AC Transit
Alameda-Contra Costa Transit District, Oakland, California


RE: Draft Guidelines for Accessible Public Rights-of-Way

Dear Mr. Windley:

AC Transit is writing to respond to the Access Board's draft ADAAG guidelines for accessibility in public rights-of-way. AC Transit is the public transit system in the San Francisco East Bay area, operating a fleet of 800 buses and 180 paratransit vehicles. We serve a diverse population that includes many individuals with disabilities. Our service area is home to many disability-oriented advocacy and service organizations, with constituencies at the local, state, national, and international levels. AC Transit's Accessibility Advisory Committee (AAC) has been a pioneering leader in consumer advocacy for local public transportation systems.

1102.7.1 Bus Route Identification: We do not agree that Braille/raised print route identifications should be required at bus shelters. In our area, shelters are provided and controlled by municipalities, not the transit system. In the Bay Area, Braille/raised print identifiers are usually placed on bus stop sign poles, by the transit system. They are not directly associated with shelters, which are sometimes placed for advertising visibility, not for transit ridership reasons.

AC Transit has nearly 7,000 stops. It is common for transit agencies, including AC Transit, to change schedules and routes often. Braille/raised print signs which must be customized for certain bus stops are expensive to make, and even more expensive to keep current. They are much more involved than stop sign decals, which can be changed easily. Local transit systems have limited field staff, and cannot be expected to handle the cost and complexity of maintaining tactile signage, without additional resources.

AC Transit is currently experimenting with bus route numbers in Braille/raised print on selected route information signs. We foresee adopting a tactile signage standard that will provide for route numbers at bus stops where there are multiple bus stop poles. This situation exists at transit centers, rail station transfer locations, and major downtown transfer locations. Some of these have shelters, and some do not.

AC Transit is considering a universal identifier for all other bus stops, most likely saying simply "Bus". This type of sign is in use by many transit systems, and has been found useful to blind passengers, where a variety of poles and posts can make finding the bus stop confusing. The AC Transit AAC agrees with management that full "route identifier" signs should not be required at all stops, or those with shelters, and that the simple "universal identifier" may be a more reasonable ADAAG requirement.

In any case, the proposed ADAAG requirement is unclear. It should state more specifically what information is required, at a minimum. Many transit systems have information about destinations, frequency, time span, and other items on route signs. This amount of information would not fit on the narrow type of Braille/raised print signs AC Transit and other Bay Area transit systems are using, which must fit on a vertical signpost, without creating a hazard for pedestrians. Our plans are to provide only the route number or letter as the “route identifier”.

1103.3 Pedestrian Access Route Clear Width: Sidewalk width is not a factor under the control of most transit systems, including AC Transit. Our staff feels that it is reasonable to require adequate sidewalk space where feasible. We would be wary, however, of any interpretation that would preclude the placement of bus stops at new or re-built locations that did not comply. While we work cooperatively with local municipalities to provide facilities that support transit usage, we ultimately cannot control them. We are also sensitive to the potential problems pointed out in the American Public Transportation Association’s (APTA) letter to you of Oct. 28, 2002. One issue is that such a provision may discourage local jurisdictions from improving their sidewalks.

In reviewing the proposal, our advisory committee, the AAC, felt that the originally-contemplated width of 60” would be more appropriate than the final draft figure of 48”, for reasons of promoting increased accessibility. Our staff pointed out that while this may be a worthy goal, it could create even more problems of the type mentioned in the APTA letter.

1104.3.2 Detectable Warnings: We support the proposed changes to the technical specifications of truncated dome detectable warnings. However, we think it is premature to expand the application of these warning features, due to several outstanding issues associated with their use.

In California, the state building code already provides for a different type of textural feature alerting pedestrians to the presence of curb ramps. There is also a potential for the proposed 24” application to be confused with rail (or Bus Rapid Transit) platform edges. If this requirement is pursued, the original concept of 36” for marking hazardous vehicular ways should be more strongly considered. In general, both our staff and AAC feel that more research and public input should be conducted before changing the existing guidelines.

We appreciate the opportunity to comment on this proposal and look forward to an NPRM that accommodates the comments of all affected parties. If you need any further information, please feel free to contact me at [...].

Sincerely,

Douglas J. Cross
Accessible Services Manager