DRAFT
REQUEST FOR EQUIVALENT FACILITATION
Modification of Detectable Warning Tactile Strip to Accommodate
Bridge Plate for New Low Floor Modern Streetcar Vehicles
Draft 12/21/2011
I. Introduction
In conjunction with its Tucson Modern Streetcar project (TMS), The Tucson Department of
Transportation (TDOT) submits this request for a determination of equivalent facilitation
pursuant to 49 CFR 37.7(b). This determination would allow TDOT to utilize an modified method
of compliance related to detectable warning area interface with modern streetcar vehicle bridge
plates at stop platforms as outlined in Department of Justice 2010 Standards for Accessible
Design (2010 Standards), Sections 705.2 & 810.5 and 49 CFR 38.83. Specifically, Sections
705.2 and 810.5, require that an accessible rail station have detectable warning surfaces at
platform boarding edges shall be 24 inches wide and shall extend the full length of the public
use areas of the platform. The detectable warning shall consist of a surface of truncated domes
as required by section 705 of 2010 Standards. The purpose of the detectable warning is to
inform blind or visually impaired passengers that they are nearing the platform edge. The
warning must be of a contrasting color (i.e., dark vs. light) and texture (i.e., truncated domes vs.
smooth surface), as well as (in the case of interior surfaces) differing from the platform in
resiliency and sound-on-cane contact.
In order to achieve Americans with Disabilities Act (ADA) compliance and safe use of the bridge
plate, TDOT is submitting this "Request for Equivalent Facilitation" to the Federal Transit
Administration proposing a minor modification to the required detectable warning strip on stop
platforms. The modification is the inclusion of approximately a 15.5-inch "clear zone," to the
standard 24-inch wide detectable warning strip. The clear zone is a flat area without truncated
domes to receive the bridge plate. Without the clear zone, the interface between the bridge
plate and the detectable warning tactile strip would violate a vertical elevation change limitation
of 49 CFR 38.83. The proposed modification will still allow the tactile warning strip to serve the
purpose it was originally intended for; warning visually impaired persons of the hazards in the
circulation path. In this case, the hazard being identified is the edge of the platform and drop-off
to the street level trackbed.
II. Entity Information
Requesting Agency: Tucson Department of Transportation (TDOT)
Address:
201 North Stone Avenue, Sixth Floor, Tucson, AZ 85701
Contact Person:
Ms. Shellie Ginn, Tucson Modern Streetcar Program Manager
Telephone:
(520) 837-6698
III. Specific Provision of Part 38 Concerning which TDOT is Seeking a
Determination of Equivalent Facilitation
Two separate ADA design standards apply to the TMS project which is vehicle bridge plate
design standards and detectable warning strips at transit stop platforms.
Streetcar Vehicle Bridge Plate Requirements
49 CFR 38.83 requires all new light rail vehicles, other than level entry vehicles, to
provide a level-change mechanism or boarding device (e.g., lift, ramp or bridge plate).
1
DRAFT
49 CFR 38.83(c)(3) specifies that the "transition from roadway or station platform and
the transition from vehicle floor to the ramp or bridge plate may be vertical without edge
treatment up to ¼ inch. Changes in level between ¼ inch and ½ inch shall be beveled
with a slope no greater than 1:2. Further, 49 CFR 38.83(c) (5) specifies acceptable slope
for bridge plates. The purpose of the bridge plate design standard is to allow a
passenger using a mobility aid to easily transition from bridge plate to station platform.
Detectable Warning Strip Requirements
The Department of Justice 2010 Standards for Accessible Design (2010 Standards)
require a 24-inch strip of detectible warnings (truncated domes) along the edge of a
transit boarding platform (2010 Standards, §§ 705.2, 810.5). As currently designed the
detectable warning area is flush with the edge of 9 ½ inch high stop platform. (see
Appendix A "Stop Design Plans"). Additionally, the plans provide for a different colored
detectable warning area that is 8’ wide to accommodate modern streetcar vehicle
bridgeplate deployment. The purpose of the warning strip is to provide a warning to the
visually impaired and other transit passengers, of hazards in the circulation path. In the
case of transit platforms, the detectable warning strip alerts individuals to the platform
edge and drop-off to the in street trackbed.
