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36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

810 Transportation Facilities

In the final rule, provisions in Chapter 10 for transportation facilities have been integrated into other chapters. Most of these requirements are now located in section 810, but some provisions have been integrated into other sections:

  • 1001.1 Scope, now at 218

  • 1002.1 through 1002.4, Bus Stops and Terminals, located at 810.2 through 810.4

  • 1002.5 Bus Stop Siting, now at 209

  • 1003.1 Facilities and Stations, now at 218

  • 1003.2 New Construction, now at 218

  • 1003.2.1 Station Entrances, now at 206.4.4

  • 1003.2.2 Signs, now at 810.6

  • 1003.2.3 Fare Machines and Gates, covered generally by 220 (Fare Machines) and 206.5 (Gates)

  • 1003.2.4 Detectable Warnings, now at 810.5

  • 1003.2.5 Rail-to-Platform Height, now at 810.5

  • 1003.2.6 TTYs, now at 217.4.7

  • 1003.2.7 Track Crossings, now at 810.10

  • 1003.2.8 Public Address Systems, now at 810.7

  • 1003.2.9 Clocks, now at 810.8

  • 1003.2.10 Escalators, now at 810.9

  • 1003.2.11 Direct Connections, now at 206.4.4

  • 1003.3 Existing Facilities, now at 218

  • 1003.3.1 Accessible Route, covered generally by 206 (Accessible Routes) and by 810.9 (Escalators

  • 1003.3.2 Rail-to-Platform Height, now at 810.5

  • 1003.3.3 Direct Connections, now at 206.4

  • 1004.2 TTYs (in airports), now at 217.4.7

  • 1004.3 Terminal Information Systems (in airports), now at 810.7

  • 1004.4 Clocks (in airports), now at 810.8

Section 810 provides requirements for bus boarding and alighting areas (810.2), bus shelters (810.3), and bus signs (810.4). Revisions address:

  • bus boarding and alighting areas, including specified dimensions (810.2.2)clarification of requirements for bus shelters (810.3)

Comment. Specifications in 810.2 for bus stops applied to "bus stop pads" in the proposed rule. Comments noted that this reference has been misinterpreted as applying to the vehicle space for buses which are sometimes provided with concrete pads, instead of to adjacent boarding areas.

Response. For clarity, the Board has applied requirements to "bus stop boarding and alighting areas" instead of to "bus stop pads."

Comment. Bus stop boarding and alighting areas are required to be at least 96 inches long and 60 inches wide. The proposed rule specified that these dimensions were required to "the maximum extent allowed by legal or site constraints" (1002.2.2). Comments considered this language unclear or unnecessary.

Response. The reference to legal or site constraints was intended to cover existing conditions that would effectively preclude sizing boarding and alighting areas to the minimum dimensions specified, such as narrow sidewalks. The Board has removed this language in section 810.2.2 in favor of a general scoping provision for alterations (202.3) which recognizes instances where compliance is not technically feasible. In such cases, compliance is required to the maximum extent feasible.

Section 810.3 addresses bus shelters, which are required to provide wheelchair space. The Board has included clarification that this space be located "entirely within the shelter" so that persons occupying the space can be adequately sheltered from the elements.

Requirements for rail stations and airports are provided in sections 810.5 through 810.10. Most of these provisions apply specifically to rail stations, but some are applicable to airports as well, such as requirements for public address systems (810.7) and clocks (810.8). Revisions made to these provisions address:

Comment. Commenters advised that the specifications should address platforms for light rail vehicles which should be allowed to conform to the grade of the street.

Response. The Board has explicitly specified that rail platforms shall slope no more than 1:48 in any direction, consistent with cross slope provisions for walking surfaces in section 403. An exception has been added for platforms at existing tracks or tracks laid in existing roadways (810.5.1). Such platforms are permitted to have a slope parallel to the track that is equal to the slope (grade) of the roadway or existing track.

Rail platform requirements include specifications for detectable warnings along platform boarding edges not protected by screens or guards (810.5.2). The Board has added clarification that detectable warnings be provided "along the full length of the public use area of the platform."

