NYCTRC Bridging the Gap: It May Be Further than You Think! Ellyn Shannon and Bradley Brashears New York City Transit Riders Council 347 Madison Avenue NYCTRC Table of Contents INTRODUCTION ......................................................................................................................... 1 METHODOLOGY ........................................................................................................................ 1 FINDINGS ................................................................................................................................... 3 A Division ............................................................................................................................... 4 B Division ............................................................................................................................... 6 RECOMMENDATIONS ............................................................................................................... 8 A and B Division Platform by Line Detail Guide ...................................................................... 12 A Division Platform Detail ................................................................................................... 16 B Division Platforms Detail .................................................................................................. 32 Appendix Appendix A: Raised Platforms and Boarding Area Description .............................................. 72 Appendix B: Description of Vertical and Horizontal Gaps, Code of Federal Regulations, and Section 504(a) of the Rehabilitation Act of 1973 ................................................................... 74 Appendix C: Subway Stations Surveyed ................................................................................. 77 Appendix D: Survey Forms ...................................................................................................... 80 Appendix E: On-The-Go Travel Stations, Help Points, and Wheelchair User Travel Training 82 INTRODUCTION In 2008, the Permanent Citizens Advisory Committee to the MTA, (PCAC) released Welcome Aboard: Accessibility at the MTA. This report identifies accessibility issues of the Long Island Rail Road (LIRR), Metro-North Railroad (MNR) and New York City Transit (NYCT) that were identified in accordance with the Americans with Disabilities Act (ADA). This report also identified several platform-related concerns, which led the New York City Transit Riders Council (NYCTRC) to further investigate the compliance of NYC Transit’s accessible station platforms with federal regulations pursuant to the ADA. The goal of the analysis presented below is to determine in practice how accessible New York City Transit’s accessible subway stations are for wheelchair users. In this report we assess four issues that undermine the efforts of wheelchair users to successfully use New York City’s subways: Train to platform vertical gaps in boarding areas that exceed federal standards. The alignment of raised platforms along subway lines. The inability of wheelchair users to board and exit from the same door of a subway car because of physical obstacles on the platform such as columns or stairways. The lack of clearly defined wheelchair boarding areas. The Council hopes that by highlighting these issues and recommending solutions, it will improve the accessibility of the subway system and instill confidence in wheelchair users that the subway system is a safe and efficient way to travel. METHODOLOGY Field surveys were conducted in 91 stations that NYC Transit identifies as accessible1 between August 2012 and March 2013. For each platform, surveyors collected information including station name, direction of travel, lines operating on the track, and detailed documentation of platform boarding areas and boarding area characteristics. Raised areas on the platforms were also identified, and surveyors determined where they began and ended in relation to specific train cars and doors.2 Incline of raised platform at Kew Gardens-Union Turnpike station Incline of 1 Due to damage by Super storm Sandy, South Ferry, Far Rockaway-Mott Avenue and Rockaway Park Beach- 116th Street stations were excluded from the survey. See Appendix C for complete list of stations surveyed. 2 See Appendix A for full description of raised platforms and MTA website information on how to use recommended boarding areas. 1 The vertical gaps between the platform and subway door thresholds were measured using a ruler with a 3” bar marked on it. A 3” maximum threshold was chosen to account for variations in train loads, so that any vertical gap measured at or above 3” would be identified as a significant problem. ADA regulations (49 CFR 38.53) require: “Retrofitted vehicles shall be coordinated with the platform in new and key stations such that the horizontal gap shall be no greater 6” than 4 inches and the height of the vehicle floor, under 50% passenger load, shall be within plus or minus 2 inches of the platform 3” height.3” Large vertical gap at 50th Street, southbound C Line Additional information collected included whether or not the train conductor’s window was within the raised platform area, the best cars and doors for boarding with notations of blocked doorways, and the nature and location of signage indicating wheelchair boarding areas. This information was recorded on a survey form, a copy of which can be found in Appendix D. The surveyor collected observations from one train per line on each track. In order to develop a clear understanding of the history and issues concerning wheelchair accessibility at designated stations, interviews were conducted with NYCTRC member Edith Prentiss (a wheelchair user), NYC wheelchair users, members of the NYCT’s Office of ADA Compliance, and with the ADA Team leader at the FTA Office of Civil Rights in Washington D.C. Staircase blocking accessible nd door at 72 St., southbound 1 In addition, research was conducted to gather background informationtrain pertaining to the accessibility of the NYC Transit subway system, MTA website information, and federal regulations. 3 See Appendix B for full description of federal regulations pertaining to vertical gap requirements 2 FINDINGS “Wait for the train near the center of the platform, where the car with the conductor normally stops. The conductor will be able to see you more easily and keep the doors open while you board. There are boarding area signs at all accessible stations. This boarding area is specifically modified to accommodate the transfer of wheelchairs between train and platform.” Instructions for Wheelchair Users on the MTA Website While NYC Transit has made progress enhancing the accessibility of its stations, the NYCTRC’s findings indicate there is more that needs to be done. The NYCTRC found 20 excessive vertical gaps in the ADA boarding areas of stations. Due to variations in train car sizes and door location, the Council recognizes that not all gaps may have been identified in the survey. These excessive gaps of three inches or more have led wheelchair users to find that the wheelchair boarding areas are not consistently reliable enough to use as a primary boarding choice. Many wheelchair users have instead chosen to use the raised platforms in stations that best align with the threshold of the train. While this is a reliable boarding strategy, it can present exit problems due to raised platforms not aligning on a given line. For this reason, we have assembled visual diagrams in this report to assist wheelchair users in seeing where these raised platforms align, and where they do not. Our observations highlight inconsistencies in platform-to-train vertical gaps and poor alignment of raised platforms along specific lines. These problems can result in a wheelchair user not being able to board the subway, or after having boarded the subway, not being able to exit, due to a large vertical gap at or an obstacle where the doors open. The surveyors also found that the perimeters of the boarding areas were not clearly marked, which makes them extremely difficult to identify. An added complexity in dealing with these issues is that some platforms serve two to three lines, frequently utilizing different car types with different door spacing. While most boarding areas are located near the conductor’s window, some places such as the inbound M,R platform at the Jackson Heights - Roosevelt Avenue station may have distances as much as a train car away from the conductor. Overview of Findings Twenty platforms with 3” or greater vertical gaps, impact 13 lines. o A Division stations have 2 platforms with 3” or greater vertical gaps, that impact 4 lines. o B Division stations have 18 platforms with 3” or greater vertical gaps that impact 9 lines. Seven doors in accessible waiting areas blocked by columns or stairwells. 3 o A Division stations have 6 doors blocked by columns or stairwells. o B Division stations have 1 door blocked by columns or stairwells. No vertical gap issues in either A or B Division accessible stations when raised platforms were located in the boarding areas. No boarding area had clearly marked boundaries with the exception of the 14th Street-8th Avenue (A, C , E) station. Raised platforms on the C, D, E, F, M, N, Q and R lines are not always aligned to ensure wheelchair users the ability to enter and exit a train. A Division Vertical Gap Issues # of Accessible Platforms and # with 3" or Greater Vertical Gaps in Boarding Areas 32 28 18 18 16