U.S. District Court District of Columbia (Washington, DC) CIVIL DOCKET FOR CASE #: 1:20-cv-03503-UNA

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Complaint ﬁled by the United States against the National Passenger Railroad Corporation - Amtrak

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Press Release

UNITED STATES OF AMERICA, Disability Rights Section (NYA) U.S. Department of Justice 950 Pennsylvania Ave., N.W. – NYA Washington, DC 20530
Plaintiff,
v.
THE NATIONAL PASSENGER RAILROAD CORPORATION (AMTRAK), 60 Massachusetts Avenue, N.E. Washington, DC 20002
Defendant.

CIVIL ACTION NO.: 1:20-cv-3503
COMPLAINT
JURY TRIAL DEMANDED

INTRODUCTION
1. The United States brings this action against Defendant, the National Railroad Passenger Corporation (Amtrak), to enforce Title II of the Americans with Disabilities Act of 1990, as amended (ADA), 42 U.S.C. §§ 12131-12165, and its implementing regulation, 49 C.F.R. Pt. 37.

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2. Defendant violated and continues to violate the ADA and its implementing regulation by failing to make existing stations in its intercity rail transportation system, for which it is responsible, readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs, as soon as practicable after July 26, 1990, but in no event later than July 26, 2010. 42 U.S.C § 12162(e)(2)(A); 49 C.F.R. §§ 37.43 and 37.55. “Stations” includes buildings (comprised of designated waiting areas, ticketing areas, restrooms, concessions, etc.), passenger platforms, and parking. 42 U.S.C. § 12161(6); 49 C.F.R. § 37.3.

BACKGROUND

3. Congress enacted the ADA in 1990 “to provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities.” 42 U.S.C. § 12101(b)(1). In enacting the ADA, Congress found that discrimination against individuals with disabilities persists in transportation. See 42 U.S.C. § 12101(a)(3).

4. The ADA states that no qualified individual with a disability shall, because of such disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity, or be subjected to discrimination by a public entity. 42 U.S.C. § 12132.

5. In commencing this action under the ADA, the United States seeks to end Amtrak’s decades-long failure to make its stations accessible to individuals with disabilities so that they can fully participate in and benefit from Amtrak’s transportation services. See 42 U.S.C. § 12133.

JURISDICTION AND VENUE

6. This Court has jurisdiction over this action under the ADA, 42 U.S.C. § 12133, and 28 U.S.C. §§ 1331, 1343(a), and 1345, because it involves claims arising under federal law and is commenced by the United States.

7. The Court may grant the relief sought in this action pursuant to 28 U.S.C. §§ 2201-2202

and 42 U.S.C. § 12133.

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8. Venue is proper in this district pursuant to 28 U.S.C. § 1391 because Amtrak is headquartered in this district, operates and resides in this district, and a substantial part of the events or omissions giving rise to the claims occurred in this district.

PARTIES

9. Plaintiff is the United States of America.

10. Defendant Amtrak is a provider of intercity rail transportation service.

ADA

11. Amtrak is a “public entity” subject to the ADA and its implementing regulation, 42 U.S.C. § 12131(1)(C) and 49 C.F.R. Part 37.

12. The ADA required Amtrak to make its existing stations in its intercity rail transportation system readily accessible to and usable by individuals with disabilities, no later than July 26, 2010. 42 U.S.C. § 12162(e)(2)(A); 49 C.F.R. §§ 37.43 and 37.55.

13. To make its existing stations readily accessible to and usable by individuals with disabilities, Amtrak must comply with the Department of Transportation Standards for Accessible Transportation Facilities (DOT Standards). 49 C.F.R. §§ 37.9, 37.43(a)(3), and 49 C.F.R. Part. 37, App. A.

FACTS

AMTRAK RAIL SERVICE

14. Amtrak provides intercity rail transportation services within the meaning of the ADA to passengers, including passengers with disabilities. See 42 U.S.C. §§ 12131(1)(C), 12161(3).

15. Amtrak operates more than 300 trains each day on 30 routes and connects more than 500 destinations in 46 states.

16. In Fiscal Year 2019 (October 2018-September 2019), Amtrak had $3.3 billion in revenue and a total ridership of 32.5 million passenger trips.

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COMPLAINTS AGAINST AMTRAK

17. The United States Department of Justice opened an investigation of Amtrak under Title II of the ADA following receipt of complaints in 2011 and 2012 from individuals with disabilities alleging that certain Amtrak stations are inaccessible.

18. The Department also received a complaint in 2013 from the National Disability Rights Network (NDRN), the nonprofit membership organization for the federally mandated Protection and Advocacy (P&A) Systems and Client Assistance Programs (CAP) for individuals with disabilities. P&As and CAPs work to improve the lives of people with disabilities, including by ensuring access and accountability in health care, education, employment, housing, transportation, voting, and within the juvenile and criminal justice systems. The complaint included an NDRN-generated report alleging that Amtrak stations across the country were inaccessible in violation of the ADA. NDRN based its report on more than 100 on-site surveys conducted in the summer of 2013 of Amtrak stations across the country. NDRN alleged ADA violations of the DOT Standards at stations for which Amtrak was responsible.

LETTER OF FINDINGS

19. On June 9, 2015, the Department issued a Letter of Findings (LOF) notifying Amtrak of the Department’s determination that Amtrak failed to comply with the ADA. The LOF notified Amtrak that it had failed to make its existing stations readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs, and of necessary remedies to bring its services, programs, and activities into compliance with the ADA.

INACCESSIBLE STATIONS

20. As of July 27, 2010, Amtrak failed to make its stations readily accessible to and usable by individuals with disabilities, including those who use wheelchairs, as prescribed by the DOT Standards with respect to parking, routes from accessible parking to buildings, building entrances, waiting areas, elevators, toilet rooms, signs, routes from buildings to passenger

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platforms, passenger platforms, passenger platform heights, and track crossings, including as alleged in paragraphs 21 through 31.

21. Parking. As of July 27, 2010, Amtrak failed to make parking readily accessible to and usable by individuals with disabilities as prescribed by the DOT Standards, including at the following stations: Tuscaloosa, Alabama; Little Rock, Arkansas; Malvern, Arkansas; Texarkana, Arkansas; Grand Junction, Colorado; Windsor, Connecticut; Winter Haven, Florida; Atlanta, Georgia; Waterloo, Indiana; Newton, Kansas; Red Wing, Minnesota; Jefferson City, Missouri; Malta, Montana; Plattsburgh, New York; Rhinecliff, New York; Rochester, New York; Williston, North Dakota; Pittsburgh, Pennsylvania; Charleston, South Carolina; Florence, South Carolina; Marshall, Texas; and Lorton, Virginia. For example, parking spaces at some stations were not located on the shortest accessible route from parking to the accessible building entrance, violating DOT Standards § 208.3.1. Some stations had parking spaces without access aisles, violating DOT Standards §§ 208.1, 208.2, and 502.2. Certain stations had parking spaces with access aisles that were not adjoining an accessible route, violating DOT Standards §§ 208.1, 208.2, 502.2, and 502.3. Some stations had parking spaces with access aisles that were too narrow, violating DOT Standards §§ 208.1, 208.2, 502.2, and 502.3.1. Certain stations had parking spaces with access aisles that were not demarcated, violating DOT Standards §§ 208.1, 208.2, 502.2, and 502.3.3. A number of stations had parking spaces and access aisles with surfaces that were not stable, firm, and slip resistant, violating DOT Standards §§ 208.1, 208.2, 302.1, 502.2, and 502.4. Also, several stations had parking spaces that lacked accessible signage, violating DOT Standards §§ 208.1, 208.2, and 502.6.

