelchair space and priority seating, folded up and signage and stanchions.]

Slide 48

ADA Light Rail interior circulation, handrails and stanchions requirements (49 C.F.R. §38.77)

Phoenix Valley Metro Kinkisharyo light rail car wheelchair space and priority seats and signage

Wheelchair space in Charlotte Lynx Siemens S70 (same as Minneapolis Metro. Seem small?)

[Images: Charlotte Area Transit System (CATS) Siemems S70 LYNX Blue Line light rail car interior showing wheelchair space which seems to envision wheelchair user perpendicular to movement of car. Photo of Phoenix Valley Metro Kinkisharyo light rail car wheelchair space with the long dimension parallel to length of car. There are three longitudinal fold up priority seats with International Symbol of Accessibility and Priority seating signage.]

Slide 49

Commuter railcar mobility aid accessibility49 C.F.R. §38.95

• Requires new commuter cars to provide either level boarding or have level change mechanism

• Provides detailed specifications for load, controls, emergency operation, power or equipment failure, and platform details.

• Provides specifics for car ramps and bridgeplates

and

• Has requirements for mobility aid seating location

Slide 50

Commuter rail car mobility aid seating location49 C.F.R. §38.95

Above, wheelchair space on lower level of Minnesota Northstar Bombardier bi-level commuter car.

Left, wheelchair space on Portland Tri-Met Westside Express Service using single level Colorado Rail Car Diesel Multiple Unit railcar

[Images: photo of interior of Portland Tri-Met Westside Express Service Colorado Rail Car Diesel Multiple Unit Railcar, showing wheelchair space and signage, rest of seats with handholds on seat sides. Photo of interior of Minnesota Northstar Bombardier bi-level commuter railcar showing lower level, wheelchair space and priority seating with two seats folded up, on seat folded down and showing carborne lift in foreground.]

Slide 51

ADA Commuter Railcar restroom provisions49 C.F.R. §38.107

§38.107 Restrooms.

(a) If a restroom is provided for the general public, it shall be designed so as to allow a person using a wheelchair or mobility aid to enter and use such restroom as specified in paragraphs (a) (1) through (5) of this section.

(1) The minimum clear floor area shall be 35 inches by 60 inches. Permanently installed fixtures may overlap this area a maximum of 6 inches, if the lowest portion of the fixture is a minimum of 9 inches above the floor, and may overlap a maximum of 19 inches, if the lowest portion of the fixture is a minimum of 29 inches above the floor, provided such fixtures do not interfere with access to the water closet. Fold-down or retractable seats or shelves may overlap the clear floor space at a lower height provided they can be easily folded up or moved out of the way.

(2) The height of the water closet shall be 17 inches to 19 inches measured to the top of the toilet seat. Seats shall not be sprung to return to a lifted position.

(3) A grab bar at least 24 inches long shall be mounted behind the water closet, and a horizontal grab bar at least 40 inches long shall be mounted on at least one side wall, with one end not more than 12 inches from the back wall, at a height between 33 inches and 36 inches above the floor.

(4) Faucets and flush controls shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls shall be no greater than 5 lbs. (22.2 N). Controls for flush valves shall be mounted no more than 44 inches above the floor.

(5) Doorways on the end of the enclosure, opposite the water closet, shall have a minimum clear opening width of 32 inches. Doorways on the side wall shall have a minimum clear opening width of 39 inches. Door latches and hardware shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist.

(b) Restrooms required to be accessible shall be in close proximity to at least one seating location for persons using mobility aids and shall be connected to such a space by an unobstructed path having a minimum width of 32 inches.

Slide 52

Restrooms in commuter railcars49 C.F.R. §38.107

Above, accessible restroom on lower level of Amtrak California bi-level car (which is sort of a hybrid between a commuter rail car and an intercity rail car). The maximum dimensions of the restroom are approximately 65 inches by 75 inches.

Above, restroom on lower level of Minnesota Northstar Bombardier bi-level commuter car.

[Images: photo of accessible restroom on lower level of Amtrak California bi-level car (which is sort of a hybrid between a commuter rail car and an intercity rail car). The maximum dimensions of the restroom are approximately 65 inches by 75 inches. Note grab bars on opposite walls of the restroom. Photo of interior of Minnesota Northstar Bombardier bi-level commuter rail car. Note locations of grab bars, and other restroom elements.]

Slide 53

Restrooms in commuter railcars49 C.F.R. §38.107

Restroom in Virginia Railway Express (VRE) Nippon Sharyo Gallery car

Restroom in Maryland Area Regional Commuter (MARC) Kawasaki MARC III multilevel car

[Images: photo of interior of Virginia Railway Express (VRE) Nippon Sharyo Gallery commuter rail restroom. Photo of interior of Maryland Area Regional Commuter (MARC) Kawasaski MARC III rail car restroom.]

Slide 54

ADA Public Information System Requirements

Rapid Rail

§38.61 Public information system.

