Requirement
“Where vehicles or other conveyances for more than one route serve the same stop, the entity shall 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” (§ 37.167(c)).
Discussion
Since DOT first issued the ADA regulations in 1991, the techniques commonly used to achieve route identification have changed. Appendix D to § 37.167 identifies techniques such as colored mitts or numbered cards that waiting riders would use to inform drivers which route they desired to use. Today, most buses and many rail cars are equipped with external speakers for announcing route information. At bus or rail stations, many transit agencies use the station’s public address system to identify arriving vehicles. Transit agencies using public address systems may also choose to make such announcements verbally or through automated systems.
Note that this requirement obligates transit agencies to identify routes only at stops or stations served by more than one route or line. This requirement also applies to rail stations that serve trains of the same route but that travel in opposite directions. Announcements are not required for a single line stop or station, but many transit agencies—particularly those that have automated announcement systems—identify the routes at all stations or stops, eliminating the need to determine which stops require route identification.
Depending on available technology, the following are four ways in which transit agencies typically make the required route identification announcements:
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Bus drivers or rail vehicle personnel verbally announce the route by opening the door and speaking to waiting riders at the stop or station
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Bus drivers or rail vehicle personnel verbally announce the route by using external public address systems if vehicles are so equipped34
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Transit agencies equip their bus and rail vehicles with and use automated route identification systems
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Transit agencies announce the route from boarding areas rather than from arriving vehicles using automated systems or verbally (using public address systems or not)
To meet the requirement for route identification, FTA encourages transit agencies to ensure operators are instructed to announce routes even if waiting riders do not readily appear to have a visual impairment (e.g., someone not using a cane or without a service animal), as not all disabilities are apparent. FTA also encourages agencies to adopt policies requiring that operators always stop at bus stops with waiting passengers and not only when an individual at the stop waves or otherwise signals the operator to stop. Absent such a practice, individuals unable to see and signal the operator to pull over would be denied service. At busy transit hubs serving multiple bus routes, FTA similarly recommends that agencies adopt policies requiring operators always to pull up to their designated route stop and perform the route identification, even if it means waiting for a bus in front to depart the stop.
When practical, FTA encourages transit agencies using vehicles with external speakers to test speaker volume and fidelity in settings where announcements typically take place (e.g., transfer centers, commercial districts, and residential areas). Calibrating external speakers to field conditions helps to ensure that riders will be able to clearly hear announcements. Another option is to try to simulate the settings to determine whether riders will be able to hear announcements.
Automated Route Identification Systems
Automated systems for route identification are typically paired with automated stop announcement systems. When correctly programmed, these systems provide clear, consistent, and timely announcements. Such systems can be programmed for use on multiple routes and route variations.
As with any technology, automated announcement systems may fail or be improperly programmed either through the software or by personnel entering the incorrect information. Fulfilling the route identification requirements in such instances means drivers or rail personnel must verbally announce and identify routes.
FTA encourages transit agencies to include a test of the announcement system during the operators’ pre-trip inspections. If the announcement system or the external public address system is not working properly and cannot be repaired before pullout, the operator of that vehicle would then be required to announce routes unaided by a public address system.
Announcements at Stations and Platforms
As noted above, external speakers are not required on rail cars where station announcement systems provide information on arriving trains. If a transit agency chooses to make route identification announcements that originate from a facility rather than from a vehicle, it is important that riders can hear these announcements at all stops and platforms, as well as from any waiting areas.
In addition, it should be noted that under Section 810.7 of the DOT Standards, where public address systems convey audible information to the public, the same or equivalent information must be provided in a visual format. Often this is accomplished by signs on the station platforms indicating which track is for trains heading “uptown” and which is for “downtown,” for example, and by signs on the trains indicating whether it is a “red line” train or a “green line” train.
To ensure compliance with the route identification requirements, transit agencies must sufficiently monitor their operators’ performance and the effectiveness of the announcement equipment. To perform such activities, agencies typically employ the following people to conduct field observations:
Road supervisors or managers
Agency employees commuting by fixed route
Volunteer riders who record and submit their riding experiences (“secret” or “ghost” riders)
Contracted secret riders
Road supervisors or managers who perform in-service observations will be more effective if they are inconspicuous by not wearing uniforms or other identifying items. Transit agencies with multiple garages often assign road supervisors to observe employees from other garages or from other agencies.
Route Identification Data Collection
Attachment 6-2 presents a sample data collection form for recording route identification performance. For efficient data collection, observers may stand at stops or stations served by multiple routes or lines, such as major transfer centers or downtown locations. As each bus or train arrives, regardless of the specific data collection form used, FTA recommends obtaining the following key information for each observation:
Vehicle number
Route number or line name
Time of arrival
Whether an announcement of the route or line took place
Whether the driver, another transit employee, or an automated system made the announcement
Information included in the announcement
The number of routes and lines that serve each stop or station observation site and the operating schedule will determine how much data each observer can record.
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