22. Routes from Accessible Parking to Buildings. As of July 27, 2010, Amtrak failed to make the routes from accessible parking, public streets, sidewalks, and public transportation stops to the entrances of buildings accessible to individuals with disabilities as prescribed by the DOT Standards, including at the following stations: Tuscaloosa, Alabama; Little Rock, Arkansas; Texarkana, Arkansas; Grand Junction, Colorado; Windsor, Connecticut; Winter Haven, Florida; Atlanta, Georgia; Waterloo, Indiana; Red Wing, Minnesota; Williston, North Dakota; Pittsburgh, Pennsylvania; Charleston, South Carolina; Florence, South Carolina; and

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Complaint ﬁled by the United States against the National Passenger Railroad Corporation - Amtrak
Marshall, Texas. For example, the running slopes and cross slopes of some walking surfaces and ramps were too steep, violating DOT Standards §§ 206.1, 206.2.1, 303.4, 402.1, 403.3, 403.4, 405.1, and 406.1. Some routes were too narrow, violating DOT Standards §§ 206.1, 206.2.1, 402.1, and 403.5. The surfaces along certain routes were not stable, firm, and slip resistant, violating DOT Standards §§ 206.1, 206.2.1, 302.1, and 403.2. Certain routes lacked curb ramps, violating DOT Standards §§ 206.1, 206.2.1, 303.4, 403.4, and 406.1. Some of the routes had ramps with no edge protection, violating DOT Standards §§ 206.1, 206.2.1, 303.4, and 405.9. Certain routes had ramps with no handrails, violating DOT Standards §§ 206.1, 206.2.1, 303.4, and 405.8. Some curb ramps projected into vehicular traffic lanes, violating DOT Standards §§ 206.1, 206.2.1, 303.4, and 406.5. Several routes had objects protruding more than four inches into the circulation paths without a cane detectable barrier, violating DOT Standards §§ 204.1, 307.2, and 307.5.

23. Building Entrances. As of July 27, 2010, Amtrak failed to make building entrances readily accessible to and usable by individuals with disabilities as prescribed by the DOT Standards, including at the following stations: Tuscaloosa, Alabama; Little Rock, Arkansas; Texarkana, Arkansas; Grand Junction, Colorado; Winter Haven, Florida; Atlanta, Georgia; Macomb, Illinois; Mount Pleasant, Iowa; Newton, Kansas; Red Wing, Minnesota; St. Cloud, Minnesota; Jefferson City, Missouri; La Plata, Missouri; Malta, Montana; Plattsburgh, New York; Rhinecliff, New York; Williston, North Dakota; Pittsburgh, Pennsylvania; Charleston, South Carolina; Florence, South Carolina; and Lorton, Virginia. For example, the entrances at certain of these buildings had door openings that were too narrow, violating DOT Standards §§ 206.4, 404.1, and 404.2.3. Some of these building entrances had doors with maneuvering clearances that were too small, violating DOT Standards §§ 206.4, 404.1 and 404.2.4. Certain entrances had maneuvering clearances with slopes that were too steep, violating DOT Standards §§ 206.4, 404.1 and 404.2.4.4. Some entrance doorway thresholds were too high, violating DOT Standards §§ 206.4, 404.1, and 404.2.5. Specific exterior door hardware was mounted too low, violating DOT Standards §§ 206.4, 404.1, and 404.2.7. Certain entrance door hardware required tight grasping, pinching, or twisting of the wrist, violating DOT Standards §§ 206.4, 404.1, 309.4, and 404.2.7.

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24.

Complaint ﬁled by the United States against the National Passenger Railroad Corporation - Amtrak
Waiting Areas. As of July 27, 2010, Amtrak failed to make waiting areas readily

accessible to and usable by individuals with disabilities as prescribed by the DOT Standards,

including at the following stations: Little Rock, Arkansas; Texarkana, Arkansas; Grand

Junction, Colorado; Winter Haven, Florida; Atlanta, Georgia; Rochester, New York; Williston,

North Dakota; Pittsburgh, Pennsylvania; Charleston, South Carolina; Florence, South

Carolina; and Lorton, Virginia. For example, routes throughout the waiting areas at particular

stations had excessive cross slopes, violating DOT Standards §§ 206.1, 206.2.4, 402.1, and

403.3. Certain routes to and through the waiting areas were too narrow, violating DOT

Standards § 206.1, 206.2.4, 402.1, and 403.5. Ramps to some waiting areas had handrails that

did not extend past the end of the ramp, violating DOT Standards §§ 206.1, 206.2.4, 402.1,

405.8, and 505.10. Some ramps to waiting areas had a handrail that was only provided on one

side, violating DOT Standards §§ 206.1, 206.2.4, 402.1, 405.8, 505.1, and 505.2. Also, ticket

counters in certain waiting areas were too high, violating DOT Standards §§ 227.1, 227.3, and

904.4. Various waiting areas lacked visual fire alarms, violating DOT Standards §§ 215.1,

215.2, and 702.1.

25. Elevators. As of July 27, 2010, Amtrak failed to make elevators readily accessible to and usable by individuals with disabilities as prescribed by the DOT Standards, including at the following stations: Atlanta, Georgia; Pittsburgh, Pennsylvania; and Marshall, Texas. In Atlanta, Georgia, the elevator car visible position indicator and visible signal at each hoistway entrance did not operate, violating DOT Standards §§ 206.1, 206.2.3, 402.1, 407.2.2.1, and 407.4.8 and 49 C.F.R. § 37.161. In Pittsburgh, Pennsylvania, the elevators lacked visible hall signals that could indicate which elevator car was arriving and had in-car signals that were not visible from the area adjacent to the hall call button, had no visible car position indicator in the elevator cab, and the emergency communication systems were not identified with tactile symbols, violating DOT Standards §§ 206.1, 206.2.3, 402.1, 407.1, 407.2.2.1, 407.4.8, and 407.4.9. The elevator in Marshall, Texas, was not operable, violating DOT Standards §§ 206.1, 206.2.3, 402.1, 407.1 and 49 C.F.R. § 37.161.

26. Toilet Rooms. As of July 27, 2010, Amtrak failed to make toilet rooms in buildings readily accessible to and usable by individuals with disabilities as prescribed by the DOT Standards,

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including at the following stations: Birmingham, Alabama; Tuscaloosa, Alabama; Little Rock, Arkansas; Grand Junction, Colorado; Winter Haven, Florida; Atlanta, Georgia; Effingham, Illinois; Homewood, Illinois; Princeton, Illinois; Mount Pleasant, Iowa; Newton, Kansas; Red Wing, Minnesota; St. Cloud, Minnesota; Jefferson City, Missouri; Malta, Montana; Plattsburgh, New York; Rhinecliff, New York; Rochester, New York; Williston, North Dakota; Pittsburgh, Pennsylvania; Charleston, South Carolina; Florence, South Carolina; Marshall, Texas; and Lorton, Virginia. For example, some station toilet room doors lacked maneuvering clearance for wheelchairs, violating DOT Standards §§ 206.5.2 and 404.2.4. Some station toilet room doors had hardware that required tight grasping, pinching, and twisting of the wrist to operate, violating DOT Standards §§ 206.5.2 and 404.2.7. Certain station toilet room door openings were too narrow, violating DOT Standards §§ 206.5.2 and 404.2.3. Some stations had toilet rooms with water closet seats that were too high, violating DOT Standards §§ 213.3.2 and 604.4. In water closets at some stations, the flush controls were not on the open side of the water closet, violating DOT Standards §§ 213.3.2 and 604.6. Certain toilet rooms had lavatories with insufficient knee or toe clearance, violating DOT Standards §§ 213.3.4 and 606.2. The lavatory faucet hardware in some toilet rooms was not operable without tight grasping, pinching, or twisting of the wrist, violating DOT Standards §§ 213.3.4, 309.4, and 606.4. The water supply and drain pipes under certain lavatories were not insulated or otherwise configured to protect against contact, violating DOT Standards §§ 213.3.4 and 606.5. The lavatories in some toilet rooms were too high, violating DOT Standards §§ 213.3.4 and 606.3. In some toilet rooms, the bottom of the mirror-reflecting surfaces were too high, violating DOT Standards §§ 213.3.5 and 603.3. There were also objects in various toilet rooms protruding more than four inches into the circulation path without a cane detectable barrier, violating DOT Standards §§ 204.1 and 307.1.

