36 CFR Part 1192 Americans with Disabilities Act (ADA) Accessibility Guidelines for Transportation Vehicles (2016 Non-Rail Vehicle Guidelines) - Preamble

2. Benefits: Qualitative Summary of Benefits

Benefits of the revised accessibility requirements in the 2016 Non-Rail Vehicle Guidelines to persons with disabilities (and others)—while significant—are not quantified or monetized in the Final RA, but instead described from a qualitative perspective. Such benefits are particularly challenging to quantify or monetize due to a variety of considerations. These challenges include: (a) a lack of current, reliable statistics on ridership by persons with specific disabilities on transit buses and OTRBs; (b) the fact that persons with disabilities will experience benefits differently, depending on the nature of their respective disabilities, and the current level of accessibility provided by the transit system or OTRB they wish to use; (c) the unknown extent to which improved accessibility of transit buses and OTRBs may either spur new demand among persons with disabilities who do not currently use such vehicles due to accessibility barriers that are addressed by the 2016 Non-Rail Vehicle Guidelines, or increase demand among current passengers with disabilities; (d) the extent to which persons with disabilities have reliable access to transportation, since, even when accessible, vehicles cannot be used if a potential passenger cannot reach them; (e) personal transportation preferences of persons with disabilities, who, like all individuals, make transit decisions for multiple reasons, some of which are unrelated to accessibility; and (f) the inherent challenges posed by monetization of key benefits of the 2016 Non-Rail Vehicle Guidelines, such as equity, fairness, independence, and better integration into society.

While the foregoing factors make formal quantification or monetization of the 2016 Non-Rail Vehicle Guidelines’ benefits inherently difficult, their significant benefits can still be amply described. The most significant benefits from the 2016 Non-Rail Vehicle Guidelines are expected to flow from the automated stop and route announcement systems requirement. The failure to announce stops and other identifying route information has been a recurring problem under the existing regulatory regime. See Final RA, Section 3.2. By requiring audible and visible notification of upcoming stops and identifying route information through automated announcements, the new requirement is expected to deliver significant benefits to passengers with vision- or hearing-related disabilities who use fixed route buses and OTRBs, or who would use such services absent communications barriers. Id. at Section 6.

Consistent and intelligible stop and route announcements, for example, may enable passengers who are blind or have low vision—for the first time—to use fixed route service independently, or permit them to do so more reliably and with greater frequency. Automated announcements are also expected to generate time savings by lessening (if not preventing) situations in which passengers with vision- or hearing-related disabilities disembark at the wrong stop, and then must wait for another bus (or other means of transportation) to transport them to their desired destination. In sum, the automated announcement systems requirement will not only deliver direct and substantial benefits to fixed route passengers with vision- or hearing-related disabilities, but will also promote fairness by ensuring a more consistent approach to announcements on fixed route buses across the country.

Individuals with other types of disabilities may also experience benefits from the automated announcement system requirement. Studies have shown that individuals with cognitive or intellectual disabilities also frequently face communications barriers when using fixed route transit, and, thus will benefit from consistent, reliable stop and route announcements, such as those provided by automated announcement systems.²⁰ Additionally, for individuals with significant mobility impairments, automated stop announcements may mean the difference between getting off at the correct stop and getting off at the wrong stop—due to unintelligible (or non-existent) stop or route announcements—to face a physically arduous or hazardous journey to his or her intended destination (or other location that gets the trip back on track). See Final RA, Section 6 (summarizing findings from transportation research studies on the importance of consistent and intelligible stop and route announcements to passengers with disabilities). 

For the new OTRB-related requirements, benefits are expected to be similar to, though perhaps more incremental than, the benefits accruing from automated announcement systems. These four new accessibility requirements—identification of wheelchair spaces and accessible doorways (with the International Symbol of Accessibility) and priority seats (with signs), exterior destination or route signage, public address systems, and stop request systems—are all aimed at addressing communication barriers to use of, or use of accessible features on, OTRBs. Signage of wheelchair spaces and priority seats is expected to enable passengers with disabilities to more readily locate these accessibility features. Signage for accessible seating may also aid in deterring passengers without disabilities from using priority seating or setting packages or strollers in wheelchair spaces (when such spaces are not otherwise occupied by flip-down seating), thereby keeping them available for passengers with disabilities. Similarly, having accessible stop request mechanisms within reach of passengers seated in accessible seating on fixed-route OTRBs ensures that passengers with disabilities who use such seating can independently indicate their desire to disembark at the next designated stop. Public address systems, in turn, enable passengers with hearing-related disabilities (as well as other passengers) to better understand information conveyed by the vehicle operator, which, in the event of an emergency, could be of urgent significance. Lastly, having exterior route or destination signage on the front and boarding sides of OTRBs aids passengers with disabilities by making it easier to ascertain a given vehicle’s route, destination, or identity. Having such signage in both locations is particularly important, for example, at transit hubs, bus terminals, areas where multiple vehicles are parked simultaneously, or other locations where traffic or terrain make circling to the front of the vehicle difficult or hazardous.

Additionally, it bears noting that other individuals and entities, including transit agencies, may benefit indirectly from new accessibility requirements in the 2016 Non-Rail Vehicle Guidelines. Several research studies on ITS deployments and automated announcement systems have shown that such systems often have the beneficial effect of increasing both customer satisfaction and ridership.²¹ For large transit agencies that do not yet have automated announcement systems, compliance costs incurred in deploying such systems might thus be offset in part by increases in fixed route ridership and fare revenue. Additionally, bus passengers who are unfamiliar with a particular route, or who are visiting from outside the area, may find the wayfinding assistance provided by automated stop and route announcements to be helpful.