Table of Contents

[1] The authors of the Topic Guide Series on ADA Transportation are Marilyn Golden, Policy Analyst, Disability Rights Education & Defense Fund (DREDF) and Russell Thatcher, Senior Transportation Planner, TranSystems Corporation.

We wish to acknowledge our Advisory Committee and the additional people who reviewed the Topic Guide series. The Advisory Committee includes Linda Deavens, Director, Paratransit, Inc., Sacramento, California; Susan Gallagher, Manager of Accessible Services, San Francisco Bay Area Rapid Transit District, Oakland, California; Bonnie Hitch, Customer Service Manager, DART First State/Delaware Transit Corporation, Dover, Delaware; Kevin Irvine, formerly Senior Advocate, Equip for Equality, Chicago, Illinois; Toby Olson, Executive Secretary, Washington State Governor's Committee on Disability Issues and Employment, Olympia, Washington; and Nancy Pineles, Managing Attorney, Maryland Disability Law Center, Baltimore, Maryland.

The Topic Guide series was also reviewed, in whole or in part, by Doug Douglas, Vice President, Paratransit Services and Tammy Haenftling, Assistant Vice President, Paratransit Management Services, Dallas Area Rapid Transit (DART), Dallas, Texas; Karen Hoesch, Executive Director, Access Transportation System, Pittsburgh, Pennsylvania; Richard Weiner, Principal, Nelson\Nygaard Consulting Associates, San Francisco, California; and Stacy Zwagers, Program Manager, Access to Independence, San Diego, California.

The authors also extend appreciation to DREDF staff Ann McDonald-Cacho, Dave Nold, Julia Epstein, Linda D. Kilb, and Katie Keil.

[2] This report was funded through a cooperative agreement between the Disability Rights Education & Defense Fund (DREDF) and the Federal Transit Administration (FTA), U.S. Department of Transportation. The views and policies expressed herein do not necessarily represent the views or policies of the Federal Transit Administration. The United States government assumes no liability for the contents or use of this report.

[3] A Letter of Finding from the Federal Transit Administration Office of Civil Rights stated in 2003, "Where the failure to call stops is a systemic problem with low rates of calling out stops, and the person with the disability cannot use the system, the transit system must make that rider ADA Complementary Paratransit eligible. This is so until such time as the problem is remedied and the system becomes accessible."

Letter of Finding by Cheryl L. Hershey, then ADA Group Leader, Office of Civil Rights, Federal Transit Administration, October 14, 2003, regarding FTA Complaint No. 99218 against Maryland Transit Administration, p. 3.

[4] Many FTA ADA compliance reviews, including these six, found a variety of difficulties with implementation of the ADA stop announcement requirements on both bus and rail vehicles.

Finding: "Of the 45 bus trips observed all of the scheduled stops were announced on 3 trips (7%), some of the stops were announced on 37 trips (82%) and no stops were announced on 5 trips (11%). Overall bus drivers announced 50 % of the stops from the stop lists."

Recommendation: "It is recommended that the importance of stop announcements for individuals with visual impairments or other disabilities, as well as people without disabilities, as an aid to using the transit system, be clearly emphasized to bus and LRV operators by both trainers and transportation supervisors."

Federal Transit Administration ADA Compliance Review of Sacramento Regional Transit District (RT), Sacramento, California, Assessment of Stop Announcement and Route Identification Efforts, Summary of Observations, conducted June 12 – 15, 2000, Final Report dated May 25, 2001, pp. 13 – 14, available at www.fta.dot.gov/civilrights/ada/civil_rights_3899.html.

Finding: "Of 58 observations of route segments, no stop announcements were made on 11 (19 percent) of the routes."

Federal Transit Administration ADA Compliance Review of Kansas City Transportation Authority (KCATA), Kansas City, Missouri, Summary of Observations, Review of Route Identification and Stop Announcements, conducted January 16 – 19, 2007, Final Report dated July 30, 2007, p. 29, available at www.fta.dot.gov/civilrights/ada/civil_rights_3899.html.

Finding: "For MTA-operated bus service some announcements were made on 7 of the 34 trips observed. The assessment team observed MTA bus operators announcing 13% of the stops included in the MTA stop list. No stops were announced on 2 MTA contracted private contractor commuter bus trips. The team also observed stop announcements of 81%, 75%, and 91% respectively for LRT, rapid rail, and commuter rail services."

Recommendation: "It is recommended that MTA revise its policy regarding stop announcements to include announcement of stops at sufficient intervals along the route to orient passengers, as required by 49 CFR 37.167 (b), and expand its written policies to apply to all fixed route, rail and contracted private carrier bus services, in addition to MTA operated bus service. The revised policy should emphasize that stop announcements are required for compliance with the ADA."

Federal Transit Administration ADA Compliance Review of Maryland Mass Transit Administration (MTA), Baltimore, Maryland, Assessment of Stop Announcement and Route Identification Efforts, Summary of Observations, conducted October 2 – 5, 2000, Final Report dated February 1, 2001, pp. 13 and 15, available at www.fta.dot.gov/civilrights/ada/civil_rights_3899.html.

Finding: "Drivers announced 109 (27 %) of 402 listed bus stops observed by the assessment team."

Finding: "On the 55 bus trips observed, 8 drivers (15%) announced all of the stops from PAT's stop announcement list. Of those drivers who announced all of the stops 4 announced far more stops than those on PAT's stop list. A total of 10 drivers (18%) announced more than 80% of the stops, 25 drivers (45%) announced at least one stop and 30 drivers (55 %) announced no stops at all."

Recommendation: "It is recommended that PAT clarify its procedures to implement the stop calling policy to specifically require calling out all stops on the stop list. Stop lists should be available on a continual basis at each garage where the driver checks out to begin the run in addition to being distributed to drivers upon picking new work schedules."

Recommendation: "It is recommended that PAT implement a central reporting and monitoring system for tracking driver compliance to ADA stop announcement requirements (as opposed to the existing system of separate tracking at each garage)."

Recommendation: "PAT should consider more aggressive remediation of drivers who fail to make stop announcements. Otherwise, failure to make announcements may be considered an acceptable practice by many drivers. Likewise, PAT should continue to commend drivers that make stop announcements in compliance with PAT policy."

Federal Transit Administration ADA Compliance Review of Port Authority of Allegheny County (PAT), Pittsburgh, Pennsylvania, Assessment of Fixed Route Stop Announcement and Route Identification Efforts, Summary of Observations, conducted August 21 – 24, 2000, Final Report dated February 6, 2001, pp. 13 and 15 – 16, available at www.fta.dot.gov/civilrights/ada/civil_rights_3899.html.

Finding: "The assessment team observed that, overall, 61% of stop announcements were being made. Of that total, 29% of bus stop announcements were made; 63% of LRT Green Line and Mattapan Trolley announcements were made; 90% of Rapid Transit Blue, Orange, and Red Line announcements were made; and 77% of commuter rail announcements were being made."