(a) (1) Requirements. Each vehicle shall be equipped with a public address system permitting transportation system personnel, or recorded or digitized human speech messages, to announce stations and provide other passenger information. Alternative systems or devices which provide equivalent access are also permitted. Each vehicle operating in stations having more than one line or route shall have an external public address system to permit transportation system personnel, or recorded or digitized human speech messages, to announce train, route, or line identification information.

(2)Exception. Where station announcement systems provide information on arriving trains, an external train speaker is not required.

(b) [Reserved]

Light Rail

§38.87 Public information system.

(a) Each vehicle shall be equipped with an interior public address system permitting transportation system personnel, or recorded or digitized human speech messages, to announce stations and provide other passenger information. Alternative systems or devices which provide equivalent access are also permitted.

(b) [Reserved]

Commuter Rail

§38.121 Public information system.

(a) Each car shall be equipped with a public address system permitting transportation system personnel, or recorded or digitized human speech messages, to announce stations and provide other passenger information. Alternative systems or devices which provide equivalent access are also permitted.

(b) [Reserved]

Slide 55

Public Address/Communications in Rail Vehicles

Above, visual public address display on New Mexico Rail Runner Bombardier Bi-Level Commuter

Upper Right, variable message moving map on D.C. Metro 7000 series rapid rail cars

Lower Right, video display map with connecting and other information on D.C. Metro 7000 series rapid rail car.

[Images: photo of video visual public address display on New Mexico Rail Runner Bombardier Bi-Level Commuter in 2016, providing information that "Smoking including E-cigarettes is not permitted on platform or inside the train" and "Next Station: Santa Fe Co./NM 599. These video displays were not on cars in 2011.Photo of variable message moving route map on D.C. Metro 7000 series rapid rail cars showing next station is Union Station and showing next five stops and last stops at the end of the line and the number of stops. Photo of D.C. Metro Rail 7000 series car, video display map showing next stop being Rhode Island Avenue, and showing next three stops on strip map and last stop for train. Video display sign provides additional information of services and features at each station]

Slide 56

Accessible Stations -ADA Statutory New Construction & Alterations Requirements

Sec. 12146. New facilities

For purposes of section 12132 of this title and section 794 of title 29, it shall be considered discrimination for a public entity to construct a new facility to be used in the provision of designated public transportation services unless such facility is readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs.

Sec. 12147. Alterations of existing facilities

(a) General rule

With respect to alterations of an existing facility or part thereof used in the provision of designated public transportation services that affect or could affect the usability of the facility or part thereof, it shall be considered discrimination, for purposes of section 12132 of this title and section 794 of title 29, for a public entity to fail to make such alterations (or to ensure that the alterations are made) in such a manner that, to the maximum extent feasible, the altered portions of the facility are readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs, upon the completion of such alterations. Where the public entity is undertaking an alteration that affects or could affect usability of or access to an area of the facility containing a primary function, the entity shall also make the alterations in such a manner that, to the maximum extent feasible, the path of travel to the altered area and the bathrooms, telephones, and drinking fountains serving the altered area, are readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs, upon completion of such alterations, where such alterations to the path of travel or the bathrooms, telephones, and drinking fountains serving the altered area are not disproportionate to the overall alterations in terms of cost and scope (as determined under criteria established by the Attorney General).

Slide 57

Newly Constructed Commuter Rail Stations

Minnesota Northstar Stations, from left to right, Anoka, Coon Rapids, and Ramsey, MN

[Images: photo of Coon Rapids, MN Northstar train station showing over the tracks bridge and elevator and stair tower on far side of the tracks. Photo of Anoka, MN Northstar platform, station building anb bridge over the tracks. Photo of Ramsey, MN Northstar train station showing elevator and stair tower on far side of the tracks and bridge over the tracks.]

Slide 58

Alterations of Rapid Rail Stations to provide accessibility

Street to station elevator kiosk in the style of original stairway kiosks at New York City MTA rapid rail Brooklyn Bridge-City Hall Subway Station for #4, #5 #6 trains

[Image: street to station elevator at New York City MTA rapid rail Brooklyn Bridge-City Hall Subway Station for #4, #5 #6 trains. Architecture of the elevator kiosk replicates older New York City Subway stairway entrances]

Slide 59

Recent ADA Station Litigation

Earlier this year, there have been two new cases filed against transit agencies for failure to maintain accessible features under the ADA and a case seeking improved station access under state law. All three cases filed by Disability Rights Advocates with co-counsel from Legal Aid at Work against BART and the law firm Sheppard Mullin and the NYCTA and MTA.

• Senior and Disability Action, et al. v. San Francisco Bay Area Rapid Transit District (N.D. Calif.) filed April 5, 2017

• Center for Independence of the Disabled New York (CIDNY), et al. v. New York City Transit Authority (NYCTA), et al. (S.D.N.Y.)

