49 CFR Parts 37 and 38 -- Transportation for Individuals With Disabilities at Intercity, Commuter, and High Speed Passenger Railroad Station Platforms; Miscellaneous Amendments, Preamble
DOT Response
In the Department's view, the ADA does not provide a statutory basis for requiring the expansion of the list of key stations, renovation of which for accessibility was to have been completed within a stated amount of time after the statute became effective. By incorporating the key station concept, the ADA clearly did not take the view that all existing stations in pre-ADA systems had to be retrofitted. The Department agrees with transit industry commenters who said that local decisions to react to changes in a system, plus the requirement to make alterations to stations in an accessible way, should be sufficient.
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