Finding: "According to the MBTA Bus Stop Announcement Program 38% of bus and 75% of Green Line stops are currently announced (April 2000 quarterly report)."

Recommendation: "The MBTA should review and update the stop announcement lists to include all major intersections, transfer points, major destinations, and at sufficient intervals to orient passengers. Attention should be paid to making these announcement lists consistent among routes covering the same area and the lists are free of errors. This review should include input from the Advisory Committee."

Recommendation: "The MBTA should continue its Stop Announcement Monitoring Program and related training."

Federal Transit Administration ADA Compliance Review of Massachusetts Bay Transportation Authority (MBTA), Boston, Massachusetts, Summary of Observations, Assessment of Stop Announcement and Route Identification Efforts & Assessment of Lift Reliability and Maintenance, conducted July 2000, Final Report dated April 20, 2001, pp. I-1-20 and I-1-21, available at www.fta.dot.gov/civilrights/ada/civil_rights_3899.html.

Finding: "Overall, the assessment team found that 74% of the operators observed made at least some stop announcements; 55% of the vehicle operators made ‘all' stop announcements; 9% made ‘most' stop announcements; 10% made ‘some' stop announcements; and 26% made ‘none.'"

Recommendation: "It is recommended that installation of the automated stop announcement systems on fixed route buses be continued."

Recommendation: "For those buses that do not have the automated system, the PAs should be repaired and/or replaced so that drivers can use them to make stop announcements."

Recommendation: "It is recommended that SEPTA's procedures be revised to require bus drivers to announce all stops on the lists being developed for the automated system when operating buses that do not yet have the automated system. This will improve uniformity of stop announcement practices and eliminate the inconsistencies among drivers. SEPTA should consider eliminating its megaphone program, which appears to be confusing to drivers and passengers."

Federal Transit Administration ADA Compliance Review of Southeastern Pennsylvania Transportation Authority (SEPTA), Philadelphia, Pennsylvania, Summary of Observations, Assessment of Stop Announcement and Route Identification Efforts & Assessment of Lift Reliability and Maintenance, conducted August 20 – 24, 2001, Final Report dated April 18, 2002, pp. 26 and 27, available at www.fta.dot.gov/civilrights/ada/civil_rights_3899.html.

[5] This Topic Guide discusses the transportation provisions of the Americans with Disabilities Act Department of Transportation (DOT) regulation at 49 C.F.R. §§ 37.167(b) and (c), and 49 C.F.R. Part 37, App. D, § 37.167, available at www.fta.dot.gov/civilrights/ada/civil_rights_3899.html.

[6] Fixed route transit systems are those that operate along prescribed routes according to fixed schedules, in contrast to demand response transit service, in which a vehicle is dispatched or routed in response to a potential rider's request. For example, the subway train is a fixed route system; taxis are a demand response service.

[7] Several FTA ADA compliance reviews, including these three, addressed stop announcement deficiencies on the train.

Finding: "Out of LIRR's passenger fleet of 1,140 coaches, 73 percent have an automated station information system (ASI) that uses global positioning system technology. Another 12 percent of the coaches have ASI that uses transponders installed in the right-of-way. The remaining 15 percent have PA systems but no ASI."

Finding: On cars equipped with the ASI system, team members observed that station announcements were made by the ASI system 93 percent of the time. For the 14 observations in which cars had an ASI system, but the system was not working, crews made announcements 11 of the 14 times. Combining these two sets of observations yields an audible station announcement performance rate of 98 percent on cars equipped with ASI."

Finding: "On cars without ASI, the review team observed audible announcements 62 percent of the time. This rate of announcements by train crews on cars without ASI is deficient in identifying stations for people who are blind, have low vision, or many other types of disabilities."

Finding: "As noted in Section 3 of this report, conductors are not responsible for testing the PA system at the start of a trip. Rather, car repairmen are responsible for daily inspection of PA systems. As a result, conductors indicated that they do not consistently check the operation of the PA system on each car. Consequently, conductors may not know if the PA is functioning."

Recommendation: "LIRR should increase the frequency of its covert monitoring of on-board station announcements. It should also consider implementing a ‘secret shopper' monitoring program of paid or volunteer riders."

Recommendation: "LIRR should continue to inspect ASI systems daily and identify and repair the ASI systems expeditiously."

Recommendation: "LIRR should increase its efforts to train crews to announce all stations when an operational ASI system is not available. LIRR should increase its efforts to monitor train crew performance in making station announcements and take appropriate remedial or disciplinary action to improve the performance of the train crews."

Recommendation: "LIRR should have train crews test the PA systems before beginning their daily runs rather than rely on car repairmen. Problems should be immediately reported to the Communications Network Operations Center."

Recommendation: "Conductor training should reinforce the importance of making station announcements and provide a specific procedure for making voice announcements when the ASI system is unavailable or inoperable."

Federal Transit Administration ADA Compliance Review of Long Island Rail Road (LIRR), Jamaica, New York, Review of Route Identification and Station Announcements, Summary of Observations, conducted July 16 – 19, 2007, Final Report dated October 17, 2008, pp. 26 and 31 – 32, available at www.fta.dot.gov/civilrights/ada/civil_rights_3899.html.

Finding: "Rapid transit and subway station announcements appear to be made on the Orange, Red, and Blue lines, when the PA systems are operational. However, there was only 1 external announcement observed for the Green Line, which has up to four routes sharing the same track on most of the subway portion of that line."

Recommendation: "The MTBA should re-train personnel with respect to the requirement for route/vehicle identification."

Federal Transit Administration ADA Compliance Review of Massachusetts Bay Transportation Authority (MBTA), Boston, Massachusetts, op. cit., p. I-1-26.

Finding: "Broad Street Subway operators did not differentiate between southbound trains headed toward Pattison versus the Broad Street Spur."

Recommendation: "It is recommended that external announcements be required at all stops on those segments of the Broad Street Subway and Subway-Surface lines where trains serve more than one route."

Federal Transit Administration ADA Compliance Review of Southeastern Pennsylvania Transportation Authority (SEPTA), Philadelphia, Pennsylvania, op. cit., p. 31.

[8] In these three FTA ADA compliance reviews, vehicle operators believed that the ADA stop announcement and/or route identification requirements applied only when they could identify a rider who is blind or has a vision impairment.

Finding: "Most drivers interviewed appeared to be aware of a requirement to call out stops. However, many understood this requirement to apply only when a passenger appears to be blind or disabled. Several drivers did not know that stop cards existed."

Finding: "Drivers interviewed do not appear to understand the requirements for external stop announcements. Many drivers indicated that they only make external route announcements if the passenger ‘looks' blind."

Recommendation: "It is recommended that PAT's training program, including supplemental ADA training, emphasize the need for drivers to identify routes to all waiting passengers at stops shared by more than one route. The training program should identify the reasons for this requirement noting that some individuals with visual impairments or other disabilities, such as developmental disabilities, will not be recognizable to the driver. PAT should also provide training to driver supervisors and QAO monitors."