27. Signs. As of July 27, 2010, Amtrak failed to make signs readily accessible to and usable by

individuals with disabilities as prescribed by the DOT Standards, including at the following

stations: Little Rock, Arkansas; Texarkana, Arkansas; Grand Junction, Colorado; Winter

Haven, Florida; Atlanta, Georgia; Waterloo, Indiana; Williston, North Dakota; Pittsburgh,

Pennsylvania; Charleston, South Carolina; Florence, South Carolina; and Lorton, Virginia.

For example, at certain stations Amtrak failed to provide directional signage at inaccessible

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building entrances indicating the location of the nearest accessible entrance, violating DOT Standards § 216.6. Also, at some buildings Amtrak provided inaccessible interior signs identifying permanent rooms and spaces, violating DOT Standards §§ 216.2, 703.1, 703.2, and 703.5. At the passenger platforms for some of these buildings, Amtrak provided signs without raised characters on the platform identifying a station or its entrance, violating DOT Standards §§ 218.3 and 810.6.1. At certain stations, Amtrak failed to provide station identification signs that were clearly visible and within the sight lines of standing and sitting passengers from within the vehicle on both sides when not obstructed by another train, violating DOT Standards §§ 218.3 and 810.6.3.

28. Routes from Buildings to Passenger Platforms. As of July 27, 2010, Amtrak failed to make routes from buildings to passenger platforms readily accessible to and usable by individuals with disabilities as prescribed by DOT Standards, including at the following stations: Malvern, Arkansas; New London, Connecticut; Winter Haven, Florida; Waterloo, Indiana; Red Wing, Minnesota; Florence, South Carolina; Ashland, Virginia; Fredericksburg, Virginia; and Lorton, Virginia. For example, several routes from buildings to passenger platforms had openings in the floor or ground surfaces that were too wide, violating DOT Standards §§ 206.2.4, 302.3, 402.1, and 403.2. Some routes had running slopes that were too steep, violating DOT Standards §§ 206.2.4, 402.1, and 403.3. Certain routes had steps or other vertical changes in level that were too great, violating DOT Standards §§ 206.2.4, 303.4, 402.1, and 403.4. Various routes had objects protruding more than four inches into the circulation path without a cane detectable barrier, violating DOT Standards §§ 204.1 and 307.1.

29. Passenger Platforms. As of July 27, 2010, Amtrak failed to make passenger platforms readily accessible to and usable by individuals with disabilities as prescribed by the DOT Standards, including at the following stations: Birmingham, Alabama; Little Rock, Arkansas; Texarkana, Arkansas; Grand Junction, Colorado; New London, Connecticut; Windsor, Connecticut; Tampa, Florida; Winter Haven, Florida; Atlanta, Georgia; Centralia, Illinois; Effingham, Illinois; Homewood, Illinois; Macomb, Illinois; Mattoon, Illinois; Princeton, Illinois; Waterloo, Indiana; Dowagiac, Michigan; Hudson, New York; Plattsburgh, New York;

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Rhinecliff, New York; Williston, North Dakota; Pittsburgh, Pennsylvania; Charleston, South Carolina; Florence, South Carolina; Temple, Texas; Ashland, Virginia; Williamsburg, Virginia; Charleston, West Virginia; and Martinsburg, West Virginia. For example, several passenger platforms had running and cross slopes that were too steep, violating DOT Standards §§ 218.3 and 810.5.1. Some passenger platforms had no detectable warnings at the boarding edges, violating DOT Standards §§ 218.3 and 810.5.2. Particular passenger platforms had floor and ground surfaces that were not stable, firm, and slip resistant, violating DOT Standards §§ 206.2.4, 302.1, 402.1, and 403.2. Various passenger platforms had objects protruding more than four inches into the circulation path without a cane detectable barrier, violating DOT Standards §§ 204.1 and 307.1. Particular passenger platforms had surfaces that were in disrepair, violating DOT Standards §§ 206.2.4, 402.1, and 403.2 and 49 C.F.R. § 37.161.

30. Passenger Platform Heights and Gaps. As of July 27, 2010, Amtrak failed to make the passenger platforms readily accessible to and usable by individuals with disabilities as prescribed by the DOT Standards, including at the following stations: Little Rock, Arkansas; Texarkana, Arkansas; Winter Haven, Florida; Atlanta, Georgia; Red Wing, Minnesota; Williston, North Dakota; Charleston, South Carolina; Florence, South Carolina; and Ashland, Virginia. At these stations, Amtrak had excessive horizontal gaps or vertical height differences between the passenger platforms and the rail car floors, violating DOT Standards §§ 218.3 and 810.5.3 and 36 C.F.R. § 1192.113(d).

31. Track Crossings. As of July 27, 2010, Amtrak failed to make track crossings readily accessible to and usable by individuals with disabilities as prescribed by the DOT Standards, including at the following stations: Grand Junction, Colorado; Atlanta, Georgia; Princeton, Illinois; Waterloo, Indiana; Mount Pleasant, Iowa; Ottumwa, Iowa; Newton, Kansas; La Plata, Missouri; and Ashland, Virginia. For example, certain track crossings were not stable, firm, and slip resistant, violating DOT Standards §§ 218.3, 302.1, 402.1, and 810.10. Some track crossings had cross slopes that were too steep, violating DOT Standards §§ 218.3, 402.1, 403.3, and 810.10. Some track crossings had vertical changes in level that were too great,

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violating DOT Standards §§ 218.3, 402, 403.4, 810.10. In addition, some track crossings had openings for wheel flanges that were too wide, violating DOT Standards §§ 218.3 and 810.10.

32. Amtrak’s failure nationwide to make its existing stations readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs, as prescribed by the DOT Standards and required by the ADA, harmed individuals with disabilities across the country who use or seek to use Amtrak’s transportation services.

33. Amtrak’s failures nationwide to make its existing stations readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs, continue today, and these failures continue to harm individuals with disabilities across the country who use or seek to use Amtrak’s transportation services.

CAUSE OF ACTION

VIOLATION OF THE ADA

34. The United States re-alleges and incorporates by reference the allegations set forth in all the preceding paragraphs.

35. Amtrak’s actions in failing to make its existing stations readily accessible to and usable by individuals with disabilities as soon as practicable and by no later than July 26, 2010, constitute discrimination in violation of the ADA, and its implementing regulation. 42 U.S.C. §§ 12132 and 12162(e)(2)(A); 49 C.F.R. §§ 37.43 and 37.55.

36. Individuals have been harmed and continue to be harmed by Amtrak’s failure to make its existing stations readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs, and are entitled to damages to include compensatory damages and damages for emotional distress, humiliation, delay, and inconvenience. 42 U.S.C. § 12133.

37. Amtrak acted intentionally by failing to make its existing stations accessible.

38. Unless restrained by this Court, Amtrak will continue to violate the ADA and cause harm to

individuals with disabilities.

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Complaint ﬁled by the United States against the National Passenger Railroad Corporation - Amtrak
PRAYER FOR RELIEF

The United States prays that the Court:

A. Grant judgment in favor of the United States and declare that Amtrak has violated the ADA, 42 U.S.C. §§ 12131-12165, and its implementing regulation, 49 C.F.R. Part 37.

B. Enjoin Amtrak, and its officers, agents, servants, employees, and attorneys, and other persons who are in active concert or participation with Amtrak, from engaging in discriminatory policies and practices against individuals based on disability, and specifically from failing or refusing to comply with the requirements of the ADA, 42 U.S.C. §§ 1213112165, and its implementing regulation, 49 C.F.R. Part 37.

