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

F. Chapter 5: Doorways, Circulation Paths, and Fare Collection Devices

Chapter 5 in the 2016 Non-Rail Vehicle Guidelines contains the technical requirements for doorways, illumination at doorways and boarding and alighting areas, passenger access routes, and, where provided, fare collection devices. Chapter 5 has been significantly reorganized since the proposed rule, with two sections being moved out of this chapter and located elsewhere in the final rule (i.e., former T505 addressing handrails, stanchions, and handholds moved to scoping provisions in Chapter 2, and former T504 addressing steps moved to Chapter 4), and two other sections, which were formerly housed in other chapters of the proposed rule, now being located in this chapter (i.e., T503 Illumination, T505 Fare Collection Devices). The Board believes that this reorganization makes for a more cohesive presentation of the technical requirements in this chapter. Additionally, in the final rule, the technical requirements for vertical clearances at doorways with lifts or ramps and for illumination at doorway areas have been restated using text in lieu of the tabular formats in the proposed rule. Compare, e.g., 2010 NPRM, Table T503.1 (Vertical Clearance at Doorways with Lifts or Ramps) and Table T803 (Areas Illuminated and Illuminance Levels) with 2016 Non-Rail Vehicle Guidelines, Sections T502 (Doorways) and T503 (Illumination). Other provisions in this chapter have also undergone modest editorial changes aimed at clarifying or simplifying the regulatory text. Despite the foregoing organizational changes and editorial revisions to Chapter 5, the substance of the underlying technical requirements remains largely the same as in the proposed rule, with the exception of the requirements for passenger access routes.

T503 Passenger Access Routes

In the 2016 Non-Rail Vehicle Guidelines, passenger access routes (which were referred to as “accessible circulation paths” in the proposed rule) must provide clearances sufficient to permit passengers using wheelchairs to move between doorways with accessible boarding and alighting features and wheelchair spaces, and to maneuver in and out of wheelchair spaces. This requirement essentially mirrors the current provisions in the existing guidelines applicable to buses, OTRBs, and vans. See 36 CFR 1192.23(a) (“All [covered] vehicles . . . shall provide . . . sufficient clearances to permit a wheelchair or other mobility aid user to reach a securement location.”), 1192.159(a)(1) (establishing same requirement for OTRBs). In the 2010 NPRM, the Access Board proposed prescribing a specific dimensional standard (34 inches) for the clear width of passenger access routes. See 2010 NPRM, Section T502.2. For the reasons discussed previously, see Section III (Major Issues), the Board decided not to move forward with this proposal in the final rule. It is hoped that, in the near future, ongoing research on interior circulation on public transportation vehicles will yield a performance standard that will serve the needs of transit operators, bus and equipment manufacturers, and persons with disabilities alike. At present, however, no such performance standard exists that can be referenced in the final rule.

T504 Fare Collection Devices

Section T504 in the 2016 Non-Rail Vehicle Guidelines establishes specifications for the location of fare collection devices (to ensure that such devices do not impede wheelchair movement along passenger access routes), as well as their operable parts (to ensure such devices are reachable and usable by passengers with disabilities). These technical requirements mirror those proposed in the 2010 NPRM. However, the Access Board did not retain a proposed specification—which also appears in the existing guidelines for buses and vans—requiring fare collection devices, where provided, to be located “as close to the dashboard as practicable.” See 2010 NPRM, Section T502.3; see also 36 CFR 1192.33 (“Where provided, the farebox shall be located as far forward as possible[.]”). This change recognizes the possibility that some bus systems may also provide fare collection devices at center or rear doors. Wherever located, however, fare collection devices must not interfere with passenger circulation.

A transit agency expressed concern that application of the requirements in this section, in conjunction with the maximum mounting height for operable parts specified in T304 (i.e., operable parts cannot be located higher than 48 inches above the vehicle floor), would require fare collection devices to be mounted higher than the industry norm of 45 inches. The Access Board believes such concerns are misplaced, and has not modified the specified height range for operable parts on fare collection devices (or any other devices). Forty-eight inches is the maximum height at which parts intended for use by passengers may be located; it is not the required height for operable parts. Under the 2016 Non-Rail Vehicle Guidelines, operable parts may be located at any point within the specified range of 24 inches minimum and 48 inches maximum. Transit operators may thus continue to follow industry norm and mount fare collection devices such that their operable parts are located 45 inches above the vehicle floor.