Federal Transit Administration ADA Compliance Review of Port Authority of Allegheny County (PAT), Pittsburgh, Pennsylvania, op. cit., pp. 13 and 19 – 20.

Finding: "Of twelve operators interviewed many were unaware of any requirement for route identification and the remainder understood the requirement to be limited to making external route announcements only when they identified a passenger who was blind."

Federal Transit Administration ADA Compliance Review of Sacramento Regional Transit District (RT), Sacramento, California, op. cit., p. 18.

Finding: "Many operators appear to be cognizant of the need to identify the route to someone who appears to be blind. This practice can result in operators not identifying routes to many individuals with visual impairments or other disabilities, who do not appear to be blind, such as individuals with cognitive disabilities. In general, operators interviewed appeared to be unaware of the ADA requirements to identify routes."

Recommendation: "It is recommended that MTA's training program instruct LRT operators and bus drivers to identify routes to all waiting passengers at stops shared by more than one route."

Federal Transit Administration ADA Compliance Review of Maryland Mass Transit Administration (MTA), Baltimore, Maryland, op. cit., p. 20.

[9] In many ADA compliance reviews, including these eight, FTA found that transit agencies have not consistently implemented the route identification requirement.

Finding: "KCATA does not require operators to identify their route to customers waiting at stops shared by more than one route. In Subsection D of the Disability Awareness Section of its Metro Operator Training Manual and Resource Guide, KCATA requests operators to announce, outside their bus, their route number at transfer points and bus stops serviced by other routes."

Finding: "Of 12 operators interviewed, none understood the requirement to make route announcements at stops shared by more than one route so that people who are blind, have low vision, or cognitive disabilities which prevent them from identifying the bus can identify the route."

Finding: "The review team observed only one route announcement in 68 observations."

Recommendation: "KCATA must require operators to identify their route to customers waiting at stops shared by more than one route. Procedures should be revised accordingly."

Recommendation: "KCATA should revise its operator training to ensure that operators understand the requirement to make route announcements at any stop shared by more than one route."

Recommendation: "KCATA should implement the automated route announcement component of its automated announcer system as expeditiously as possible."

Federal Transit Administration ADA Compliance Review of Kansas City Transportation Authority (KCATA), Kansas City, Missouri, op. cit., pp. 18 – 19 and 33 – 34.

Finding: "No external stop announcements were made at ten bus stops shared by multiple routes for any of the 78 buses observed. The bus route was not identified to waiting passengers at 121 stops shared by other routes while riding on 17 bus trips."

Finding: "No external announcements and one internal announcement were made at 49-shared stops on 6 observed trips on the LRT System. It appears that MTA's practice is to announce trip destinations to passengers on the vehicle at the last outbound stop shared by the two LRT Routes. This practice requires individuals with a visual impairment or other disability to transfer from one train to another during their trip."

Finding: "Many operators appear to be cognizant of the need to identify the route to someone who appears to be blind. This practice can result in operators not identifying routes to many individuals with visual impairments or other disabilities, who do not appear to be blind, such as individuals with cognitive disabilities. In general, operators interviewed appeared to be unaware of the ADA requirements to identify routes."

Finding: "Route identification by operators does not appear to be monitored by MTA."

Recommendation: "It is recommended that all management and supervisory personnel and operators be briefed and trained in the ADA requirements to identify routes."

Recommendation: "It is recommended that MTA's training program instruct LRT operators and bus drivers to identify routes to all waiting passengers at stops shared by more than one route."

Recommendation: "It is recommended that MTA establish a regular, consistent program to monitor route identification to permit accurate identification of performance and to support remedial action for violations. MTA may want to consider hiring temporary personnel to prevent easy identification of monitors by operators.  It is recommended that monitoring be sufficient to review each operator at least once per year."

Federal Transit Administration ADA Compliance Review of Maryland Mass Transit Administration (MTA), Baltimore, Maryland, op. cit., pp. 20 and 21.

Finding: "Bus operators did not appear to be making external stop announcements at the time of the on-site assessment. Of the 110 situations where an external announcement should have been made, only 9 were observed."

Recommendation: "Training materials and policy manuals should be modified to more clearly describe the requirements for external identification. Specifically, the practice of identifying the route and destination at transfer locations should not be limited to times when someone has a white cane or guide dog. Many disabilities, including visual impairments, are not always apparent."

Recommendation: "The MBTA should re-train personnel with respect to the requirement for route/vehicle identification."

Recommendation: "Monitoring external announcements should be incorporated into the Bus Announcement Monitoring Program."

Federal Transit Administration ADA Compliance Review of Massachusetts Bay Transportation Authority (MBTA), Boston, Massachusetts, op. cit., p. I-1-26.

Finding: "Of twelve operators interviewed many were unaware of any requirement for route identification and the remainder understood the requirement to be limited to making external route announcements only when they identified a passenger who was blind."

Finding: "Riders with visual impairments report a wide variance in the extent to which routes are identified, possibly because of reliance on driver's judgement to recognize people with visual impairments."

Finding: "Operators did not appear to be making external stop announcements at the time of the on-site assessment. In 70 situations where an external announcement should have been made, none were observed."

Recommendation: "It is recommended that RT revise its Operators manual and District Guide to clearly describe its procedures regarding route identification. The policy should clearly identify procedures that provide a means by which an individual with a visual impairment or other disability can identify the proper vehicle to enter, or be identified to the vehicle operator as a person seeking a ride on a particular route, where vehicles for more than one route serve the same stop."

Recommendation: "It is recommended that RT revise its training program for operators to instruct drivers in procedures for route identification."

Recommendation: "It is recommended that RT's monitoring procedures be revised to include observations of external route identification and that a remedial procedure for failure to make external route announcements be established."

Federal Transit Administration ADA Compliance Review of Sacramento Regional Transit District (RT), Sacramento, California, op. cit., pp. 18 – 19.

Finding: "The assessment team found that 23% of the 179 drivers observed at 12 different times made route/vehicle identification announcements. Of those, 57% were automated bus announcements."

Recommendation: "It is recommended that training materials and policy manuals be modified to more clearly describe the requirements for external route identification. Specifically, the practice of identifying the route and destination at transfer locations should not be limited to times when a waiting passenger has a white cane or guide dog. Many persons with disabilities, including those with developmental disabilities and some visual impairments, are not always apparent."

Recommendation: "It is recommended that monitoring external announcements be incorporated into the Quality Control Monitoring Program."

Federal Transit Administration ADA Compliance Review of Southeastern Pennsylvania Transportation Authority (SEPTA), Philadelphia, Pennsylvania, op. cit., p. 31.

Finding: "Operators did not appear to be making external stop announcements at the time of the on-site assessment. In 44 situations where an external announcement should have been made, none were observed."

Recommendation: "An external announcement/bus identification policy should be added to CATA's Work Rules and training materials."

Recommendation: "A renewed effort to inform operators of this policy and then to monitor operator performance should be undertaken by CATA."