C. Order Amtrak, and its officers, agents, servants, employees, and attorneys, and other persons who are in active concert or participation with Amtrak, to make the existing stations for which it is responsible readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs. 42 U.S.C. §§ 12131-12165, 49 C.F.R. Part 37.

D. Award compensatory damages, including damages for emotional distress, to persons aggrieved by Amtrak’s failure to comply with the ADA, 42 U.S.C. §§ 12131-12165, and its implementing regulation, 49 C.F.R. Part 37. 42 U.S.C. § 12133.

E. Order all other appropriate relief.

JURY DEMAND

The United States hereby demands a trial by jury on all issues so triable, pursuant to Rule 38 of the Federal Rules of Civil Procedure.

Respectfully submitted this the 2nd day of December, 2020.

FOR THE UNITED STATES:

MICHAEL R. SHERWIN Acting United States Attorney
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/s/ ERIC S. DREIBAND
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District of Columbia

Assistant Attorney General

DANIEL F. VAN HORN

Civil Rights Division

D.C. BAR #924092

CYNTHIA M. McKNIGHT

Chief, Civil Division

Deputy Assistant Attorney General

Civil Rights Division /s/

JOHN C. TRUONG

REBECCA B. BOND

D.C. BAR #465901

Chief

Assistant United States Attorney

KATHLEEN P. WOLFE

555 4th Street, N.W.

Special Litigation Counsel

Washington, DC 20530

KEVIN J. KIJEWSKI

Tel: (202) 252-2524

Deputy Chief

John.Truong@usdoj.gov

Disability Rights Section

Civil Rights Division

/s/ DAVID W. KNIGHT Trial Attorney FELICIA L. SADLER Trial Attorney Disability Rights Section Civil Rights Division U.S. Department of Justice 150 M Street, N.E. Washington, DC 20002 Telephone: (202) 616-2110 David.Knight@usdoj.gov

ADA Enforcement Page | ADA Home Page

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Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND NATIONAL RAILROAD PASSENGER CORPORATION
(“AMTRAK”)
Press Release
I. INTRODUCTION
1. The United States of America (“United States”) intends to bring an action against the National Railroad Passenger Corporation (“Amtrak”) to enforce Title II of the Americans with Disabilities Act of 1990, as amended (“ADA”), 42 U.S.C. § 1213112165, and its implementing regulation, 49 C.F.R. Part 37, United States v. Amtrak (the “Civil Action”). The United States alleges Amtrak violated Title II of the ADA by failing to make the existing stations1 for which it is responsible in its intercity rail transportation system readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs, per the U.S. Department of Transportation Standards for Accessible Transportation Facilities (“DOT Standards”), 49 C.F.R. §§ 37.9 and 37.43, and 49 C.F.R. Part 37, Appendix A. The United States further alleges this has harmed passengers with disabilities using or seeking to use Amtrak’s services. Amtrak denies these allegations and asserts that it is, and has been, committed to complying with the ADA and to accommodating individuals with disabilities, but it enters into this Settlement Agreement (“Agreement”) voluntarily in order to continue in good faith to devote significant resources to improve transportation services to passengers with disabilities as it has for several years, rather than in litigation.
2. The United States and Amtrak (collectively, the “Parties”) agree that it is in the Parties’ best interests, and the public’s interest, to resolve this matter on mutually agreeable terms. The Parties acknowledge and agree that the fact that Amtrak has entered into this Agreement should not be considered an admission or evidence of guilt

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or liability. The Parties therefore agree and stipulate to enter into this Agreement to resolve the United States’ complaint against Amtrak.

II. AMTRAK

3. Amtrak operates at approximately 500 stations across 46 states and the District of Columbia, and is a corporation organized under the laws of the District of Columbia. 49 U.S.C. § 24301(a)(2). The parties agree that Amtrak is deemed a “public entity” for purposes of the ADA, 42 U.S.C. § 12131(1)(C) and 49 C.F.R. § 37.3, that is subject to Title II of the ADA and its implementing regulations, 28 C.F.R. Part 35 and 49 C.F.R. Parts 37 and 38.

III. TERMS

4. Amtrak will comply with Title II of the ADA, 42 U.S.C. §§ 12131-12165, and its implementing regulation, 49 C.F.R. Parts 37, and will modify its policies, practices, and procedures, to the extent set forth herein, when such modifications are necessary to bring its intercity rail transportation service into compliance with Title II of the ADA.

5. Amtrak will take steps, where expressly required by this Agreement, to inform its agents, vendors, contractors, and service providers that each must comply with Title II of the ADA and its accessible transportation requirements.

6. Amtrak will not retaliate against or coerce in any way any person who has tried or tries to exercise his or her rights under this Agreement or Title II of the ADA.

7. When Amtrak constructs any new station, Amtrak shall construct it to be readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs, unless Amtrak can demonstrate that it is structurally impracticable, as required by 42 U.S.C. § 12162(e)(1) and 49 C.F.R. § 37.41.

8. Consistent with the terms set forth in this Agreement, Amtrak shall make existing stations for which it is responsible readily accessible to and usable by individuals with

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disabilities, including individuals who use wheelchairs, as required by 42 U.S.C. § 12162(e)(2)(A)(i) and 49 C.F.R. § 37.49.

9. When Amtrak alters an existing station or part of an existing station in a way that affects or could affect the usability of the facility or part of the facility, Amtrak shall make the alterations “in such a manner that, to the maximum extent feasible, the altered portions of the facility are readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs, upon the completion of such alterations,” as required by 42 U.S.C. § 12162(e)(2)(B)(i) and 49 C.F.R. § 37.43. When Amtrak undertakes an alteration that affects or could affect the usability of or access to an area of a facility containing a primary function, Amtrak “shall make the alterations in such a manner that, to the maximum extent feasible, the path of travel to the altered area and the bathrooms, telephones, and drinking fountains serving the altered area, are readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs,” if the cost and scope of doing so would not be disproportionate, as required by 42 U.S.C. § 12162(e)(2)(B)(ii) and 49 C.F.R. § 37.43(a).

ADA Stations Program (“ADASP”)

10. Amtrak alleges it has expended hundreds of millions of dollars improving access to its trains in a variety of ways. Beginning in 2009, Amtrak implemented the ADA Stations Program (“ADASP”), through which Amtrak plans for the design and construction of ADA-compliant station facilities, including buildings, passenger platforms, and parking. Under the current ADASP, Amtrak prioritizes projects as follows:

A. The 24 stations originally identified as having significant known or potential accessibility deficiencies, attached as Exhibit 1;

B. Passenger Information Display Systems (“PIDS”). PIDS provide both audio and visual messages for passengers, including passengers with disabilities. A list of stations for which Amtrak has ADA responsibility or is voluntarily installing PIDS is attached as Exhibit 2 (many of which have already been installed);

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C. Additional stations with known or potential building access or key amenity deficiencies (such as entrances, restrooms, or ticket counters); and

D. Ensuring access to all accessible cars in each Amtrak train servicing a station in an integrated setting, by providing level-entry passenger platforms where legally required, or, with the Federal Railroad Administration’s (FRA) approval of a proposed plan, by an alternate means of achieving access to all accessible cars in each Amtrak train servicing the station to the maximum extent feasible, as required by 42 U.S.C. § 12162(e)(2)(B)(i) and 49 C.F.R. § 37.43.

11. Consistent with Amtrak’s mission, and the terms in this Agreement, Amtrak will continue to expand on its existing ADASP (including with the deliverables identified in Paragraphs 12-16), which will also include a rolling ADASP Five Year Strategic Plan (see Paragraphs 17-18) and an ADASP Sunset Analysis (see Paragraph 19).