Equivalent facilitation approval is necessary because TMS is unable to comply with both of the
above design standards at the same time. TMS proposes a slight modification to the detectible
warning strip design to accommodate a bridge plate that meets the requirements of 49 CFR 38.83
IV. Alternate Method of Compliance
During the design process there was an evaluation/coordination of similar systems to determine
the safest and most accessible means of boarding the vehicle. Upon consultation with several
transit agencies the TMS project has decided to pursue a modification to the detectable warning
tactile strip as an equivalent replacement to the standard 24 inch wide tactile strip. This
modification has been successfully utilized by other agencies and is proposed by the TMS to
resolve the incompatibility between the 2010 Standards for the detectable warning and the 49
CFR 38.83 bridge plate design standard.
A. Background Information
Tucson Modern Streetcar Project
The Tucson Modern Streetcar Project will provide a 3.9-mile new streetcar system and add 18
new streetcar stops pairs. The project includes the purchase of seven (7) new streetcar
vehicles. The Project Construction Grant Agreement for the TMS Project was executed by the
Federal Transportation Administration (FTA) and TDOT December 2010. The project is
currently under construction and revenue service is scheduled to begin in fall 2013.
The new vehicles, which are being manufactured in Clackamas, Oregon by Oregon Iron Works,
will have the same general design as The City of Portland’s existing Streetcar’s fleet. The
design of the bridge plates for the new Tucson vehicles is nearly identical to the existing
streetcar in operation. See Exhibit 1 for the interface of the existing bridge plates and the tactile
warning area for the existing Portland Streetcar System.
2
DRAFT
Exhibit 1. Existing Portland Streetcar bridge plate and tactile warning area interface
B. Prior Determination of Equivalent Facilitation for other Systems
TDOT has discussed the operational experience regarding bridge plate and tactile warning
interface with both San Diego’s Metropolitan Transit System (MTS) and Portland’s TriMet
System. Both agencies have received similar equivalent facilitation rulings related to their
existing light rail lines.
MTS
In 2006, the FTA granted MTS's request for Equivalent Facilitation to install the modified
tactile warning strips on the Mission Valley East line. On November 21,2011, the FTA
granted MTS's request to extend this Equivalent Facilitation to MTS's entire light rail
system. This modification was necessary to meet the dual mandates of providing a
tactile warning strip for the visually impaired, while at the same time providing a smooth
surface for our wheelchair ramp bridgeplates to rest on our platforms.
The modified tactile warning strips have been in place for MTS’s Mission Valley East
light rail line since it opened in 2005. Based on a review their files, MTS has not received
any formal customer complaints, claims, legal actions or lawsuits directly related to this
design. There is no evidence that use of this design has resulted in accidents or injuries
to MTS users.
3
DRAFT
TriMet
In 1995, the FTA granted TriMet's request for Equivalent Facilitation to install the
modified detectable warning platform edge on the Westside Light Rail Project. TriMet
was the first transit jurisdiction to utilize low floor light rail vehicles (LFLRV) equipped
with bridge plates to provide near level boarding. TriMet moved to LFLRVs with bridge
plates to provide improved accessibility versus other methods such as lifts and mini-high
platforms.
Included in TriMet’s request for Equivalent Facilitation was testing
documenting whether there was a loss of detectability between the proposed
modifications to the detectable warning area at station platforms and the required 24”
detectable warning area. These tests concluded that there was no loss of detectability
with their modified design. The detectable warning platform edge have been in use on
TriMet’s Light Rail platforms since 1995 and have been operating successfully.
C. Design Detail
The TMS new streetcar vehicles will be fully compliant with 49 CFR subpart D, with the
proposed exception that bridge plates will not have side barriers as required by required by 49
CFR 38.83(c)(4).