Federal Transit Administration ADA Compliance Review of Capital Area Transportation Authority (CATA), Lansing, Michigan, Assessment of Stop Announcement and Route Identification Efforts, Summary of Observations, conducted April 3 – 5, 2000, Final Report dated November 21, 2000, p. 15, available at www.fta.dot.gov/civilrights/ada/civil_rights_3899.html.

Finding: "PAT's procedures, as expressed in the ‘Americans with Disabilities Act, Educational Manual and Reference Guide,' appear to instruct drivers to announce route number and destination only to passengers who have visual impairments or appear to need assistance. In instances where individuals with visual impairments or other disability are not recognized as such by the driver, and the driver fails to identify the route, the individual may be unable to identify the correct vehicle to enter. PAT's procedures could result in failure to identify routes to individuals with visual impairments or other disabilities."

Finding: "Supervisors appear to be unclear as to the requirement to identify routes to customers waiting at bus stops that are served by multiple routes. In at least one garage, drivers are not instructed to make external announcements."

Finding: "Drivers interviewed do not appear to understand the requirements for external stop announcements. Many drivers indicated that they only make external route announcements if the passenger ‘looks' blind."

Recommendation: "It is recommended that PAT consider revising its policy regarding route identification to require drivers to announce route number and destination to waiting passengers at all stops shared by more than one route. Such an approach would assure that all passengers with disabilities are able to identify the proper vehicle to enter."

Recommendation: "It is recommended that PAT's training program, including supplemental ADA training, emphasize the need for drivers to identify routes to all waiting passengers at stops shared by more than one route.  The training program should identify the reasons for this requirement noting that some individuals with visual impairments or other disabilities, such as developmental disabilities, will not be recognizable to the driver. PAT should also provide training to driver supervisors and QAO monitors."

Recommendation: "Upon completion of training/retraining of all drivers in revised route identification requirements it is recommended that monitors carefully record driver performance on QAO reports and that the information be entered into a central monitoring database."

Recommendation: "It is recommended that PAT address failure of drivers to identify routes to waiting passengers at stops shared by multiple routes with retraining and/or progressive driver discipline as appropriate.

Federal Transit Administration ADA Compliance Review of Port Authority of Allegheny County (PAT), Pittsburgh, Pennsylvania, op. cit., pp. 19 and 20.

Finding: "The assessment team found that while some drivers were making route identification announcements during the boarding process, there were no external route identifications made to waiting passengers at stops served by more than one route, as required by the US DOT ADA Regulations."

Recommendation: "It is recommended that Pace require external announcements identifying the route be made by all drivers at all stops served by more than one route."

Recommendation: "It is recommended that Pace retrain personnel with respect to the requirement for route/vehicle identification. The list being developed for use with the new IBS automated announcement system should be used to train drivers."

Federal Transit Administration ADA Compliance Review of Pace Suburban Bus Division of the Regional Transportation Authority (PACE), Arlington Heights, Illinois, Summary of Observations, Assessment of Stop Announcement and Route Identification Efforts & Assessment of Lift Reliability and Maintenance, conducted July 22 – 25, 2002, Final Report dated March 4, 2003, pp. 20 – 21, available at www.fta.dot.gov/civilrights/ada/civil_rights_3899.html.

[10] Some of the issues discussed in this section are summarized from Easter Seals Project ACTION, Resource Guide to Effective Approaches for Increasing Stop Announcements and Route Identification by Transit Operators, Washington D.C., June 2009, p. 9.

[11] In several ADA compliance reviews, including these three, FTA found that transit agency stop announcement policies did not adequately address the requirement for stop announcements to be made at intervals along the route sufficient to permit people with disabilities to be oriented to their location. At times, other required categories of stop announcements were also not implemented properly.

Finding: "The average (mean) interval between announcements exceeded five minutes on 16 (28 percent) of the route segments observed by the review team, and the average interval between announcements was between three and five minutes on 13 (22 percent) of the route segments."

Finding: "For the 44 route segments observed with automated announcements, the average interval between stop announcements exceeded three minutes on 26 (59 percent) of the route segments."

Finding: "The interval between stop announcements exceeded three minutes on all of the routes relying upon operators to make voice announcements. Of the 14 routes with inoperable automated stop announcement systems, operators made voice announcements on only three (21 percent)."

Finding: "The stop lists used by KCATA do not appear to adequately address DOT regulatory requirements to announce stops at transfers to other routes and to announce stops sufficiently to orientate passengers. A comparison of KCATA's automated and operator stop lists to lists developed by review team for eight sample routes indicates that many stops where multiple routes converge, diverge, or cross and stops at turns on routes, are not included on KCATA's lists."

Finding: "In Subsection D of the Disability Awareness Section of its Metro Operator Training Manual and Resource Guide, KCATA requires its operators to announce transfer points and destination points on fixed routes. Operators are required to ‘announce stops upon the request of a person with a disability'.  The ADA requires that stops be announced sufficiently to permit individuals with visual impairments or other disabilities (observable or hidden) to be oriented to their location."

Recommendation: "KCATA should review and revise its automated stop list to include all stops where different bus routes converge, diverge, or cross and stops located after the route turns from one street to another."

Federal Transit Administration ADA Compliance Review of Kansas City Transportation Authority (KCATA), Kansas City, Missouri, op. cit., pp. 18, 29, and 30.

Finding: "Although it is MTA's policy to announce stops at transfer points, major intersections, and destination points, the policy does not include announcement of stops at sufficient intervals along the route to orient passengers as required by 49 CFR 37.167 (b)."

Finding: "The stop announcement lists included in the Stop Announcement Book appear to include most transfer points with other fixed routes and other major intersections and destination points. However, based on a sample of suburban routes, stop lists do not appear to include stops at intervals along the route sufficient to permit individuals with visual impairments or other disabilities to be oriented to their location."

Recommendation: "It is recommended that MTA revise its policy regarding stop announcements to include announcement of stops at sufficient intervals along the route to orient passengers, as required by 49 CFR 37.167 (b), and expand its written policies to apply to all fixed route, rail and contracted private carrier bus services, in addition to MTA operated bus service. The revised policy should emphasize that stop announcements are required for compliance with the ADA."

Federal Transit Administration ADA Compliance Review of Maryland Mass Transit Administration (MTA), Baltimore, Maryland, op. cit., pp. 13, 14, and 15.

Finding: "The stop lists appear to be missing some transfer points; appear to be inconsistent from route to route; and appear to have long distances between some stops. As a result, transit riders with visual impairments or other disabilities may have difficulty in locating transfer points and orienting themselves to their location."

Recommendation: "It is recommended that RT's route announcement stop lists be reviewed and revised to assure that lists include all transfer points with other fixed routes, and intervals along the route sufficient to permit individuals with visual impairments or other disabilities to be oriented to their location, as well as other major intersections and destination points."

Federal Transit Administration ADA Compliance Review of Sacramento Regional Transit District (RT), Sacramento, California, op. cit., pp. 13 – 14.

[12] In this ADA compliance review, FTA found that stops announced by the automated system were not consistent with driver announcements.