12. Property Surveys. As of the Effective Date of this Agreement, Amtrak agrees that it has completed Property Surveys and/or will conduct any needed title and public record data searches for all of the station facilities in Exhibit 3 for which Amtrak has ADA responsibility. 2 These Property Surveys document property lines and ownership of each such station and its surrounding area and help determine Amtrak’s legal responsibilities under the ADA. Nothing in this Paragraph is intended to restrict or limit Amtrak from performing additional Property Surveys determined to be necessary in the future or to require Amtrak to conduct any Property Surveys where it no longer has ADA responsibility.

13. ADA Assessments. By December 31, 2022, Amtrak agrees to complete ADA Assessments for the station facilities in Exhibit 3 where Amtrak has sole or shared responsibility for ADA compliance, documenting the ADA noncompliance at each of these station facilities unless, following a Property Survey or the receipt of other reliable or material information, the Parties agree that Amtrak does not have ADA responsibility for all or part of a station. For station facilities for which Amtrak acquires sole or shared responsibility for ADA compliance after the Effective Date of this Agreement,

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Amtrak shall have 12 months from the date it acquires ADA responsibility for that station facility to complete any needed ADA Assessment. Nothing in this Paragraph limits Amtrak from performing additional ADA Assessments it determines to be necessary, even if Amtrak does not have responsibility under the ADA for all or part of a station facility.

14. PIDS Deployment. Amtrak will continue its program of deploying PIDS at the stations set forth in Exhibit 2 in accordance with the ADA and the DOT Standards, § 810.7, to the extent that it does not already have PIDS. For purposes of this Agreement, PIDS deployment at a station will be considered to have been completed as soon as the system is in use.

15. Timeline for Station Facility Remediation. Amtrak will continue to eliminate station accessibility deficiencies with respect to station facilities for which Amtrak has continuing ADA responsibility, including by installing additional PIDS as set forth in its plan and in Exhibit 2, and completing building, passenger platform, and parking construction in accordance with the ADA and the DOT Standards (dimensions are subject to conventional industry tolerances, except where the requirement is stated as a range with specific minimum and maximum end points, pursuant to DOT Standards § 104.1.1), as set forth below. However, the listed mega stations, while subject to the obligation to be accessible (see Paragraph 8), due to their size and complexity, are exempt from the remediation timelines set forth in this Agreement.3

A. Amtrak will undertake and complete 100% design4 documents for station accessibility for at least 15 stations (not including stations with only PIDS deficiencies) per year for the duration of this Agreement until the number of stations needing design documents is exhausted.

B. The Parties agree that Amtrak cannot commence station construction or deploy PIDS until it receives formal approvals, acceptances, permits, consents, and agreements (“Approvals”) from external agencies and third parties that are not within Amtrak’s control. These may include Approvals from FRA (except for

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PIDS deployment, which FRA does not review), State Historic Preservation Officers, state environmental regulators, utilities, labor unions, other third parties whose property or legal interests may be affected by the proposed work, or agencies or officials whose approval FRA deems necessary or whose authority Amtrak is subject to with respect to station construction.
C. Amtrak will initiate the process for obtaining all required Approvals for station construction and PIDS deployment as soon as practicable and in accordance with normal construction and design practices after the completion of the 100% design documents, and from individuals or entities other than FRA, after FRA acceptance (except for PIDS deployment, which FRA does not review).
D. Amtrak will attempt to obtain all requisite Approvals within 180 days after completion of the 100% design documents. However, this 180-day timeline is not binding if Amtrak seeks but fails to receive required Approvals within that time period. Amtrak shall reasonably respond to FRA or any other agency, whose authority Amtrak is subject to with respect to building, passenger platform, PIDS, or parking construction (an “Authorizing Agency”), that has objections or has provided comments requiring a response, and shall comply with all reasonable Authorizing Agency requests related to obtaining Approvals within all applicable time frames. Amtrak’s time for completing station construction (set forth below) will not begin to run until all required Approvals have been obtained.
16. Once all required Approvals are finalized, and Amtrak is authorized to begin construction, Amtrak will have 36 months to complete all station construction included in the project’s scope for which Approvals were finalized. Amtrak will comply with Title II of the ADA and the DOT Standards, subject to this Agreement, in completing alterations to the station facilities for which Amtrak has responsibility, will deploy PIDS (if any), and also will also complete alterations at least to the path of travel from the parking (if provided) or drop-off point for Amtrak passengers to the platform.
ADASP Five Year Strategic Plan

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17. Amtrak’s ADASP Five Year Strategic Plan outlines the strategy and tasks that Amtrak plans to implement and complete during the following fiscal year (starting on October 1), as well as the tasks planned for the subsequent four fiscal years. Each year during this Agreement, Amtrak will update its ADASP Five Year Strategic Plan to plan as to how Amtrak will make all of those station facilities for which Amtrak is responsible accessible to and usable by individuals with disabilities, to the maximum extent feasible. Amtrak will submit a draft to DOJ and FRA in accordance with deadlines established by FRA. DOJ will provide any feedback, in writing, within 45 days of receipt. Amtrak will send the final FRA-approved ADASP Five Year Strategic Plan to DOJ approximately annually, and Amtrak will consider and respond to comments from DOJ on that FRA-approved plan when developing the following year’s ADASP Five Year Strategic Plan. Amtrak will adopt the ADASP Five Year Strategic Plan each year in accordance with deadlines as established by FRA.
18. Amtrak will plan its projects so that all of the station facilities for which Amtrak is responsible are accessible to and usable by individuals with disabilities. Amtrak will use the Prioritization Tool (originally created by FRA and now maintained by Amtrak and which may change from time to time by agreement between Amtrak and FRA). The Prioritization Tool currently prioritizes the following:
A. Alterations to station facilities (including buildings, passenger platforms, or parking) that will have a significant impact on access to individuals with disabilities, including: buildings, passenger platforms, or parking with a path-oftravel deficiency; buildings with key amenity deficiencies (such as entrances, restrooms, or ticket counters); inaccessible parking; passenger platforms where level boarding is required by law but does not exist; and stations that have legal deficiencies in the provision of audio and visual messages to passengers with hearing or vision disabilities; and
B. Modifications to station facilities at stations with high ridership.
ADASP Sunset Analysis

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19. Prior to the Effective Date of this Agreement, Amtrak created and produced to DOJ and FRA an ADASP Sunset Analysis based on the current, existing FRA-approved Prioritization Tool that plans and prioritizes major station accessibility projects in its system. Amtrak will update the ADASP Sunset Analysis in 2022, and if requested by DOJ or FRA again in 2026. Amtrak will submit the ADASP Sunset Analysis to DOJ and FRA. Amtrak’s ADASP Sunset Analysis will utilize the Prioritization Tool to identify the remaining accessibility deficiencies at station facilities for which Amtrak is responsible (Exhibit 3) and include a general estimate of the anticipated cost and timing for remediation based on the assumption that Amtrak will not face material obstacles in obtaining Approvals or in the remediation/construction project.
ADA Training
20. Amtrak alleges it has always had a robust, multifaceted ADA training program. Prior to the Effective Date of this Agreement, Amtrak developed a training program for its customer-facing employees whose primary job requirements include interaction with passengers, i.e., Conductors and Assistant Conductors, Customer Service Representatives, Station/Ticket Agents, Customer Service staff, Red Caps, Ushers, Gatemen, Baggage Handlers, Service Attendants, Lead Service Attendants, Train Attendants, and Reservation Sales Agents (“Covered Employees”), on ADA requirements as Amtrak determined are applicable and appropriate to their respective job functions and work locations, including training on providing appropriate assistance to passengers with disabilities. Amtrak provided these ADA training materials to DOJ for its review, DOJ provided written feedback, and Amtrak made changes as appropriate. Prior to the Effective Date of this Agreement, Amtrak has commenced training for Covered Employees, and will prioritize Conductors and Assistant Conductors. Training may be live, or in the form of written, computer-based, or other reasonable means of training. Absent circumstances reasonably outside of Amtrak’s control, e.g., an extended leave of absence, all Covered Employees will be provided with such training within three years of commencement of training, and approximately every two years thereafter throughout the duration of this Agreement.