Vehicle floor height will be 12 to 14 inch above top of rail, depending on passenger load and
wheel wear. The vertical gap between the station platform and the streetcar floor will be 2 1/2 to
4 1/2 inches. Bridge plate slope will be 1:6 or less, at 50% passenger load, in compliance with
49 CFR 38.83(c)(5). The end of the bridge plate will be a maximum of 1/2 inch vertical and
beveled at 1:2 gradient. However, the TMS bridge plate design standard results in the bridge
plate deploying onto the area designated for the tactile warning required by the 2010 ADA
Standards.
If the bridge plates were to land on top of the detectable warning domes, the transition from
platform to bridge plate would exceed the maximum transition allowed under 49 CFR
38.83(c)(3) and pose a barrier to individuals with mobility impairments and those using mobility
aides and devices. The 1/2 inch bridge plate thickness combined with the 0.2-inch dome height
on the tactile strip makes an abrupt step of 0.7-inches onto the bridge plate surface. The
truncated dome and bridge plate combined would present a tripping hazard for ambulatory
users and creates a hazard and reduces accessibility for persons using mobility devices.
In order to address the 49 CFR 38.83(c)(3) vertical change requirement, it is necessary for the
bridge plate end to be located below the top of the truncated detectable warning domes. TMS
therefore proposes a modification to the detectable warning area design at the TMS stop
platforms. The proposed modification will allow the TMS project to meet the intent of both
Standards.
The proposed modified tactile strip will still be 24- inches wide (see Exhibit 2), and will have the
in-line 0.2-inch truncated domes with a nominal spacing of 2.35-inch center-to-center spacing.
To accommodate the bridge plate, a flat, approximately 15.5-inch section of the tactile strip will
be provided to enable the transition from the tactile strip to the bridge plate and meet the ADA
requirements for transitional surfaces. As required by the 2010 Standards, the modified tactile
warning area is proposed to run along an 8 foot section along the platform that will coincide with
the streetcar door equipped with the bridge plate. The remaining length of the stop will have a
standard tactile warning area of a contrasting color (see Appendix A). This proposed
modification accommodates the bridge plate and increases accessibility for persons using
4
DRAFT
mobility devices, while at the same time retaining sufficient coverage of the detectible warning
strip to serve its intended purpose to alert the visually impaired of hazards in the circulation path
and the proximity of the platform edge.
Exhibit 2. Proposed Modified Tactile Warning Area/Bridge Plate Interface
V. Documentation of Public Participation
The Tucson Modern Streetcar Project has integrated accessible design in all project elements.
During the planning phase of the project the planning was coordinated with a Citizens Liaison
Group (CLG) and a Technical Advisory Committee (TAC), which included representation from
35 stakeholder groups and over 50 design professionals respectively. Included on the CLG was
representation from the City of Tucson’s Commission on Disability Issues (CODI). The CLG met
13 times, and 4 additional meetings were held with CODI representatives to review accessibility
issues for the design of the vehicle and the design of the stops. This input, as well as a review
of applicable American’s with Disabilities Act (ADA) regulations and standards were integrated
in to the design of both the vehicle and the stops. The following is a listing of meetings held:
Group
Community Liaison Group Meeting
Technical Advisory Committee Meeting
Date
November 4, 2004
December 8, 2004
Community Liaison Group Meeting
Technical Advisory Committee Meeting
Community Liaison Group Meeting
January 13, 2005
March 3, 2005
March 29, 2005
5
DRAFT
Technical Advisory Committee Meeting