Finding: "The list of stops to be announced by the automated system appears to be inconsistent with the list of stops to be announced that is provided to operators. Based on a review of eight routes, 92 stops were common to both lists of stops. There were an additional 75 stops on the operator lists that were not included on the automated list and 26 stops on the automated list that were not on the operator list."

Recommendation: "KCATA should revise the stop lists issued to operators to make them consistent with the automated stop lists."

Federal Transit Administration ADA Compliance Review of Kansas City Transportation Authority (KCATA), Kansas City, Missouri, op. cit., pp. 29 – 30.

[13] Some of the issues discussed in this section are summarized from Easter Seals Project ACTION, Resource Guide to Effective Approaches for Increasing Stop Announcements and Route Identification by Transit Operators, op. cit., pp. 31 – 34.

[14] Easter Seals Project ACTION, Resource Guide to Effective Approaches for Increasing Stop Announcements and Route Identification by Transit Operators, op. cit., pp. 29 – 30.

[15] In some ADA compliance reviews, including these six, FTA addressed stop lists. In the first review, FTA lauded the transit agency stop lists. In the others, FTA found problems related to the preparation and use of stop lists.

Finding: "The ‘Route Announcement' lists prepared by CATA with consumer input appear to include major stops and sufficient stops for riders to remain oriented as to their location."

Federal Transit Administration ADA Compliance Review of Capital Area Transportation Authority (CATA), Lansing, Michigan, op. cit., p. 11.

Finding: "MTA does not require operators to announce all of the stops on its stop list but rather leaves it up to each driver to determine which stops to call to meet MTA's policy. In the absence of a requirement for drivers to announce specific stops it can be very difficult to hold drivers accountable for stop announcement performance."

Recommendation: "It is recommended that MTA revise its procedures to implement the stop calling policy to specifically require calling out all stops on MTA's stop list."

Recommendation: "It is recommended that stop lists be distributed to drivers with each new work schedule and that lists be made available to operators at each bus division."

Federal Transit Administration ADA Compliance Review of Maryland Mass Transit Administration (MTA), Baltimore, Maryland, op. cit., pp. 13 and 15.

Finding: "The stop announcement lists contained in the ADA Announcement Handbooks do not appear to meet the requirements of the ADA regulations. Many appear to be missing stops that should be included. The #700 series fixed routes operated by private carriers do not have stop announcement lists."

Recommendation: "The MBTA should review and update the stop announcement lists to include all major intersections, transfer points, major destinations, and at sufficient intervals to orient passengers. Attention should be paid to making these announcement lists consistent among routes covering the same area and the lists are free of errors. This review should include input from the Advisory Committee."

Federal Transit Administration ADA Compliance Review of Massachusetts Bay Transportation Authority (MBTA), Boston, Massachusetts, op. cit., pp. I-1-20 and I-1-21.

Finding: "Bus drivers do not have a list of stops that are to be announced. Instead, SEPTA's procedure is to call out all stops within Center City and at major intersections, activity centers, and transfer points. The absence of stop lists can result in inconsistency in announcing stops and confusion to customers who are visually impaired. Stop lists are being prepared for each route for the automated stop announcement system. Consumers were involved in the development of the automated system to determine appropriate audio levels for on-board announcements."

Recommendation: "It is recommended that SEPTA's procedures be revised to require bus drivers to announce all stops on the lists being developed for the automated system when operating buses that do not yet have the automated system. This will improve uniformity of stop announcement practices and eliminate the inconsistencies among drivers. SEPTA should consider eliminating its megaphone program, which appears to be confusing to drivers and passengers."

Federal Transit Administration ADA Compliance Review of Southeastern Pennsylvania Transportation Authority (SEPTA), Philadelphia, Pennsylvania, op. cit., pp. 26 – 27.

Finding: "Bus drivers do not have a list of stops that are to be announced. Instead, Pace instructs its drivers to call out stops at major intersections, at transfer points, and at major destinations. The absence of stop lists can result in inconsistency in announcing stops and potential confusion for riders."

Recommendation: "It is recommended that Pace's procedures be revised to require operators to announce all stops on the lists being developed for the IBS automated system when operating buses that do not yet have the automated system. This will improve uniformity of stop announcements, and eliminate inconsistencies among drivers, thereby making it easier for customers to orient themselves."

Federal Transit Administration ADA Compliance Review of Pace Suburban Bus Division of the Regional Transportation Authority (PACE), Arlington Heights, Illinois, op. cit., p. 16.

Finding: "Some drivers indicated that stop lists were not readily available. Supervisors indicated that it is PAT's practice to provide stop lists to drivers at each driver work schedule change but this practice had been temporarily suspended during transition to a new bus stop inventory system."

Recommendation: "It is recommended that PAT clarify its procedures to implement the stop calling policy to specifically require calling out all stops on the stop list. Stop lists should be available on a continual basis at each garage where the driver checks out to begin the run in addition to being distributed to drivers upon picking new work schedules."

Federal Transit Administration ADA Compliance Review of Port Authority of Allegheny County (PAT), Pittsburgh, Pennsylvania, op. cit., p. 13.

[16] Several FTA ADA compliance reviews, including these two, have found problems with transit agencies keeping stop lists current.

Finding: "KCATA issues a list of stops to be announced, with changes as they occur, to operators in a ring-bound handbook. Road Supervisors, who are responsible for field location of bus stops, are responsible for reporting changes to schedulers, who maintain the stop lists. According to KCATA managers, road supervisors do not always report stop changes. This can result in inaccurate stop lists."

Recommendation: "KCATA should require road supervisors and all other employees who change bus stop locations to report such changes in a timely fashion to the scheduling department for inclusion in the HASTUS database."

Federal Transit Administration ADA Compliance Review of Kansas City Transportation Authority (KCATA), Kansas City, Missouri, op. cit., pp. 18 – 19.

Finding: "MTA has stop lists developed by the Training Department. The stop list is in the form of a book, which is updated yearly or less frequently because of printing costs. As a result the stop lists for many routes is out of date. Also, the current book is missing a number of routes. MTA is also developing stop lists to support its automated stop announcement system."

Recommendation: "It is recommended that MTA consider updating stop announcement lists individually for each route as service changes take place. Use of individual sheets for each route rather than use of a book with all routes can make it easier to maintain current stop lists and avoid costly and time consuming printing of a complete book each time a route change is made."

Federal Transit Administration ADA Compliance Review of Maryland Mass Transit Administration (MTA), Baltimore, Maryland, op. cit., pp. 14 and 15.

[17] Many FTA ADA compliance reviews, including these five, found problems with stop announcements being sufficiently audible.

Finding: "Voice announcements made without amplification often were not audible or clear."

Finding: "PA announcements sometimes were difficult to understand or ‘scratchy.'"

Recommendation: "PA systems should be repaired or replaced and kept in good working condition so that drivers may use them and be heard when announcing stops on fixed route buses. Further, PA systems on rapid transit/subway and commuter rail should be upgraded so that drivers are more easily understood and there is less static."