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21. Amtrak will provide ADA training to newly hired Covered Employees within 60 days of their start date as a Covered Employee in a relevant position absent circumstances reasonably outside of Amtrak’s control or, if the relevant training for the particular position is already scheduled to occur within 120 days of their start date, then by that date.
22. Amtrak will maintain records showing the dates and length of training, instructors, and attendees, including job titles.
23. For Covered Employees who do not receive training within the applicable timeframes (e.g., due to medical leave of absence, or other circumstances causing them to miss and/or be unable to attend the training), Amtrak will provide training to such persons within 60 days of their availability (for instance, from their full-time return from leave).
ADA Complaint Procedures
24. Amtrak’s Customer Relations Department and, as applicable, its Office of EEO Compliance (a/k/a the Office of HR Compliance), which handles civil rights issues, including ADA Complaints from passengers or potential passengers with disabilities, will identify, track, and respond to ADA Complaints made or referred to the Customer Relations Department or Office of EEO Compliance, as described below. An “ADA Complaint” is defined as an ADA-related complaint made by or on behalf of a passenger or potential passenger with a disability. Amtrak will not be in violation of this Agreement for any issues related to the handling or maintaining of an ADA Complaint unless the ADA Complaint alleges facts that, if true, would constitute a violation of the ADA. Within 30 days of the Effective Date of this Agreement, Amtrak will ensure its website provides contact information for submitting ADA Complaints and feedback (including a telephone number, mailing address, and an electronic mail address or electronic link). These complaint procedures apply only to complaints directed to Amtrak, and do not, for example, apply to complaints directed or brought to DOJ, DOT, FRA, or some other third party.

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25. Amtrak will continue to accept ADA Complaints. Amtrak’s Customer Relations Department or the Office of EEO Compliance, as applicable, will confirm receipt to the complainant of each ADA Complaint that is submitted through the assigned electronic mail address or electronic link through Amtrak.com as established pursuant to Paragraph 24 above within five business days, absent circumstances reasonably beyond the control of Amtrak. ADA Complaints received by Amtrak’s Customer Relations Department by letter with author address information provided will be acknowledged in writing within 30 business days from the first business day it was received, absent circumstances reasonably beyond Amtrak’s control. Amtrak’s Customer Relations Department will respond to ADA Complaints within 45 days after receiving the complaint, or will communicate to the complainant why more time is needed to respond. For ADA Complaints handled by the Office of EEO Compliance, that office will send the complainant a final written response within 45 days after receiving the complaint, or will communicate to the complainant why more time is needed to respond.
26. ADA Complaints received by the Customer Relations Department will be maintained in a format that tracks: (A) each ADA Complaint; (B) the response, resolution, or referral of the ADA Complaint to the Office of EEO Compliance; and (C) where provided by the Complainant: the name of the complainant, the date of the incident, the train or thruway bus number/route or reservation number, and the location (e.g., address or station). Amtrak will implement and maintain a document retention policy to retain this ADA Complaint information for the duration of this Agreement. This information shall be made available within a reasonable period of time to the Vice President of Stations, Properties & Accessibility (“VPA”) (see Paragraphs 29-31) or the VPA’s designee, as well as upon request to DOJ and FRA. For ADA Complaints handled by Amtrak’s Office of EEO Compliance, similar information (name, contact information, and a description or categorization of the complaint, resolution, and response) will be requested and, if provided, entered and maintained in the database utilized by that Office and similarly will be made available within a reasonable period of time to the VPA or the VPA’s designee, as well as upon request to DOJ and FRA.

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27. The VPA will periodically review the overall handling of ADA complaints by the Customer Relations Department and the Office of EEO Compliance to the extent the VPA believes sufficient, and identify complaint trends relevant to the ADA (see Paragraph 37).
28. As part of the standard onboarding process, Amtrak will train new customer-facing Customer Relations Department members to handle ADA Complaints in a manner that complies with this Agreement. Amtrak will also provide feedback, coaching, supervision, and/or discipline where it deems necessary because of a violation of Amtrak’s policy or procedures related to the handling of ADA Complaints.
Amtrak Office of the Vice President of Stations, Properties & Accessibility
29. For the duration of this Agreement, Amtrak will maintain its Office of the Vice President of Stations, Properties & Accessibility and a VPA to head this Office. Over the course of this Agreement, the VPA position could become vacant. In such a situation, Amtrak will in good faith work to fill the position. Should more than two weeks pass, one or more persons will be assigned to act in a temporary capacity over this Office until the VPA position is filled. This Office will be responsible for coordinating Amtrak’s efforts to comply with Title II of the ADA and this Agreement, including the passenger-related ADA efforts of Amtrak across all of its departments, with the authority to evaluate systemic ADA-trends and recommend systemic changes to remedy any ADA Complaint trends.
30. The VPA currently reports to Amtrak’s Executive Vice President, Strategy & Planning, and serves as a liaison and resource to senior Amtrak management on Title II of the ADA and this Agreement. Should the VPA reporting structure change in the future, Amtrak will select the appropriate Executive Vice President to whom the VPA will report, and will notify DOJ of the change within a reasonable time. The VPA will convene bi-monthly meetings of Amtrak’s ADA Executive Oversight Committee (or its equivalent), will invite Amtrak Vice Presidents and managers the VPA believes are

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necessary for the meeting and to comply with this Agreement, and will maintain minutes at all meetings, to be provided to DOJ and FRA, upon request.
31. The VPA will have general oversight responsibility for Amtrak’s work toward improved compliance with Title II of the ADA and compliance with this Agreement, including, for ADA projects, priorities, and issues, and, although not required by this Agreement, may also have responsibility for real estate matters. The VPA will provide to relevant Amtrak management overall direction for Amtrak’s compliance with Title II of the ADA, with the assistance of other relevant Amtrak personnel; propose funding levels and timeframes for the ADASP; recommend and approve recommendations of proposed projects to be funded in the ADASP Five Year Strategic Plan that will go to Amtrak’s ADA Executive Oversight Committee (or its equivalent); and recommend a target date for when Amtrak will complete the ADA stations remediation work set forth in the ADASP Sunset Analysis. The VPA (or, at Amtrak’s discretion, the President/CEO or an appropriate Executive Vice President) will provide regular status updates to Amtrak’s Board of Directors at least three times annually regarding Amtrak’s implementation of and compliance with this Agreement.
FRA and DOJ Monitoring
32. Upon advance written notice, Amtrak will provide FRA and DOJ reasonable access to relevant information that each does not already possess through Amtrak staff, facilities, and documents to assist them in evaluating Amtrak’s compliance with this Agreement. This reasonable access includes attendance by up to two designated DOJ representatives at meetings of Amtrak’s ADA Executive Oversight Committee (or its equivalent). The Parties and FRA will continue to reasonably cooperate with one another. FRA and DOJ will be permitted to make reasonable unannounced inspections and visits of Amtrak operations and facilities, to the extent such operations or facilities are open to the public (and the visit or inspection does not create a safety issue) during the course of implementing this Agreement, including reasonable, unannounced testing.

