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WMATA ADA Compliance Review - August 29, 2008

Location: Washington, DC 
Date of Final Review: August 29, 2008

Washington Metropolitan Area Transit Authority Transmittal Letter

August 29, 2008 

Mr. John B. Catoe, Jr.
General Manager
Washington Metropolitan Area Transit Authority
600 Fifth Street, NW
Washington, DC 20001

Re: ADA Compliance Review of WMATA Lift Maintenance and Reliability Final Report

Dear Mr. Catoe:

Thank you for your response to the Federal Transit Administration’s (FTA) letter and preliminary report of findings of the Americans with Disabilities Act of 1990 (ADA) compliance review of the Washington Metropolitan Area Transit Authority’s (WMATA) fixed route services, conducted from August 20 to 23, 2007. Enclosed is the Final Report that incorporates WMATA’s official response by attachment. As of the date of this letter the Final Report became a public document and is subject to dissemination under the Freedom of Information Act of 1974.

Enclosed with this letter is a progress table listing FTA’s understanding of the corrective actions either planned or taken by WMATA in response to the preliminary findings contained in the draft report. If you feel that our summarization of corrective actions is inconsistent with your response, please inform us in writing as soon as possible.

  • Following most of the areas where findings were made, we have:
  • Identified responses that adequately address the finding
  • Requested documentation of results and outcomes
  • Requested WMATA to clarify specific corrective actions based on WMATA’s response to the report findings

Please use the enclosed table as the format to report progress to FTA on the corrective actions that WMATA has completed or intends to implement as a result of our findings. Please identify each response by item number (e.g., 1.1, etc.). The requested documentation, along with updates on the status of implementation of proposed corrective actions, should be provided in quarterly reports to FTA. Each report should include the planned and actual completion date of the corrective action; the current status and contact person information for each corrective action; and specific reporting requests cited in this letter and on the enclosed table. The first report will be due on October 15, 2008, and should include data for the months of April through September 2008 , and any actions completed prior to that date that have not already been addressed. Additional reports will be due by the 15th day after each quarter (January 15, 2009, April 15, 2009, etc.) providing an update on open findings regardless of whether FTA has responded to previous quarterly reports.

We recognize the progress that you have made in responding to the findings of the review as presented in your April 9, 2008, letter. In addition to these efforts, we request that your first progress report more fully respond to the following findings, which are also addressed in the progress table. This is not an exhaustive list of open findings, for that please see the progress table.

Operation of Inoperable Lifts for More than Three Days

3. Finding: WMATA does not appear to have a consistent procedure to identify and hold buses with inoperable lifts or ramps to ensure that they are only used when no other bus is available and are used for no more than three days. Each of WMATA’s bus divisions has its own procedure for identifying vehicles available for use in passenger service each day. At some divisions, the maintenance managers identify vehicles unavailable for use in passenger service for the transportation managers. The lists provided do not appear to identify vehicles with inoperable lifts as unavailable or as having only limited availability as “trippers” in relation to the date the inoperable lift was reported and the subsequent days it had been used in service.

4/9/08 Corrective Action Proposed by WMATA:
Revised SOP 2.18 clearly outlines procedures for using the automated Maximo system to better ensure that buses with non-working lifts/ramps, and time lines are repaired promptly and taken out of service consistent with ADA requirements.

Key Performance Indicators (KPIs) showing all wheelchair lifts and ramps out-of-service will be continuously monitored on the Maximo start-up screens for the BMNT General Superintendent, Assistant General Superintendent, Division Superintendents and the Superintendent - Technical Support Services.

Clarification of Corrective Action: Are the Key Performance Indicators compiled each day for each bus division? Please provide sample reports showing lift and ramp availability and/or performance.

Please also note that the regulations do not distinguish between buses used for full service and those used for limited “tripper” service. Any bus with an inoperable lift or ramp is limited to three days of use before being removed from service (49 CFR 37.163(e)).

Additional reporting: Please provide a copy of the revised SOP 2.18.

3. Pull-out Inspections

2. Finding: It appears that operators do not always cycle lifts as part of the pre-trip inspection. In their visits to six garages, reviewers observed the starter actively intercepting operators and instructing them to cycle their lifts prior to pull-out. It appeared that many operators would not have cycled their lifts prior to pull-out without the proactive intervention of the starter. Nevertheless, 12 of 138 operators (8.7 percent) were observed by the review team to not cycle the lift or ramp during pre-trip inspections.

