September 23, 2024
To Whom It May Concern,
We at The Partnership for Inclusive Disaster Strategies appreciate the opportunity to submit our comments on the Department of Transportation’s Notice of Proposed Rulemaking (NPRM) regarding the adoption of the Accessibility Guidelines for Pedestrian Facilities in the Public Right-of-Way (PROWAG) as they apply to Docket ID Number DOT-OST-2024-0090. As a national, disability-led organization dedicated to advancing equity for people with disabilities before, during, and after disasters, we see this as a critical moment to strengthen accessibility in our transportation systems, particularly ahead of increasing extreme weather events such as excessive heat.
Disabled people who use public transportation need to be able to navigate and move within transit shelters. We strongly urge the Department to ensure that transit shelters provide unobstructed paths for wheelchair users and people who use other mobility devices. In addition, there must be ample circulation space so that people using mobility aids such as manual and power wheelchairs, scooters, crutches, and canes can board and deboard without hindrance. Boarding areas should be clearly separated from vehicular and bicycle lanes. If this isn’t possible, barriers or signals must be installed to protect passengers from incoming traffic. Another vital concern is ensuring that transit shelters do not impede the deployment of ramps or lifts used by buses or trolleys. Poorly placed or designed shelters could become barriers rather than supports. The solution lies in designs that allow for accessible transitions between the sidewalk and the bus. This also includes attention to the elevation of boarding platforms, reducing inclines that can make boarding dangerous for people using a deployed ramp to board or deboard.
With extreme weather becoming more frequent, transit shelters must take advantage of solar power technology and provide robust protection from heat, rain, wind, and snow. They should be constructed from durable, easy-to-maintain materials that stay safe to the touch during extreme heat or cold. The shelters need to be equipped with lighting for the evening and it should be powered with solar energy. Transit shelters need to incorporate materials that reflect sunlight, reducing heat buildup, while maintaining ventilation to ensure the space remains usable during heat waves. Similarly, shelter from rain, wind, and snow must be provided without compromising accessibility. The transit shelter benches need to be inviting, accessible, and comfortable. We recommend benches that feature an armrest on each side and back support, and are made of materials that do not easily overheat. There must also be spaces reserved for people using mobility devices. Moreover, non-slip flooring, proper drainage, and adequate lighting must all be part of the transit shelter design requirements. Lastly, snow plowing should not accumulate snow/ice in front of transit shelters or the nearest curb cut.
The diverse access needs of people should be taken into consideration when designing transit shelters. Thoughtful design such as minimizing ambient noise and creating intuitive layouts should be strongly considered. Transit shelters should include accessible information systems. Clear, high-contrast signage with large-print and tactile information so that everyone can easily access transit schedules and routes. We also encourage installing auditory systems and hearing loops for bus arrival and other announcements. Emergency communication devices within the shelters such as call buttons or intercom systems should also be included.
Strict adherence to PROWAG guidelines is critical, but we urge the Department to go beyond the minimum standards. Engaging the disability community throughout the design and implementation phases will ensure the final product meets real-world needs. Partnering with local disability-led organizations will provide invaluable insights to support transit infrastructure achieve compliance and inclusiveness.
There must also be a foundation of an inclusive transit experience starting with Disability Awareness and Legal Obligations Training for all transit staff. We cannot expect effective communication and accessible services if the people providing them are not trained in disability awareness and disability rights specific to transportation. Understanding proper interaction, respectful language, accessibility standards, and the diverse needs of passengers with disabilities is key to ensuring safety, dignity, and respect for everyone. Investing in comprehensive Disability Awareness and Legal Obligations Training is an unavoidable step toward creating a transit system that truly serves all.
We hope that these recommendations can guide the Department of Transportation toward creating transit shelters that serve all members of the community equitably. As an organization committed to disability justice and inclusive disaster strategies, we are available to offer further insights and look forward to continued engagement.
Thank you for your consideration.