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33. FRA has regulatory oversight (to the extent permitted by law) over the relevant operations of Amtrak. This oversight responsibility means that FRA may, in its discretion:
A. Review Amtrak’s progress in making stations accessible, including thorough review of the documents provided by Amtrak and attending bi-monthly ADA Executive Oversight Committee (or its equivalent) meetings;
B. Review and accept Amtrak’s annual ADASP Five Year Strategic Plan and ADASP Sunset Analysis;
C. Review and accept station design documents and construction plans for each relevant facility alteration Amtrak undertakes or allows to be undertaken;
D. Visit Amtrak stations to determine whether Amtrak has made stations for which it is responsible readily accessible to and usable by individuals with disabilities in accordance with the DOT Standards and this Agreement;
E. Observe on-site Amtrak operations related to passengers with disabilities and make recommendations for Amtrak’s compliance with the ADA and this Agreement; and
F. Monitor, observe, or conduct inspections permitted by the terms of its grant with Amtrak or by law.
34. Amtrak currently uses qualified third-party contractors to conduct post-construction ADA assessments upon substantial completion for new or altered station facilities. For the duration of the Agreement, Amtrak will continue to conduct these post-construction ADA assessments, identify any issues that remain out of ADA compliance, and develop a plan to remediate any such issues. On an on-going basis, Amtrak will provide each completed post-construction ADA assessment to DOJ and FRA, and will provide to FRA information sufficient to describe Amtrak’s plans to remediate any issues that remain out of ADA compliance. Upon request by DOJ, Amtrak will provide a current

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list of approved third-party contractors who may conduct post-construction ADA assessments.
Thruway Bus Service
35. Any contract to provide all or part of Amtrak’s dedicated thruway bus service (fixed route) during this Agreement will include the language related to ADA compliance in a form substantially similar to that which was approved by DOJ on September 11, 2018, requiring each front-line bus to be equipped with a working wheelchair lift, to undergo regular pre-trip inspections, and to have its wheelchair lifts, securements, and restraint devices maintained. This provision does not preclude Amtrak from incorporating additional language or provisions into its bus contracts. In the event that this language is rejected by a vendor, DOJ will reasonably and in good faith work with Amtrak and potentially, but only at Amtrak’s request, the dedicated thruway bus service vendor to attempt to formulate acceptable language and find a reasonable alternative to the proposed language.
Document Maintenance and Reporting Requirements
36. Amtrak must maintain the following documents, to the extent they exist, for the duration of this Agreement:
37. Station-Specific Documents. For each station: (1) the ADA Assessment of the particular station’s relevant facilities; (2) final designs and plans for ADA compliance; (3) documents regarding ADA construction and remediation (including bids, proposals, awards, approved plans, revisions, change orders, and close-out documents); and (4) descriptions of how passengers with disabilities will be boarded and de-boarded.
38. Compliance with Agreement. Current reports showing Amtrak’s progress in making its stations accessible, including Amtrak’s: (1) schedule for performing remedial work under this Agreement; (2) ADASP Five Year Strategic Plans and ADASP Sunset Analysis; and (3) station accessibility priority lists.

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39. Complaints. All customer ADA Complaints logged in the complaint database (see Paragraph 26); and

40. Training. The information maintained by Amtrak related to its ADA Training (see Paragraphs 20-23).

A. Six months after the Effective Date of this Agreement, Amtrak will submit to DOJ the data and records identified in Paragraph 36 for the most recent six months and will provide a written report listing its progress implementing this Agreement as well as a summary from the VPA of any complaint trends relevant to Title II of the ADA and efforts made to address the trends (see Paragraph 27) (the “ADA Progress Report”). Thereafter, Amtrak will submit to DOJ the data and records identified in Paragraph 36, to the extent not previously provided, and the ADA Progress Report on a bi-annual basis. Amtrak will make the ADA Progress Reports available to the public.

B. Agreement, upon request by DOJ, Amtrak will meet once or twice a year with DOJ, at DOJ’s discretion, to discuss the progress of the ADASP and compliance with this Agreement, including, as needed, the status of on-going work under the ADASP, challenges to accomplishing that work, proposed design and construction activities (including scope, schedule, budget, and challenges), and any proposed ADA responsibility changes to Exhibit 2 or Exhibit 3.

Compensation Fund

39. Retention of Administrator. Within 28 days of the Effective Date of this Agreement,

Amtrak will obtain bids from qualified third-party settlement administrators and select

one Administrator, subject to the United States’ approval, to administer the settlement

and Qualified Settlement Fund (“Fund”). Amtrak will pay the Administrator up to

$127,500.00 flat rate5 (which is an amount separate from the claims monies paid into

the Fund). The Administrator will be required to comply with the provisions of this

Agreement applicable to the Administrator. The Administrator shall keep the Parties

reasonably informed via e-mail of steps taken in the administration of the Fund. The

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Administrator shall provide regular reporting during and after the Claims Period (see Paragraph 41) as follows: 1) a report approximately three weeks into the Claims Period; 2) reports bi-weekly until the Claims Period closes; 3) reports bi-weekly during the Claims Review period (see Paragraph 46); and 4) a final report on the number of claims paid. The Administrator will provide for individuals seeking to be compensated by the Fund (“Claimants”) a Fund-specific website, email, facsimile, and toll-free telephone number (and accompanying TTY text telephone number) to ensure that Claimants can contact the Administrator and submit their claims. The Administrator shall maintain the confidentiality of all non-public materials received in connection with its duties under the Agreement, except with the parties or unless reasonably necessary to be disclosed (i.e., for tax reporting purposes). The Administrator shall conduct follow-up as needed, as well as follow-up as agreed to by the Parties, to determine whether a Claimant is a qualified individual who meets the eligibility requirements and has appropriately and timely completed all the procedures for payment entitling them to compensation under the Agreement (“Eligible Person”), and calculate the amount of compensation for each Eligible Person based on the requirements in the Agreement.

40. Notice. Amtrak will publish a Notice of Americans with Disabilities Act Settlement (“Notice”), comprised of the text and images in Exhibit 4, as follows:

A. Amtrak will publish and maintain the Notice on its website in an accessible and conspicuous location for the duration of the Claims Period, described herein with the description “Americans with Disabilities Act Claims Fund.” Such posting shall be in HTML text and/or otherwise accessible to individuals with visual impairments.

B. Within 60 days of the Effective Date of this Agreement, and monthly for the duration of the Claims Period, Amtrak will tweet on its Twitter account (@Amtrak) and post on its Facebook page (http://www.facebook.com/amtrak) (with the International Symbol of Accessibility), the following text and a unique link (provided by the Administrator) to the Notice on its website: “We have reached an agreement with the U.S. Department of Justice @CivilRights to

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resolve station inaccessibility that impacts our passengers with disabilities. To learn more about this agreement, including the Compensation Fund for certain passengers with mobility impairments, visit: [unique link to Administrator’s settlement fund site]”.
C. Within 60 days of the Effective Date of this Agreement, Amtrak will place at least a ¼-page advertisements of the Notice in USA Today (Friday circulation; display) the text of which is attached as Exhibit 4. Amtrak will only publish Exhibit 4 one time.
41. Claims Period. The Claims Period for Claimants to timely file claims will be the 120day period from the posting of the Notice in USA Today (“Claims Period”). The Administrator will promptly notify a Claimant if there is an issue(s) with their claim that can be corrected, i.e., missing information or an unsigned form. Claimants may attempt to cure a claim at any time during the Claims Period as well for an additional 30-day period thereafter (the “Cure Period”) so long as the initial claim was timely filed during the Claims Period. The Administrator will respond to any inquiries from Claimants and will contact the Parties should there be an issue to which the Administrator cannot respond, e.g., because clarity is required by the Administrator from the Parties to accept or reject any claim. Amtrak has the right to instruct the Administrator to accept flawed and/or late claims.
42. Establishment of Compensation Fund. Within 21 business days after the closure of the Cure Period and calculation of all payments due, Amtrak will deposit with the Administrator a maximum of $2,250,000 for the Fund. The Administrator will have access to the Fund for the purpose of compensating Eligible Persons.
43. Eligible Persons. To be entitled to relief, a Claimant must meet the eligibility requirements and timely submit a Claim Form. Monetary relief will only be provided to Eligible Persons who have been determined by the Administrator, as set forth in this Agreement and as approved by the United States, to meet the following Eligibility Requirements: (1) the individual is mobility impaired; (2) the individual was harmed