The proposed rule, consistent with the original ADAAG, provided specifications for the coordination of vehicles and platforms, including maximum changes in level (plus or minus e inch) and horizontal gaps (3 inches for rail vehicles, 1 inch for automated guideway systems). Alternate specifications were provided for existing vehicles and stations. These requirements are paralleled in the Board’s ADA Accessibility Guidelines for Transportation Vehicles.28 For simplicity, the Board has replaced requirements in section 810.5 with references to these specifications as contained in the guidelines for transportation vehicles (810.5.3). This revision does not substantively change the requirements for the coordination of platforms and vehicle floors.

Comment. The referenced vehicle guidelines (like those of the proposed rule) permit the use of mini high platforms, car-borne or platform-mounted lifts, ramps or bridge plates, or manually deployed devices where it is not operationally or structurally feasible to meet the specified changes in level or horizontal gaps. In the case of commuter and intercity rail systems, this is often due to track that is also used by freight trains because the passage of oversized freight precludes a high level platform. The American Railway Engineering and Maintenance of Way Association had previously recommended a new platform height of 8 inches above top of rail. This height allows for freight passage while reducing the height of the first step of a rail car above the platform. Often a portable step stool is used to make up the height difference between a lower platform and the first step. Negotiating such a step can be difficult for ambulatory passengers, especially since handrails are usually not available. Also, requiring the 8 inch height would reduce the vertical travel distance for a lift. The Board sought comment on whether new platforms for commuter or intercity rail stations should have a height of 8 inches above top of rail (Question 47). Most comments supported such a requirement.

Response. The Board had added a requirement that low level platforms be at least 8 inches above top of rail (810.5.3). An exception intended for light rail systems allows a height below 8 inches where vehicles are boarded from sidewalks or at street level.

Comment. Section 810.6 addresses requirements for station signage, including signs at entrances, route and destination signs, and station names. These provisions reference requirements for tactile and visual characteristics in section 703. Commenters urged the Board to recognize audible signs as an alternative to tactile signs since they can provide equal or greater access to information.

Response. The Board has added an exception under which entrance, route, and destination signs do not have to comply with visual and tactile specifications where certain audible sign technologies are provided. The exception specifically recognizes those technologies that involve hand-held receivers, activation by users, or detection of people in proximity to the sign.

Comment. Requirements for route and destination signs are subject to specifications for visual signs in section 703, including character height (810.6.2). The proposed rule allowed certain signs to have a 3 inch minimum height where space is limited and a 1 ½ inch height for characters on signs not essential to the use of the transit system (1003.2.2.3, Exception). Comments pointed out that this exception should allow characters to be less than 3 inches high for consistency with the character heights specified for signs generally in section 703.

Response. The Board has corrected this exception so that characters are not required to be more than 3 inches high where sign space is limited. This would apply to conditions where signs are more than 10 feet above the ground or floor and the viewing distance is 21 feet or more (the only types of signs required by section 703.5 to have characters more than 3 inches high). The Board has removed as unnecessary the exception for signs not essential to the use of the transit system, such as exit street names.

Section 810.7 covers public address systems in rail stations and airports. The proposed rule required that where public address systems are provided to convey information to the public, a means of conveying the same or equivalent information to persons who are deaf or hard of hearing be provided. The Board has simplified this provision so that it requires "the same or equivalent information ... in a visual format."

Comment. In the proposed rule, the Board sought information for its use in future rule making to update the Board’s transportation vehicle guidelines. Specifically, the Board requested information on technologies for providing train announcements, including station announcements and emergency announcements, in a visual format so that this information is conveyed to people who are deaf or hard of hearing (Question 46). Recommendations included use of message boards for verbal announcements and visual signals, such as a flashing light, or audible signals such as bells and chimes. Some commenters recommended that this issue be revisited in rule making specific to the vehicle guidelines.

Response. The Board intends to further explore this issue during rule making to update its accessibility guidelines for transportation vehicles.

Comment. Escalators must have a clear width of 32 inches minimum (810.9). The original ADAAG contained a requirement that at least two contiguous treads be level beyond the comb plate at the top and bottom before risers begin to form (ADAAG 10.3.1(16)). It also required color contrast on treads. Both provisions were removed in the proposed rule as recommended by the advisory committee, which questioned the need for such criteria in guidelines for accessibility. Comments requested that these specifications be restored for greater access. Commenters noted that the required color contrast benefits persons with low vision.