Federal Transit Administration ADA Compliance Review of Massachusetts Bay Transportation Authority (MBTA), Boston, Massachusetts, op. cit., pp. I-1-20 and I-1-21.

Finding: "Stop announcements on buses were significantly more audible when the PA system was used than when unassisted voice was used to make the announcements. The PA system was used on 15 (33%) of the 45 bus trips observed by the assessment team. In the 13 observations when the bus PA system was used, stop announcements were audible 11 (85%) times. Of 25 stop announcements made on buses by unassisted voice 13 were audible 9 were somewhat audible and 3 were inaudible."

Finding: "On 12 LRT trips the PA system was audible 7 times (58%) and somewhat audible 4 times (33%)."

Recommendation: "It is recommended that the importance of using the PA system, when available, to make stop announcements, be emphasized to operators by both trainers and transportation supervisors."

Recommendation: "It is recommended that the performance of the PA equipment for buses be assessed to assure its reliability given the apparent high level of required maintenance."

Recommendation: "It is recommended that the PA equipment used on LRVs be reviewed to improve the audibility of stop announcements."

Federal Transit Administration ADA Compliance Review of Sacramento Regional Transit District (RT), Sacramento, California, op. cit., pp. 13 – 14.

Finding: "Voice announcements made without amplification by drivers were sometimes not audible or clear. On three of the ten routes where voice announcements were observed, the announcements were not clear and audible."

Recommendation: "Options for being able to activate and use a PA system to amplify voice announcements should be explored. This should be explored for existing buses as well as for future purchases. CATA staff noted that 10 newer buses might be able to be easily modified to allow the PA system to be used separate from the DataGuide system."

Federal Transit Administration ADA Compliance Review of Capital Area Transportation Authority (CATA), Lansing, Michigan, op. cit., pp. 11 – 12.

Finding: "Fourteen (56%) of the stop announcements that were made were made by unassisted voice. Ten (40%) were made using the PA system. Ninety-three percent of the voice announcements were audible while 50% of the announcements using the PA were audible."

Federal Transit Administration Compliance Review of Port Authority of Allegheny County (PAT), Pittsburgh, Pennsylvania, op. cit., p. 14.

Finding: "On 3 bus trips (9%) some stops were announced and the announcements were audible. On 4 bus trips (12%) some stops were announced and the announcements were somewhat audible. On 4 (67%) of the observed MARC commuter rail trips, all stops were announced and were audible. Also on 4 (31%) of the Metro rapid rail trips and 4 (27%) of the LRT trips all stops were announced and were audible."

Finding: "For those trips on which at least some announcements were made, announcements were audible on all 6 (100%) of the MARC trips, on 67% of the LRT, 43% of MTA bus trips, and 36% of METRO trips."

Federal Transit Administration ADA Compliance Review of Maryland Mass Transit Administration (MTA), Baltimore, Maryland, op. cit., p. 13.

[18] U.S. Access Board, Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans, § T705, available at www.access-board.gov/vguidedraft2.htm (Notice of Availability at 73 Fed. Reg. 69592 (Nov. 19, 2008)). The U.S. Access Board is currently in an extended process of drafting and receiving public comment on proposed revisions to ADA accessibility guidelines for vehicles used to provide designated and specified public transportation. The first draft of such updated vehicle guidelines was released on April 11, 2007. Following public comment on that first draft, the second draft (cited here) was released on November 19, 2008. A formal Notice of Proposed Rulemaking (NPRM) will then be issued, leading to promulgation of a final rule after comments to the NPRM are analyzed.

[19] Easter Seals Project ACTION, Resource Guide to Effective Approaches for Increasing Stop Announcements and Route Identification by Transit Operators, op. cit., p. 25.

[20]Easter Seals Project ACTION, Resource Guide to Effective Approaches for Increasing Stop Announcements and Route Identification by Transit Operators, op. cit., p. 25.

[21] Several FTA ADA compliance reviews, including this one, found that drivers did not make stop announcements when the automated system was malfunctioning.

Finding: "Drivers were observed to not consistently make voice announcements when the automated system was not functioning. Voice announcements were observed for only 74 of the 436 stops that were not announced automatically."

Recommendation: "CATA should re-emphasize the need for operators to provide manual back up should the automated system fail to completely and accurately announce stops. Specific guidance for operators detailing the circumstances under which voice announcements should be made should be developed. This guidance should be incorporated into the Work Rules and into training materials."

Federal Transit Administration ADA Compliance Review of Capital Area Transportation Authority (CATA), Lansing, Michigan, op. cit., p. 11.

[22] Several FTA ADA compliance reviews, including the four below, found problems with automated stop announcement systems. Also, the National Council on Disability found a number of problems with automated announcement technology, including intentional disabling of the system or turning down of the volume by drivers, and improper triggering of announcements at the wrong time. National Council on Disability, The Current State of Transportation For People With Disabilities in the United States, June 13, 2005, pp. 27 – 28.

Finding: "CDTA managers have noted vandalism on the speaker wires for the internal bus speakers. Based on the location of these wires, they believe that drivers may have cut the wires."

Recommendation: "CDTA should consider more aggressive discipline of its drivers for failing to announce stops or make route identifications."

Federal Transit Administration ADA Compliance Review of Capital District Transportation Authority, Albany, New York, Review of Stop Announcement and Route Identification Efforts, conducted March 27 – 30, 2006, Final Report dated February 7, 2006 [sic], p. 16, available at www.fta.dot.gov/civilrights/ada/civil_rights_3899.html.

Finding: "Stop announcements outside of downtown Kansas City made by the automated system are often made too close or even after the bus stop. In calibrating the time when the automated system makes the stop announcements, KCATA does not appear to fully account for the higher speeds that buses are traveling outside of downtown Kansas City."

Finding: "There appears to be a large number of vehicles with automated stop announcement systems that are either not turned on or are not reported and recorded as needing repair. The automated stop announcement equipment was not working on 14 (24 percent) of the 58 buses observed. Assuming the same failure rate for all KCATA vehicles, approximately 53 of the approximately 220 buses used in daily service will have inoperable automated announcement systems. … An average of 10.6 automated stop announcement systems are repaired per week or 2 or 3 repairs per day. The discrepancy between 53 inoperable systems and two to three daily repairs indicates that many systems are either operational and not turned on properly, or inoperable and not reported and recorded as in need of repair."

Finding: "About half of the operators were not aware that the buses had a public address system that could be used for voice announcements."

Recommendation: "KCATA should review the timing of stop announcements made by the automated system, particularly outside downtown Kansas City, so that they are made sufficiently early for a passenger to signal a stop request and for the operator to make the stop safely."

Recommendation: "KCATA should establish a procedure to monitor operator inspections of automated stop announcement systems. Spot checks of vehicles by road supervisors or inspections by starters or mechanics after pull-in are two possible methods for spot checks. Operators who fail to properly inspect and report problems should be subject to remedial action as a means of improving reporting of automated systems that are not operating properly."

