SMTD ADA Compliance Review - February 6, 2012
Location: Springfield, IL
Date of Final Review: February 6, 2012
Springfield Mass Transit District (SMTD) Transmittal Letter
Springfield Mass Transit District
928 South Ninth Street
Springfield, IL 62703-2497
Dear Ms. Tisdale:
Thank you for your response to the Federal Transit Administration's (FTA) Americans with Disabilities Act of 1990 (ADA) Review of Stop Announcement and Route Identification Efforts of the Springfield Mass Transit District (SMTD), conducted from July 18-2, 2005. During the review, you were informed that FTA would issue a draft report of the findings, on which SMTD would have an opportunity to provide comment, following which a final report would be released.
FTA recognizes that it has been over six years since our onsite review and that changes have likely occurred in SMTD's transit program. We appreciate the efforts that SMTD has already taken to correct the deficiencies identified, as well as the cooperation and assistance that you and your staff have provided us during this review.
Based upon your December 2, 20 II letter, conveying that SMTD had no corrections to any material statements of fact made about SMTD' s operations in the preliminary report, and providing updates on substantive changes to SMTD's operations and service model, we now consider the report final and have attached a copy so marked for your records. The final report will be posted on PTA's website and is subject to dissemination under the Freedom of Information Act of 1974.
We also recognize the progress that you previously made in responding to the findings of the review as presented in your letter dated February 6, 2007. We request that you update FT A on the corrective action items covered in your 2007 letter, to ensure the information you submitted is still accurate.
Contained within this letter is a summary of the findings of noncompliance made in the report. In order to expeditiously close-out your review and release SMTD from the corrective action phase, please inform FT A within 30 days of the corrective actions SMTD will undertake in response to the findings. When providing proposed corrective actions, include the planned and actual completion date of the corrective action, the current status and contact person for each corrective action, and all supporting documentation.
After providing the requested documentation, along with updates on the status of implementation of proposed corrective actions in response to the report's findings, FTA will be able to close-out all of the findings from your review. Once all open findings have been addressed and closed-out, FTA will release SMTD from this reporting requirement. I commend you for the efforts that SMTD has already made to correct the deficiencies identified in the draft report, and we anticipate your continued endeavors to fully implement your proposed corrective actions. We appreciate the cooperation and assistance that you and your staff provided during this review.
2.1 Findings Regarding Stop Announcements
I. First-hand observations of stop announcements on 37 route segments indicated that drivers made audible stop announcements in accordance with SMTD policy on only 14 of these route segments (38 percent). Some level of stop announcement was made on another 11 route segments (30 percent), but these announcements were not in accordance with established policy or ADA requirements either because they were not audible or because an adequate number of stops was not announced. On 12 of the route segments observed (32 percent), drivers did not make any stop announcements. SMTD must take steps to ensure that drivers are making stop announcements in accordance with 49 C.P.R. Section 37 .167(b)( 1), which requires that drivers announce at least at transfer points with other fixed routes, other major intersections and destination points, and intervals along a route sufficient to permit individuals with visual impairments or other disabilities to be oriented to their location.
2.3 Findings Regarding Driver Assistance and Wheelchair Securement
- Since November 2003, SMTD has had a policy regarding bus operator assistance in accordance with Section 37 .165(f) of the DOT regulations implementing the ADA. However, SMTD drivers and other staff have inconsistent interpretations of the new policy. Even the SMTD trainer did not appear to be clear on what specific guidance is given to bus operators regarding assisting riders with large wheelchairs. Four of the 10 drivers interviewed had inconsistent interpretations of the new policy or indicated they were not clear what was specifically required.
- Bus operator interviews and team member observations also indicated that it is common practice for drivers to secure riders who use wheelchairs with only the passenger seatbelt and shoulder harness. The DOT ADA regulations at 49 C.F.R. § 38.23(d)(7) states that seat belts and shoulder harnesses shall not be used in lieu of a device which secures the wheelchair or mobility aid itself. SMTD has video documentation of several instances where riders-particularly riders using scooters-tipped over during transport. The seatbelt and shoulder harness do not provide adequate securement.
Please provide your response within 30 days of this letter. Should you have any questions about the enclosed report or this letter, please contact Aaron Meyers of my office at (202) 366-3055 or via e-mail at firstname.lastname@example.org. Please provide all correspondence to him via e-mail and regular mail. An electronic copy of this letter and the accompanying report has been sent to SMTD.
ADA Team Lead
FTA Office of Civil Rights
cc: Linda Ford, Acting Director, FTA Office of Civil Rights
Monica McCallum, Regional Operations Division Chief, FT A Office of Civil Rights
Marisol Simon, Regional Administrator, FTA Region V
Donald Allen, Regional Civil Rights Officer, Region V
David Chia, Planners Collaborative