Response. In the final rule, the Board has added a reference to relevant provisions in the ASME A17.1 Safety Code for Elevators and Escalators instead of providing its own specification (810.9). This will ensure consistency with the safety code. The ASME code requires steps to be demarcated by yellow lines 2 inches wide maximum along the back and sides of steps (ASME A17.1, section 6.1.3.5.6). It also requires at least two flat steps and no more than four flat steps at the entrance and exit of every escalator (ASME A17.1, section 6.1.3.6.5). Consistent with the original ADAAG, an exception from these requirements is provided for existing escalators in key stations (810.9, Exception).

Section 810.10 addresses track crossings at transportation facilities. The proposed rule required route surfaces to be level with the rail top, but permitted a 2 ½ inch gap at the inner edge of rails to accommodate wheel flanges (1003.2.7). Where this gap is not practicable, an above-grade or below grade accessible route was specified. In the final rule, the Board has simplified this provision by applying specifications for accessible routes. An exception preserves the permitted 2 ½ inch gap for wheel flanges.

28 36 CFR part 1192

Comment. Escalators must have a clear width of 32 inches minimum (810.9). The original ADAAG contained a requirement that at least two contiguous treads be level beyond the comb plate at the top and bottom before risers begin to form (ADAAG 10.3.1(16)). It also required color contrast on treads. Both provisions were removed in the proposed rule as recommended by the advisory committee, which questioned the need for such criteria in guidelines for accessibility. Comments requested that these specifications be restored for greater access. Commenters noted that the required color contrast benefits persons with low vision.

Response. In the final rule, the Board has added a reference to relevant provisions in the ASME A17.1 Safety Code for Elevators and Escalators instead of providing its own specification (810.9). This will ensure consistency with the safety code. The ASME code requires steps to be demarcated by yellow lines 2 inches wide maximum along the back and sides of steps (ASME A17.1, section 6.1.3.5.6). It also requires at least two flat steps and no more than four flat steps at the entrance and exit of every escalator (ASME A17.1, section 6.1.3.6.5). Consistent with the original ADAAG, an exception from these requirements is provided for existing escalators in key stations (810.9, Exception).

Comment. Requirements for route and destination signs are subject to specifications for visual signs in section 703, including character height (810.6.2). The proposed rule allowed certain signs to have a 3 inch minimum height where space is limited and a 1 ½ inch height for characters on signs not essential to the use of the transit system (1003.2.2.3, Exception). Comments pointed out that this exception should allow characters to be less than 3 inches high for consistency with the character heights specified for signs generally in section 703.

Response. The Board has corrected this exception so that characters are not required to be more than 3 inches high where sign space is limited. This would apply to conditions where signs are more than 10 feet above the ground or floor and the viewing distance is 21 feet or more (the only types of signs required by section 703.5 to have characters more than 3 inches high). The Board has removed as unnecessary the exception for signs not essential to the use of the transit system, such as exit street names.

Section 810.10 addresses track crossings at transportation facilities. The proposed rule required route surfaces to be level with the rail top, but permitted a 2 ½ inch gap at the inner edge of rails to accommodate wheel flanges (1003.2.7). Where this gap is not practicable, an above-grade or below grade accessible route was specified. In the final rule, the Board has simplified this provision by applying specifications for accessible routes. An exception preserves the permitted 2 ½ inch gap for wheel flanges.

Comment. Section 810.6 addresses requirements for station signage, including signs at entrances, route and destination signs, and station names. These provisions reference requirements for tactile and visual characteristics in section 703. Commenters urged the Board to recognize audible signs as an alternative to tactile signs since they can provide equal or greater access to information.

Response. The Board has added an exception under which entrance, route, and destination signs do not have to comply with visual and tactile specifications where certain audible sign technologies are provided. The exception specifically recognizes those technologies that involve hand-held receivers, activation by users, or detection of people in proximity to the sign.

Comment. Commenters advised that the specifications should address platforms for light rail vehicles which should be allowed to conform to the grade of the street.