Recommendation: "KCATA should train and re-train its operators in the proper use of the public address system."

Federal Transit Administration ADA Compliance Review of Kansas City Transportation Authority (KCATA), Kansas City, Missouri, op. cit., pp. 30 – 31.

Finding: "Automated announcements, using synthesized, computer-generated speech, were not always clear. On two of the five routes where automated announcements were observed, the announcements could not be clearly understood by the reviewers and on one route the announcements could be understood only some of the time."

Federal Transit Administration ADA Compliance Review of Capital Area Transportation Authority (CATA), Lansing, Michigan, op. cit., p. 11.

Finding: "Only 1 out of 8 observed automated stop announcement equipped buses was working properly. The new automated stop announcement system is currently being phased into operation. Accuracy is expected to improve as system corrections are made. The stop announcements are sometimes made in the wrong location."

Recommendation: "It is recommended that PAT fully test the automated stop announcement system before final acceptance from the equipment supplier to assure that stops are called at the correct location. An alternative procedure to use of the automated system for stop announcements in the CBD should be implemented if the automated system proves unreliable in this area. MTA should be prepared to quickly implement a back-up procedure, such as driver voice announcements, if needed."

Federal Transit Administration ADA Compliance Review of Port Authority of Allegheny County (PAT), Pittsburgh, Pennsylvania, op. cit., pp. 14 and 15.

[23] Easter Seals Project ACTION, Resource Guide to Effective Approaches for Increasing Stop Announcements and Route Identification by Transit Operators, op. cit., p. 37.

[24] Easter Seals Project ACTION, Resource Guide to Effective Approaches for Increasing Stop Announcements and Route Identification by Transit Operators, op. cit., p. 38.

[25] Several FTA ADA compliance reviews, including these two, found problems with maintenance of public address systems.

Finding: "Two of twelve operators interviewed said that they report a malfunctioning public address system when identified; the other ten operators said that they do not."

Recommendation: "KCATA should train and re-train its operators in the proper use of the public address system."

Federal Transit Administration ADA Compliance Review of Kansas City Transportation Authority (KCATA), Kansas City, Missouri, op. cit., p. 30.

Finding: "Based upon driver interviews, it appears that approximately half of the gooseneck PAs on older buses are working."

Finding: "Neither the MTA Vehicle Report nor the checklist for Major Inspections, specifically includes PAs among the vehicle systems to be inspected."

Finding: "It does not appear that defective PAs are recorded into a maintenance tracking system at the time that a defect is first observed and that the time required for repair is recorded."

Recommendation: "It is recommended that PA systems be added to the checklist on both the Vehicle Report and the checklist for Major Inspections; and that operators and maintenance personnel be instructed to test PAs and report defective systems."

Recommendation: "It is recommended that defective PAs be recorded in a maintenance tracking system at the time that a defect is first observed and that the repair be tracked in that system."

Federal Transit Administration ADA Compliance Review of Maryland Mass Transit Administration (MTA), Baltimore, Maryland, op. cit., pp. 14 and 15.

[26] In several FTA ADA compliance reviews, including this one, FTA found that instead of identifying the bus route to all waiting passengers at every stop, drivers stopped only in response to waiting passengers who signaled their interest in boarding.

Finding: "A number of operators were observed stopping only in response to a signal from waiting customers."

Recommendation: "In addition to monitoring driver performance for making route announcements and disciplining operators for failing to make route announcements … KCATA should implement monitoring and discipline to address operator failure to stop where people are waiting at the bus stop."

Federal Transit Administration ADA Compliance Review of Kansas City Transportation Authority (KCATA), Kansas City, Missouri, op. cit., p. 34.

[27] U.S. Access Board, Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans, § T704, available at www.access-board.gov/vguidedraft2.htm (Notice of Availability at 73 Fed. Reg. 69592 (Nov. 19, 2008)), op. cit.

[28] Easter Seals Project ACTION, Resource Guide to Effective Approaches for Increasing Stop Announcements and Route Identification by Transit Operators, op. cit., p. 34.

[29] Easter Seals Project ACTION, Resource Guide to Effective Approaches for Increasing Stop Announcements and Route Identification by Transit Operators, op. cit., p. 19.

[30] Easter Seals Project ACTION, Resource Guide to Effective Approaches for Increasing Stop Announcements and Route Identification by Transit Operators, op. cit., p. 28.

[31] Easter Seals Project ACTION, Resource Guide to Effective Approaches for Increasing Stop Announcements and Route Identification by Transit Operators, op. cit., p. 24.

[32] National Council on Disability, The Current State of Transportation For People With Disabilities in the United States, June 13, 2005, pp. 97 – 99.

[33] This requirement is not in the DOT ADA regulation, but rather in what is called Part 27. Part 27 contains other transit agency obligations including the DOT regulation for Section 504 of the Rehabilitation Act of 1973, another disability rights law. Part 27, which is formally cited as 49 C.F.R. Part 27, is available at www.fta.dot.gov/civilrights/ada/civil_rights_3907.html. The reporting requirement is at 49 C.F.R. § 27.13(b), 49 C.F.R. Subpart C, §§ 27.121 – 27.129.

[34] Federal Transit Administration Office of Civil Rights, Rider Complaint Form, available at www.fta.dot.gov/civilrights/ada/civil_rights_3889.html.

[35] Several FTA ADA compliance reviews, including these three, found a lack of detailed written policies to address each ADA stop announcement and route identification requirement.

Finding: "RT policies and procedures regarding stop announcements as presented in RT's Operator's Manual and District Guide to ADA Regulations contain some inconsistencies and are not fully consistent with the language in the regulations."

Finding: "RT policies and procedures, as described in the Operator's Manual and District Guide, do not appear to be clear and could be construed to limit stop identification by the operator to situations in which a person who appears to be blind is waiting for a vehicle or to instances in which the vehicle is equipped with an external PA system."

Recommendation: "It is recommended that RT review and revise its Operators Manual, District Guide to ADA Regulations and other document that present RT's stop announcement policies and procedures in order to make clear that stops are to be announced in accordance with 49 CFR Section 37.167. The revised language and materials should be consistently presented in driver training."

Recommendation: "It is recommended that RT revise its Operators manual and District Guide to clearly describe its procedures regarding route identification. The policy should clearly identify procedures that provide a means by which an individual with a visual impairment or other disability can identify the proper vehicle to enter, or be identified to the vehicle operator as a person seeking a ride on a particular route, where vehicles for more than one route serve the same stop."

Federal Transit Administration ADA Compliance Review of Sacramento Regional Transit District (RT), Sacramento, California, op. cit., pp. 13 – 14 and 18 – 19.

Finding: "The ADA requirement for route identification does not appear to be included in Pace policy notices and training materials."

Recommendation: "It is recommended that training materials and policy manuals be modified to more clearly describe the requirements for external route identification. Specifically, the practice of identifying the route and destination at transfer locations should not be limited to times when a waiting passenger has a white cane or guide dog. Many persons with disabilities, including those with developmental disabilities and some with visual impairments, are not always recognizable."

