New Jersey Transit Review of Lift Reliability and Maintenance for Operation of Fixed Route Bus Service September 2009
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New Jersey Transit Newark, NJ Review of Lift Reliability and Maintenance for Operation of Fixed Route Bus Service September 14–18, 2009 Summary of Observations Prepared for Federal Transit Administration Office of Civil Rights Washington, DC Prepared by Planners Collaborative March 7, 2014 New Jersey Transit: ADA Lift Reliability and Maintenance Review Draft Report TABLE OF CONTENTS 1 Purpose of the Review .............................................................................................................1 2 Background ..............................................................................................................................3 3 Overview of the Review ...........................................................................................................6 3.1 Customer Comments ........................................................................................................... 9 3.2 NJ Transit Policies and Procedures ................................................................................... 12 3.3 Service Monitoring and Enforcement Procedures ............................................................ 15 3.4 Review Team Observations .............................................................................................. 27 4 Findings and Recommendations...........................................................................................36 4.1 Findings............................................................................................................................. 36 4.2 Recommendations............................................................................................................. 39 ATTACHMENTS A. FTA Notification Letter B. On-Site Review Schedule C. NJ Transit Response Letter D. NJ Transit Policies and Procedures E. Investigator Service Quality Performance Report F. Bus Condition Report G. Excerpts from Accessibility Audit within Maintenance SOP H. NJ Transit Bus Fleet I. Driver Interview Form J. Record of Lift Cycling/Working Condition of Lifts and Access Features K. Bus and Van Specification Checklist New Jersey Transit: ADA Lift Reliability and Maintenance Review Draft Report 1 Purpose of the Review U.S. Department of Transportation (DOT) regulations implementing the Americans with Disabilities Act of 1990 (ADA) contain two primary provisions to ensure that transit authorities reliably and properly maintain vehicles with accessibility features in Section 31.167. General equipment maintenance requirements, which pertain to all types of entities and services, include the following: (a) Public and private entities providing transportation services shall maintain in operative condition those features of facilities and vehicles that are required to make the vehicles and facilities readily accessible to and usable by individuals with disabilities. These features include, but are not limited to, lifts and other means of access to vehicles, securement devices, elevators, signage and systems to facilitate communications with persons with impaired vision or hearing. (b) Accessibility features shall be repaired promptly if they are damaged or out of order. When an accessibility feature is out of order, the entity shall take reasonable steps to accommodate individuals with disabilities who would otherwise use the feature. (c) This section does not prohibit isolated or temporary interruptions in service or access due to maintenance or repairs. In addition to the general equipment maintenance provisions described above that apply to all transportation providers, Section 37.163 of the DOT ADA regulations requires public entities to keep vehicle lifts in operative condition as follows: (a) This section applies only to public entities with respect to lifts in non-rail vehicles. (b) The entity shall establish a system of regular and frequent maintenance checks of lifts sufficient to determine if they are operative. (c) The entity shall ensure that vehicle operators report to the entity, by the most immediate means available, any failure of a lift to operate in service. (d) Except as provided in paragraph (e) of this section, when a lift is discovered to be inoperative, the entity shall take the vehicle out of service before the beginning of the vehicle’s next service day and ensure that the lift is repaired before the vehicle returns to service. (e) If there is no spare vehicle available to take the place of a vehicle with an inoperable lift, such that taking the vehicle out of service will reduce the transportation service the entity is able to provide, the public entity may keep the vehicle in service with an inoperable lift for no more than five days (if the entity serves an area of 50,000 or less population) or three days (if the entity serves an area of over 50,000 population) from the day on which the lift is discovered to be inoperative. (f) In any case in which a vehicle is operating on a fixed route with an inoperative lift, and the headway to the next accessible vehicle on the route exceeds 30 minutes, the entity shall promptly provide alternative transportation to individuals with disabilities who are unable to use the vehicle because its lift does not work. Page 1 New Jersey Transit: ADA Lift Reliability and Maintenance Review Draft Report DOT ADA regulations also contain several requirements related to the operation of accessibility features. Part 38 of the regulations requires accessible vehicles to have mobility aid securement systems and passenger restraint systems and includes technical and functional specifications for these securement and restraint systems. The regulations require that transit systems use the securement system available on vehicles. Section 37.165 requires that agency personnel assist individuals with disabilities with the use of lifts, ramps, and securement systems (and that they leave their seat if necessary to provide this assistance). Section 37.173 then requires transit agencies to ensure that “personnel are trained to proficiency, as appropriate to their duties, so that they operate vehicles and equipment safely and properly assist and treat individuals with disabilities who use the service in a respectful and courteous way, with appropriate attention to the differences among individuals with disabilities.” The Federal Transit Administration (FTA) ensures compliance with the ADA and the DOT implementing regulations. As part of its oversight efforts, FTA, through its Office of Civil Rights, conducts periodic reviews of fixed route transit services operated by grantees. This report includes the results of the review of lift reliability, maintenance, and operation at the New Jersey Transit Corporation (NJ Transit), operating throughout the state of New Jersey. The review team conducted the review from September 14–8, 2009. This report summarizes the observations and findings of the on-site review of NJ Transit’s fixed route bus service by providing a description of key features of the fixed route bus service, followed by a description of the approach and methodology used to carry out the review, and finally describing observations and findings related to the ADA requirements. The last section summarizes the major findings of the review and provides recommendations for addressing identified issues. Page 2 New Jersey Transit: ADA Lift Reliability and Maintenance Review Draft Report 2 Background The Public Transportation Act of 1979 created the New Jersey Transit Corporation (NJ Transit) to “acquire, operate and contract for transportation service in the public interest.” In 1980, NJ Transit purchased Transport of New Jersey, the state’s largest private bus company at that time. Between 1981 and 1985, NJ Transit incorporated the services of several other bus companies. On January 1, 1983, a second subsidiary (NJ Transit Rail Operations, Inc.) assumed control of commuter rail. In 1984, a third subsidiary (NJ Transit Mercer, Inc.) assumed control of bus service in the Trenton/Mercer County area. In 1992, NJ Transit unified all three subsidiaries. Appointed by the Governor, the NJ Transit Board of Directors has seven members—four members of the general public and three state officials—who select an Executive Director to administer the entire agency and to serve as President of the three subsidiaries. In addition, NJ Transit employs a Chief Operating Officer to coordinate operations. NJ Transit’s board meets monthly at NJ Transit headquarters in Newark. Additional input is provided by two transit advisory committees, the North Jersey Transit Advisory Committee (14 members, 4-year terms) and the South Jersey Transit Advisory Committee (14 members, 3-year terms). Covering a service area of 5,325 square miles, NJ Transit is the nation’s third largest provider of bus, rail, and light rail transit, linking major points in New Jersey, New York City, and Philadelphia. The agency operates a fleet of more than 2,000 buses, 700 trains, and 45 light rail vehicles. NJ Transit also administers several publicly-funded transit programs for people with disabilities, older adults, and people living in the state’s rural areas who have no other means of transportation. In addition, the agency provides support and equipment to private contractors. According to its FY 2009 Annual Report, NJ Transit provided 270.3 million passenger trips that year on all modes. NJ Transit buses operate throughout the state as well as in Philadelphia and New York City. It has 15 bus garages, a central bus maintenance facility, and more than 24 passenger terminals