• Center for Independence of the Disabled New York (CIDNY), et al. v. New York City Transit Authority (NYCTA), et al.(N.Y. State Supreme Court) –LATER TWO both filed April 25, 2017

Slide 60

Fare Machines & Web Accessibility

2010 ADA Accessibility Guidelines

§220 Automatic Teller Machines and Fare Machines

• Provide at least one compliant with 707 §707 Automatic Teller Machines and Fare Machines

• Standards for clear floor space, operable parts, privacy, speech output, receipts, input controls, numerical keypads, function keys, tactile symbols, display screen and braille

Web no ADA regulations but clear DOJ enforcement activity requiring compliance with the Web Content Accessibility Guidelines 2.0, Level AA.

Slide 61

Fare Machines

Minneapolis Metro Transit Fare Machine

Charlotte Area Transit System (CATS) LYNX Blue Line Fare Machine

[Images: photo of Minneapolis Metro Transit Fare Machine. Photo of Charlotte Area Transit System (CATS) LYNX Blue Line Fare Machine]

Slide 62

Inaccessible WMATA/D.C. Metro Smart Trip card machines

All Metro stations now have SmarTrip vending machines

By Luz Lazo

November 6, 2012

Washington Post

After months of delays, SmarTrip card vending machines are now available at every Metrorail station.

The transit agency has been installing new machines across the system, and with older machines in place in 47 stations, Metro now has at least one machine in each of the system’s 86 stations.

Installation of the 100 new machines was put on hold this year after disability advocates complained in August that the new dispensers did not comply with the Americans With Disabilities Act.

Metro said it planned to add Braille and an audio feature once the machines were in use, but under pressure, officials opted to keep the machines out of service until all of them were made accessible to people with sight impairments.

“We learned some lessons,” Christian T. Kent, assistant general manager of access services, told members of the Metro’s Accessibility Advisory Committee on Monday.

“We learned how important it is before we deploy any equipment to have proper vetting,” he said.

Slide 63

Another fare system accessibility issue

BART Clipper Card

Date Settled: 11/24/2015

BART Clipper Card (fare payment card) readers at BART fare gates did not provide any audible feedback so blind passengers could not easily determine whether to move through the gates or whether they would not be able to because of an error or low-balance.

BART and the Metropolitan Transportation Commission (“MTC”) signed a settlement in which they agreed to improve the accessibility of the Clipper Card system at BART stations by modifying the fare gates to emit audible Tagging Tones.

The Tagging Tones will now communicate to blind or low-vision passengers their successful entry or exit through a fare gate, as well as any error or low-balance on their Clipper Cards.

Slide 64

Houston METRO Website Agreement

METROPOLITAN TRANSIT AUTHORITY OF HARRIS COUNTY ANNOUNCES DIGITAL ACCESSIBILITY INITIATIVE

HOUSTON (March 17, 2016) —Consistent with its commitment to all of its riders, the Metropolitan Transit Authority of Harris County (“METRO”) today announced an initiative to make its affiliated websites, mobile applications, and print formation more accessible and inclusive.

METRO adopted the Web Content Accessibility Guidelines (WCAG) version 2.0 level AA as its accessibility standard and is making enhancements to work toward meeting this standard. METRO will also continue providing braille, large print, electronic, and audio versions of print information to riders with visual impairments upon their request within a reasonable time after the request has been made.

METRO worked with blind riders and with Disability Rights Texas, a non-profit legal advocacy agency serving Texans with disabilities, on its accessibility initiative.

[Image: screenshot of Houston Transit Authority Website Houston Transit Authority Website]

Slide 65

Accessibility Nationwide, a mix

• Newer light rail systems and new commuter rail cars and stations are largely accessible

• Some older rail systems are getting better but some have a long way to go:

• For example, as of November 2016, 106 out of 139 (75%) of MBTA commuter rail stations were accessible.

• Key requirement is to maintain infrastructure, particularly elevators

SHINING EXAMPLE

• MassDOT–Office of Performance Management & Innovation MBTA 2016

Scorecard page 65



[Image: shows chart with the following information; Performance measure for Platform accessibility (all rapid transit stations with elevators), current FY16 is 99.5% (April 2015 -March 2016) +0.1% change from FY 15 (April 2014 -March 2015) the two year target is in development. Performance measure for Vehicle accessibility (Green Line), current FY16 98.6% no data change from FY15. Two year target is in development. Performance measure for Customer satisfaction, current FY16 is 3.2, no data change from FY15. Two year target is in development.]

Slide 66

An Inspiration for Rail Accessibility Advocacy

“Grab Bar” over bed in President Franklin D. Roosevelt’s 1920s-1930s Private Rail Car, the “Marco Polo”

[Image: photo of “Grab Bar” over bed in President Franklin D. Roosevelt’s 19202-1930's Private Rail Car, the “Marco Polo.”]

Slide 67

Questions?

Hope you enjoyed this presentation. I had fun putting it together.

All photographs except for the MBTA mini-high platform were taken by Kenneth Shiotani.

Contact information: Kenneth Shiotani Senior Staff Attorney

National Disability Rights Network

820 First Street Suite 740 Washington, DC 20002

(202) 408-9514 x 126

Kenneth.shiotani@

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