Federal Transit Administration ADA Compliance Review of Pace Suburban Bus Division of the Regional Transportation Authority (PACE), Arlington Heights, Illinois, op. cit., pp. 20 – 21.

Finding: "MTA policies do not appear to reflect the ADA requirement to identify transit routes to passengers waiting at stops served by more than one route. MTA Managers appear to be unaware or unclear as to the requirement to identify routes to customers."

Recommendation: "It is recommended that MTA revise or clarify its policy to include identification of routes to waiting passengers at bus and LRT stops shared by more than one route in accordance with 49 CFR 37.167(c). These policy revisions should be included in MTA work rules as appropriate."

Federal Transit Administration ADA Compliance Review of Maryland Mass Transit Administration (MTA), Baltimore, Maryland, op. cit., p. 20.

[36] Many FTA ADA compliance reviews, including these six, addressed transit agency monitoring and discipline in the area of stop announcement and route identification. In the first two compliance reviews, FTA lauded the transit agency stop announcement and/or route identification monitoring and disciplinary efforts, in whole or in part. In the others, FTA identified deficiencies.

Finding: "Contracted ride checkers appear to be effective in identifying drivers who are not making stop announcements. RT used contracted ride checkers to monitor approximately 300 bus trips made by its 350 drivers in 1999. Ride checkers identified 89 drivers who failed to make stop announcements."

Finding: "RT appeared to aggressively discipline drivers who failed to make stop announcements. Through a progressive discipline program, 64 drivers who failed to make stop announcements were reprimanded, 22 were suspended and 3 were terminated."

Recommendation: "It is recommended that RT continue its progressive discipline program coupled with retraining, for failure to make stop announcements."

Recommendation: "It is recommended that the progressive discipline program also be applied for failure to use the PA system on buses."

Recommendation: "It is recommended that RT consider implementing a program to provide positive feedback to bus drivers who properly announce stops."

Federal Transit Administration ADA Compliance Review of Sacramento Regional Transit District (RT), Sacramento, California, op. cit., pp. 14 – 15.

Finding: "Pace has developed an extensive service-monitoring program that, among other things, evaluates whether stop announcements are being made. From July 2000 through June 2001, the monitors cited 371 drivers for failing to make stop announcements or not using the PA."

Finding: "Pace does not monitor drivers for compliance with the ADA route identification requirements."

Recommendation: "It is recommended that Pace continue its monitoring program. Once the stop announcement lists have been put into effect, the monitoring staff should evaluate stop announcement practices based on whether drivers are announcing all stops on the list."

Recommendation: "It is recommended that monitoring external announcements be incorporated into the Service Monitoring Program."

Federal Transit Administration ADA Compliance Review of Pace Suburban Bus Division of the Regional Transportation Authority (PACE), Arlington Heights, Illinois, op. cit., pp. 16, 20, and 21.

Finding: "KCATA does not monitor operator performance in making route announcements at stops shared by more than one route."

Finding: "It appears that KCATA does not include failure to make route announcements at stops shared by more than one route in its operator discipline and remediation program."

Recommendation: "KCATA should include operator performance in making route announcements at stops shared by more than one route in its operator monitoring programs."

Recommendation: "KCATA should include failure to make route announcements at stops shared by more than one route in its operator discipline and remediation program."

Federal Transit Administration ADA Compliance Review of Kansas City Transportation Authority (KCATA), Kansas City, Missouri, op. cit., pp. 18 and 19.

Finding: "Although MTA conducts some operator performance monitoring, the agency does not appear to monitor bus stop announcements sufficiently to measure operator performance."

Finding: "There is no category for stop announcements in MTA's complaint tracking reports."

Finding: "MTA has a five-step progressive discipline program. Records of discipline violations and remedial actions are not tracked in a central system. The absence of a central tracking system makes it difficult to assess MTA's remediation for stop announcement violations."

Recommendation: "It is recommended that MTA establish a regular, consistent program to monitor bus stop announcements to permit accurate identification of performance and support remedial action for violations. MTA may want to consider hiring temporary personnel to prevent easy identification of monitors by operators. It is recommended that monitoring be sufficient to review each operator at least once per year."

Recommendation: "It is recommended that MTA's complaint tracking system explicitly include stop announcements."

Recommendation: "It is recommended that discipline violations and remedial actions be tracked in a central system to track follow-up on stop announcement violations. If operator confidentiality is an issue in designing such a system, operator identification could be suppressed in summary performance reports."

Federal Transit Administration ADA Compliance Review of Maryland Mass Transit Administration (MTA), Baltimore, Maryland, op. cit., pp. 14 – 16.

Finding: "The Quality Control Section of SEPTA does not currently monitor compliance with the ADA route identification requirement."

Recommendation: "It is recommended that monitoring external announcements be incorporated into the Quality Control Monitoring Program."

Federal Transit Administration ADA Compliance Review of Southeastern Pennsylvania Transportation Authority (SEPTA), Philadelphia, Pennsylvania, op. cit., p. 31.

Finding: "It appears that Quality Assurance Monitors may be overstating the number of drivers who are making stop announcements. PAT reported 61% of drivers making all stop announcements verses 15% observed by the assessment team."

Finding: "It appears that some observations of stop announcements by Quality Assurance Monitors may not be entered into the QAO Reporting Systems. The number of entries for no stop announcements is far below what would be expected based upon assessment team observations."

Finding: "While PAT appears to do a good job of commending drivers who make stop announcements, it appears that PAT takes limited remedial action with drivers who fail to make stop announcements. PAT took no action with 64 of 67 drivers who made no stop announcements at West Mifflin Garage in 1999."

Recommendation: "It is recommended that PAT implement a central reporting and monitoring system for tracking driver compliance to ADA stop announcement requirements (as opposed to the existing system of separate tracking at each garage)."

Recommendation: "It is recommended that QAO reports from monitors be entered into a tracking system before distribution to garages for remedial action."

Recommendation: "PAT should consider more aggressive remediation of drivers who fail to make stop announcements. Otherwise, failure to make announcements may be considered an acceptable practice by many drivers. Likewise, PAT should continue to commend drivers that make stop announcements in compliance with PAT policy."

Federal Transit Administration ADA Compliance Review of Port Authority of Allegheny County (PAT), Pittsburgh, Pennsylvania, op. cit., pp. 14 – 16.

[37] Easter Seals Project ACTION, Resource Guide to Effective Approaches for Increasing Stop Announcements and Route Identification by Transit Operators, op. cit., p. 54.

[38] This requirement is not in the DOT ADA regulation, but rather in what is called Part 27. Part 27 contains other transit agency obligations including the DOT regulation for Section 504 of the Rehabilitation Act of 1973, another disability rights law. Part 27, which is formally cited as 49 C.F.R. Part 27, is available at www.fta.dot.gov/civilrights/ada/civil_rights_3907.html. The reporting requirement is at 49 C.F.R. § 27.13(b), 49 C.F.R. Subpart C, §§ 27.121 – 27.129.