Response. The Board has explicitly specified that rail platforms shall slope no more than 1:48 in any direction, consistent with cross slope provisions for walking surfaces in section 403. An exception has been added for platforms at existing tracks or tracks laid in existing roadways (810.5.1). Such platforms are permitted to have a slope parallel to the track that is equal to the slope (grade) of the roadway or existing track.

Rail platform requirements include specifications for detectable warnings along platform boarding edges not protected by screens or guards (810.5.2). The Board has added clarification that detectable warnings be provided "along the full length of the public use area of the platform."

The proposed rule, consistent with the original ADAAG, provided specifications for the coordination of vehicles and platforms, including maximum changes in level (plus or minus e inch) and horizontal gaps (3 inches for rail vehicles, 1 inch for automated guideway systems). Alternate specifications were provided for existing vehicles and stations. These requirements are paralleled in the Board’s ADA Accessibility Guidelines for Transportation Vehicles.28 For simplicity, the Board has replaced requirements in section 810.5 with references to these specifications as contained in the guidelines for transportation vehicles (810.5.3). This revision does not substantively change the requirements for the coordination of platforms and vehicle floors.

28 36 CFR part 1192

Comment. Specifications in 810.2 for bus stops applied to "bus stop pads" in the proposed rule. Comments noted that this reference has been misinterpreted as applying to the vehicle space for buses which are sometimes provided with concrete pads, instead of to adjacent boarding areas.

Response. For clarity, the Board has applied requirements to "bus stop boarding and alighting areas" instead of to "bus stop pads."

Comment. Bus stop boarding and alighting areas are required to be at least 96 inches long and 60 inches wide. The proposed rule specified that these dimensions were required to "the maximum extent allowed by legal or site constraints" (1002.2.2). Comments considered this language unclear or unnecessary.

Response. The reference to legal or site constraints was intended to cover existing conditions that would effectively preclude sizing boarding and alighting areas to the minimum dimensions specified, such as narrow sidewalks. The Board has removed this language in section 810.2.2 in favor of a general scoping provision for alterations (202.3) which recognizes instances where compliance is not technically feasible. In such cases, compliance is required to the maximum extent feasible. Section 810.3 addresses bus shelters, which are required to provide wheelchair space. The Board has included clarification that this space be located "entirely within the shelter" so that persons occupying the space can be adequately sheltered from the elements.

Comment. The referenced vehicle guidelines (like those of the proposed rule) permit the use of mini high platforms, car-borne or platform-mounted lifts, ramps or bridge plates, or manually deployed devices where it is not operationally or structurally feasible to meet the specified changes in level or horizontal gaps. In the case of commuter and intercity rail systems, this is often due to track that is also used by freight trains because the passage of oversized freight precludes a high level platform. The American Railway Engineering and Maintenance of Way Association had previously recommended a new platform height of 8 inches above top of rail. This height allows for freight passage while reducing the height of the first step of a rail car above the platform. Often a portable step stool is used to make up the height difference between a lower platform and the first step. Negotiating such a step can be difficult for ambulatory passengers, especially since handrails are usually not available. Also, requiring the 8 inch height would reduce the vertical travel distance for a lift. The Board sought comment on whether new platforms for commuter or intercity rail stations should have a height of 8 inches above top of rail (Question 47). Most comments supported such a requirement.

Response. The Board had added a requirement that low level platforms be at least 8 inches above top of rail (810.5.3). An exception intended for light rail systems allows a height below 8 inches where vehicles are boarded from sidewalks or at street level.

Section 810.7 covers public address systems in rail stations and airports. The proposed rule required that where public address systems are provided to convey information to the public, a means of conveying the same or equivalent information to persons who are deaf or hard of hearing be provided. The Board has simplified this provision so that it requires "the same or equivalent information ... in a visual format."

Comment. In the proposed rule, the Board sought information for its use in future rule making to update the Board’s transportation vehicle guidelines. Specifically, the Board requested information on technologies for providing train announcements, including station announcements and emergency announcements, in a visual format so that this information is conveyed to people who are deaf or hard of hearing (Question 46). Recommendations included use of message boards for verbal announcements and visual signals, such as a flashing light, or audible signals such as bells and chimes. Some commenters recommended that this issue be revisited in rule making specific to the vehicle guidelines.

Response. The Board intends to further explore this issue during rule making to update its accessibility guidelines for transportation vehicles.

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