4/9/08 Corrective Action Proposed by WMATA:
Operators are required to cycle lifts/ramps prior to departure as part of their pre-trip inspection procedure. WMATA will periodically monitor this issue for compliance. A copy of the existing Operations Administrative Procedure (OAP) is attached.

Clarification of Corrective Action: Please note that the existing OAP provided does not include testing of the public address system or the automated annunciators. While not within the scope of this review, previous correspondence between WMATA and this office has highlighted deficiencies in compliance with stop announcement requirements. These checks should be added to the OAP.

Additional reporting: Please provide a revised OAP. Also provide more information about WMATA’s periodic monitoring of pre-trip inspections by the operators. Please provide any documentation of monitoring results.

4. Finding: At some facilities, including the Western facility, there was little room for operators to cycle the bus lift without obstructing traffic. This space limitation appears to restrict operators’ ability to cycle lifts and ramps before leaving the bus yard.

4/9/08 Corrective Action Proposed by WMATA:
WMATA will utilize Yard Management to assist the operators as needed to ensure the cycling of all lifts and ramps prior to departure.

Additional reporting: Please describe in more detail WMATA’s “Yard Management” to help provide operators with sufficient room to cycle lifts.

6. Finding: Review team observations found that wheelchair restraints were dirty in 39 of 72 (46 percent) buses. In four of 23 observations (15 percent), lap and shoulder restraints failed to work properly.

4/9/08 Corrective Action Proposed by WMATA:
All divisions have been notified to fully monitor the cleanliness and operation of securement belts. Our interior cleaning contractor has been tasked with improved cleaning in area of securement belts. All buses are now inspected for clean lifts/ramps and securement equipment anytime bus is in shop for maintenance.

WMATA is working with seat manufacturers to develop an improved restraint system and an improved system to keep belts off of the floor.

Additional reporting: Please provide an update on WMATA’s discussions with manufacturers to develop an improved restraint system and an improved system to keep belts off of the floor.

6. Budget and Resources

2. Finding: Vehicle inspections identified three recurring problems with the WMATA bus fleet: priority seating for people who have disabilities was side facing rather than forward facing, signs designating priority seating and securement areas were often missing, and the vertical clearance from lift platform to top of door was inadequate on a number of vehicles.

4/9/08 Corrective Action Proposed by WMATA:
All securement areas will be inspected for securement decals and where missing, two decals will be placed indicating wheelchair restraint position. One Priority Seating decal will be placed in the first forward facing seat. Decals will be installed within 30 days of approval from the FTA.

Orion has been formally requested to provide their documentation for compliance to the regulations and their proposal to resolve 1992/1997 Orion V 68" door clearance issue. Manufacturer compliance documentation is attached.

Additional reporting: The October 25, 2007, letter from Orion to WMATA states that “the Orion V frame was designed to meet ADA… Actual measurements on particular buses are impacted by manufacturing tolerances, the amount and type of materials used, the position and final adjustment of the lift when it is installed, ongoing maintenance and use, and possible differences in the door system components depending on the technical specification utilized by the transit authority.”

Consequently, while the bus vendor’s design may comply with the ADA specifications, WMATA must be aware of the other factors that could result in actual buses not meeting the requirements.

Please note that the inspections also identified insufficient vertical clearance from the raised lift platform to the top of the door (65" versus 68") on the 1993 Flxible 401026CE.

Please provide a plan for ensuring compliance with the ADA requirements in future WMATA vehicle procurements.

We appreciate the cooperation and assistance that you and your staff have provided us during this review. If you have any questions about this matter, please contact Jonathan Klein, program manager for this review, at (202) 366-0809 or at his e-mail address: jonathan.klein@dot.gov. You can also contact Betty Jackson at betty.jackson@dot.gov an electronic copy of the reporting table. Thank you for your continued cooperation. 


Sincerely,

Cheryl L. Hershey
Director
Office of Civil Rights

Enclosures
cc: Letitia Thompson, FTA Region III Administrator
Brian Glenn, FTA Washington, DC Metropolitan Office
Sandra McCrea, FTA Office of Civil Rights

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