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

H. Chapter 7: Communication Features

Chapter 7 in the 2016 Non-Rail Vehicle Guidelines establishes technical requirements for characters on signs, the International Symbol of Accessibility, and vehicular announcement systems. With the exception of requirements addressing announcement systems in T704, this chapter has been neither reorganized nor substantively changed from the proposed rule. Section T704 in the final rule has been reorganized and editorially revised to improve clarity; these modifications, however, did not materially alter its terms. We received no comments on two of the three sections in Chapter 7—namely, Signs (T702) and International Symbol of Accessibility (T703)—and so these sections are not addressed below.

T704 Announcement Systems

The technical requirements for announcement systems include provisions on automated route identification announcement systems, automated stop announcement systems, and stop request systems. These requirements are intended to ensure that passengers with disabilities have the critical information needed to make public bus transportation systems accessible, usable, and safe for independent use by persons with disabilities.

Stop request systems must provide audible and visible notification onboard the non-rail vehicle indicating that a passenger has requested to disembark at the next stop. See T704.3. Audible notifications may be verbal or non-verbal signals, while visible notifications must include either signs (complying with T702), lights, or other visually perceptible indicators. Id. There are also specifications addressing when stop request notifications must extinguish. Id. Parts on stop request systems intended for passenger use must comply with the technical requirements for operable parts (T304), including height, location, and ease of use. The technical requirement in the final rule for stop request systems on buses and vans are similar to the existing guidelines. See 36 CFR 1192.37. At the request of a transit agency, the final rule does clarify that a mechanism for requesting stops must be located within reach of each wheelchair and priority seat. See T704.3.2.

Automated announcement systems must also provide both audible and visible notifications. See T704.2, T704.4. Automated route identification systems must audibly and visibly identify the route on which the bus is operating. Automated stop announcement systems must provide audible and visible notification of upcoming stops on fixed routes. For both types of automated announcement systems, audible messages must be delivered using synthesized, recorded or digitized speech. For stop announcement systems, such messages must be audible within the bus, while, for route announcement systems, audible messages must be broadcasted externally at boarding and alighting areas. With respect to visible components, route identification systems are required to provide signs displaying route information on the front and boarding sides of the vehicle. For stop announcement systems, signs must be provided onboard and be viewable from all wheelchair spaces and priority seats. (Signs for each type of automated announcement system must also comply with T702.)

The vast majority of comments received in response to the Access Board’s proposed requirements for automated announcement systems in the 2010 NPRM related to the scoping for these requirements (i.e., automated announcement systems must be provided by large transit agencies that operate 100 or more buses in annual maximum service in fixed route bus modes), rather than the technical specifications for such systems. Comments related to the scoping requirements for automated announcement systems are addressed at length in Section III (Major Issues) and IV (Summary of Comments and Responses on Other Aspects of the Proposed Rule – Chapter 2: Scoping Requirements).

Several commenters, including a public transportation organization, a transit agency, and individuals with disabilities, recommended that the Access Board include standards for the volume or quality (clarity) of audible components of automated announcement systems in the final rule. Other commenters, while not specifically opining on audibility standards, noted that the volume of announcements can sometimes be inconsistent or need adjustment in real-time to account for ambient noise.

While the Access Board shares these commenters’ view that the audibility of stop and route information is a critical aspect of announcement systems, we are not aware of any national standards that would provide clear, objective, and consistent measures to assess compliance. Indeed, in the 2010 NPRM, the Board requested information on standards for audio quality that could be referenced in the final rule or, in the alternative, recommended in advisory materials. See 2010 NPRM, 75 FR at 43754 (Question 19). No commenters suggested or cited any referenceable standards for audio quality. Absent such standards, the Board declines at this time to include specifications for audio volume or quality in the technical requirements for automated announcement systems. However, should referenceable standards for audio quality of announcements in public transportation vehicles be developed, the Board will certainly consider referencing such standards in future rulemakings. Additionally, when DOT initiates its own rulemaking process to adopt these revised guidelines as enforceable standards for buses, OTRBs, and vans, it may find that inclusion of programmatic standards for announcement audibility (which are beyond the Board’s jurisdiction) would be both appropriate and useful.

With respect to the requirement that automated stop announcement systems must have signage viewable onboard from all wheelchair spaces and priority seats, APTA expressed concerns about the cost of providing signs for rear-facing wheelchair positions. For several reasons, we do not believe that, in practice, such signs will pose a significant expense. First, rear-facing wheelchair spaces are not required by the 2016 Non-Rail Vehicle Guidelines. Rather, the default orientation for wheelchair spaces is front facing, with the rear-facing position being an exception permitted only on certain large non-rail vehicles so long as at least one wheelchair securement system is front facing. See T603.2. Second, while rear-facing wheelchair spaces are prevalent throughout Europe and Canada, they are still relatively uncommon in the United States. Only a handful of transit agencies employ rear-facing wheelchair spaces for bus transit, and, when used, it is generally on bus rapid transit systems. Together, these considerations augur against significant costs for provision of stop announcements signs for rear-facing wheelchair spaces. Moreover, we believe it is beneficial for non-rail vehicles with any rear-facing passengers to provide this important communication feature.