Sincerely,
The Partnership for Inclusive Disaster Strategies
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Posted: September 24, 2024 by admin
September 23, 2024
To Whom It May Concern,
We at The Partnership for Inclusive Disaster Strategies appreciate the opportunity to submit our comments on the Department of Transportation’s Notice of Proposed Rulemaking (NPRM) regarding the adoption of the Accessibility Guidelines for Pedestrian Facilities in the Public Right-of-Way (PROWAG) as they apply to Docket ID Number DOT-OST-2024-0090. As a national, disability-led organization dedicated to advancing equity for people with disabilities before, during, and after disasters, we see this as a critical moment to strengthen accessibility in our transportation systems, particularly ahead of increasing extreme weather events such as excessive heat.
Disabled people who use public transportation need to be able to navigate and move within transit shelters. We strongly urge the Department to ensure that transit shelters provide unobstructed paths for wheelchair users and people who use other mobility devices. In addition, there must be ample circulation space so that people using mobility aids such as manual and power wheelchairs, scooters, crutches, and canes can board and deboard without hindrance. Boarding areas should be clearly separated from vehicular and bicycle lanes. If this isn’t possible, barriers or signals must be installed to protect passengers from incoming traffic. Another vital concern is ensuring that transit shelters do not impede the deployment of ramps or lifts used by buses or trolleys. Poorly placed or designed shelters could become barriers rather than supports. The solution lies in designs that allow for accessible transitions between the sidewalk and the bus. This also includes attention to the elevation of boarding platforms, reducing inclines that can make boarding dangerous for people using a deployed ramp to board or deboard.
With extreme weather becoming more frequent, transit shelters must take advantage of solar power technology and provide robust protection from heat, rain, wind, and snow. They should be constructed from durable, easy-to-maintain materials that stay safe to the touch during extreme heat or cold. The shelters need to be equipped with lighting for the evening and it should be powered with solar energy. Transit shelters need to incorporate materials that reflect sunlight, reducing heat buildup, while maintaining ventilation to ensure the space remains usable during heat waves. Similarly, shelter from rain, wind, and snow must be provided without compromising accessibility. The transit shelter benches need to be inviting, accessible, and comfortable. We recommend benches that feature an armrest on each side and back support, and are made of materials that do not easily overheat. There must also be spaces reserved for people using mobility devices. Moreover, non-slip flooring, proper drainage, and adequate lighting must all be part of the transit shelter design requirements. Lastly, snow plowing should not accumulate snow/ice in front of transit shelters or the nearest curb cut.
The diverse access needs of people should be taken into consideration when designing transit shelters. Thoughtful design such as minimizing ambient noise and creating intuitive layouts should be strongly considered. Transit shelters should include accessible information systems. Clear, high-contrast signage with large-print and tactile information so that everyone can easily access transit schedules and routes. We also encourage installing auditory systems and hearing loops for bus arrival and other announcements. Emergency communication devices within the shelters such as call buttons or intercom systems should also be included.
Strict adherence to PROWAG guidelines is critical, but we urge the Department to go beyond the minimum standards. Engaging the disability community throughout the design and implementation phases will ensure the final product meets real-world needs. Partnering with local disability-led organizations will provide invaluable insights to support transit infrastructure achieve compliance and inclusiveness.
There must also be a foundation of an inclusive transit experience starting with Disability Awareness and Legal Obligations Training for all transit staff. We cannot expect effective communication and accessible services if the people providing them are not trained in disability awareness and disability rights specific to transportation. Understanding proper interaction, respectful language, accessibility standards, and the diverse needs of passengers with disabilities is key to ensuring safety, dignity, and respect for everyone. Investing in comprehensive Disability Awareness and Legal Obligations Training is an unavoidable step toward creating a transit system that truly serves all.
We hope that these recommendations can guide the Department of Transportation toward creating transit shelters that serve all members of the community equitably. As an organization committed to disability justice and inclusive disaster strategies, we are available to offer further insights and look forward to continued engagement.
Thank you for your consideration.
Sincerely,
The Partnership for Inclusive Disaster Strategies
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