Community Liaison Group Meeting
Community Liaison Group Meeting
Technical Advisory Committee Meeting
Community Liaison Group Meeting
Technical Advisory Committee Meetings
Community Liaison Group Meeting
Technical Advisory Committee Meetings
Community Liaison Group Meeting
Technical Advisory Committee Meeting
Community Liaison Group Meeting
Technical Advisory Committee Meetings
Community Liaison Group Meeting
Community Liaison Group Meeting
Technical Advisory Committee Meeting
CODI Transportation Subcommittee Meeting
CODI Transportation Subcommittee Meeting
Technical Advisory Committee Meeting
Community Liaison Group Meeting
Community Liaison Group Meeting
Technical Advisory Committee Meeting
CODI Transportation Subcommittee Meeting
CODI Transportation Subcommittee Meeting
May 18, 2005
May 19, 2005
October 6, 2005
October 6, 2005
November 9, 2006
November 9, 2006
February 28, 2007
February 28, 2007
June 27, 2007
June 27, 2007
November 1, 2007
November 1, 2007
September 18, 2008
March 11, 2009
March 11, 2009
November 10, 2009
November 18, 2009
December 3, 2009
December 3, 2009
June 21, 2010
June 21, 2010
July 21, 2010
March 16, 2011
In addition to the CLG, TAC, and CODI Transportation Subcommittee meetings, The TMS held
special meetings with the following groups to specifically discuss the proposed Equivalent
Facilitation



Representatives of CODI on December 1, 2011
The University of Arizona Disability Resource Center (UADRC), December 6, 2011
Southern Arizona Association for the Visually Impaired (SAAVI), December 7, 2011
Positive comment was received from each of these groups and they supported the request, see
Appendix B-E for support letters. Based on this, TMS has scheduled a public hearing on
January 10, 2012 to take comment on the draft Request. Public notice for the hearing will be
provided using the following methods:
The public notice for the hearing also indicated that the document was available in alternate
formats upon request and that written comment would also be accepted. Hard copies of the
document were provided at the hearing. The hearing was attended by XX individuals, and public
comment was received, and included in Appendix F.
6
DRAFT
APPENDIX A
TYPICAL STOP DESIGN PLAN
7
DRAFT
8
DRAFT
APPENDIX B
SAN DIEGO’S METROPOLITAN TRANSIT SYSTEM (MTS)
SUPPORT LETTER
9
DRAFT
10
DRAFT
11
DRAFT
APPENDIX C
TUCSON COMMISSION ON DISABILITY ISSUES (CODI)
SUPPORT LETTER
12
WB3 Management Consulting
Integration…Without
Assimilation.
DRAFT
Willie H. Bond, III
Chairperson
Tucson Commission on Disability Issues
Tucson, Arizona 85726
December 19, 2011
Shellie Ginn
Streetcar Program Manager
City of Tucson, Department of Transportation
P. O. Box 27210
Tucson, AZ 85726-7210
Ms. Ginn,
I, and several other Commissioners, had the pleasure of meeting with the Streetcar program
staff at the beginning of December. I must say that your staff proved to be very informative and helpful
in answering all questions posed by the CODI. We left the meeting feeling secure in that the streetcar
program, with the adjustments listed below, should meet the foreseeable needs of not just the disabled
residents and visitors of Tucson, but all residents and visitors of Tucson!
With that said, CODI supports the Tucson's modern streetcar project Equivalent Facilitation
requests as follows:
1. Modification of the tactile warning strips (truncated domes) to accommodate the bridge plate at
designated locations at the passenger stops.
2. Removal of the bridge plate side rails
CODI encourages the Federal Transit Administration to approve these requests.
13
Phone: 520.245.2585 | fax: 520.269.6362 | 14344 S. Via Del Moro, Sahuarita, Arizona 85629 | www.wb3consulting.com
DRAFT
APPENDIX D
SOUTHERN ARIZONA ASSOCIATION
FOR THE VISUALLY IMPAIRED (SAAVI)
SUPPORT LETTER
14
DRAFT
15
DRAFT
APPENDIX E
THE UNIVERSITY OF ARIZONA
DISABILITY RESOURCE CENTER (UARDC)
SUPPORT LETTER
16
DRAFT
17
DRAFT
APPENDIX F
PUBLIC COMMENTS
18
DRAFT
19