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because of accessibility issues at the stations listed in Exhibit 5 (“Issue Stations”) between July 27, 2013 and the Effective Date of this Agreement; (3) the Administrator is satisfied that the individual lived at, visited, or desired to visit a place closer to the Issue Station(s) than an accessible, alternative Amtrak station within the applicable time period (based on the information collected in Paragraph 44); (4) the individual declares under penalty of perjury that the information they have provided in the Claim Forms and/or to the Administrator is true and correct (“Declaration”); and (5) the individual executes the release of claims required in Paragraph 45, as described in Exhibit 6. Any additional instructions to the Administrator regarding eligibility and Eligible Persons shall be agreed upon by the Parties.
44. Proof Necessary for Claims: Anyone who believes they qualify as an Eligible Person must submit a timely Claim Form and Declaration to the Administrator including the following information, to be incorporated into a Claim Form, which Form will include an assurance from the Claims Administrator that all collected information will be kept confidential:
A. Contact Information 1. Name 2. Mailing Address 3. Phone 4. E-mail (optional) 5. Preferred means of contact and any anticipated change in contact information with the approximate date of the contact information changing. 6. All tax information requested by and required for the Administrator to make payment and appropriately report to the taxing authority. B. Residency Information 1. Addresses you resided at during the time of your claim(s). C. Disability Information 1. Do you have a disability? 2. Please identify and describe the nature of your limitations and/or

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disability. It is not necessary to provide your medical diagnosis. 3. Do you use an assistive device (for example, a wheelchair, scooter, walker, etc.)? If so, please identify any assistive device(s) and when you use and/or have used each assistive device, if at all. D. Travel Information 1. Between July 27, 2013 and [the Effective Date of this Agreement], did you travel from or to an Amtrak Issue Station(s) and face difficulty using the facility due to a disability? a. Station you traveled from: b. Station you traveled to: c. Approximate dates you traveled: d. Documentation of travel (if available) or if not available, a brief written description of travel. e. Description of the difficulty you faced using the facility due to a disability. f. Documentation of the difficulty you faced using the facility due to a disability (if available, but not required). -- AND/OR -2. Between July 27, 2013 and [the Effective Date of this Agreement], did you desire to travel from or to an Amtrak Issue Station(s), but decided not to because of physical barriers to using the facility? Answer the following questions for each station pair: a. Station you would have traveled from: b. Station you would have traveled to: c. Approximate dates you would have traveled: d. Number of times you would have traveled between those two stations: e. Destination City or Area: f. Specific physical barrier(s) that prevented you from using the facility: g. Any documentation supporting your claim that you would have traveled to or from a listed Amtrak station(s) but decided not to because of physical barriers to using the facility (if available, but not required).

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E. Declaration 1. I, ____________________, declare under penalty of perjury that: a) I am 18 years or older and am either i) submitting this on my own behalf or ii) I am the guardian of a person with a disability (“Ward”) who is an Eligible Person, and b) that all of the information in this Claim Form is true and correct to the best of my knowledge. 2. Signature and Printed Name and, where applicable, the printed name of the Ward. 3. Date

45. Release Required. Each Claimant, as part of the Claim Form, will be required to sign a release of claims (“the Release”) against Amtrak for any issues addressed in this Agreement and any related claim for a violation of the ADA, and similar state or local laws. The Release will clearly state that it is not effective unless the Claimant is deemed an Eligible Person, and not unless the check is negotiated (i.e., cashed or deposited) by the Eligible Person, after which time the Administrator will provide the Claim Forms and Releases to the Parties.

46. Claims Review. Upon the expiration of the Claims Period, the Administrator shall finalize the determination regarding which Claimants are Eligible Persons with valid claims for compensation and calculate the amounts to be paid to those Eligible Persons (see Paragraph 47). No individual, other than the Parties, may request a review by the District Court in the underlying Civil Action (the “Court”) or the Administrator of these determinations.

47. Compensation Level Criteria. Compensation levels will be two tiers, one for Eligible Persons who lived closer to an Issue Station than another Amtrak station (“Tier 1 Claimants”) and one for Eligible Persons who traveled to or were deterred from travel to an Issue Station (“Tier 2 Claimants”). The compensation amount for Tier 1 Claimants will be triple that of Tier 2 Claimants, i.e., Tier 1 Claimants’ claims will be worth 3 points, and Tier 2 Claimants’ claims will be worth 1 point. In no event shall any Claimant be entitled to more than 3 points. Upon the expiration of the Claims Period

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and the completion of follow-up by the Administrator with outstanding Claimants, the Administrator will assign each Eligible Person either 1 or 3 points based on the Tier into which their claim falls. The Administrator will then total the number of points (“Total Points”) by adding the points assigned to all Eligible Persons. Next, the Administrator will determine the preliminary dollar amount per point (“Preliminary Point Value) by dividing the total dollar amount of the Fund ($2.25 million) by the number of Total Points. If the Preliminary Point Value does not exceed $833.33, then the Preliminary Point Value will be the Final Point Value. If the Preliminary Point Value exceeds $833.33, then the Final Point Value will be reduced to $833.33. The compensation amount to each Tier 1 Claimant will equal the final Point Value multiplied by three. The compensation amount to each Tier 2 Claimant will equal the Final Point Value. Amtrak will retain or have reverted to it the balance of the Fund for use in furtherance of the ADASP.

48. Notification of Payment. In its final report, the Administrator will include a list of the dates and amount of payments made to Eligible Persons. Eligible Persons who receive payment are responsible for any taxes due on the payment by them and will receive a Form 1099 from the Administrator for the payment made which shall be sent to the address provided by the Eligible Person where applicable.

49. Uncashed Checks. Checks will expire no sooner than 90 days from issuance. In the event that there remain uncashed checks after reasonable efforts by the Administrator to contact Eligible Persons (including, for example, skip-trace searches), the Administrator shall send those payments to the state as required by the law of that state. Should there be no such law, then the residual amount will be returned to Amtrak, for use in furtherance of the ADASP. In the event that the Eligible Person requests a new check from either Party or the Administrator within the one year period following the issuance of the initial check, a duplicate check will be provided so long as the check was not cashed, and the person states that the original check was lost and will be destroyed in the event it is found.

IV. IMPLEMENTATION AND ENFORCEMENT
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50. Within 14 days of Amtrak complying with the Notice requirements of Paragraph 40(C), the Parties shall jointly move the Court to dismiss the underlying Civil Action with prejudice, pursuant to Fed. R. Civ. P. 41(a)(2), subject to reinstatement as set forth in Paragraph 51. The joint motion will include this Agreement as an Exhibit.

51. If the United States believes that Amtrak has breached any provision of this

Agreement, then the United States may move to restore the Civil Action to the active

docket of this Court for the purposes of resolving any such claims of breach. If the

United States makes a claim of breach, Amtrak consents to and agrees not to contest the

United States’ motion to restore the present Civil Action to the Court’s active docket.

Alternatively, the United States may bring a civil action for breach of this Agreement or

any provision thereof, or for a violation of Title II of the ADA, in the United States

District Court for the District of Columbia, and may in such action seek to have the

Court impose any remedy authorized at law or equity. Before seeking Court

involvement, the United States will give written notice (including reasonable, detailed

particulars) to Amtrak of the alleged violations and the basis for the alleged violations

(the “Breach Notice”). 6 Amtrak must respond to this Breach Notice as soon as

practicable but no later than 30 days thereafter. The United States and Amtrak will

negotiate in good faith to resolve the allegations in a timely manner and will then (i)

agree on any necessary or required actions to be taken by Amtrak, and any reasonable

extension of time, (ii) agree that no additional actions are necessary or required by

Amtrak, or (iii) disagree on matters set forth in the Breach Notice. If the Parties

disagree or are unable to reach a mutually acceptable resolution within 60 days of

Amtrak’s response, the United States may seek court action as described above. During

the 60 days, the Parties will make good faith attempts to resolve the matter, including

through in- person meetings and/or with a neutral person/party. The Breach Notice must

be provided by certified mail to Amtrak’s Chief Legal Officer (by the then current name

of such person) and General Counsel (by the then current name of such person), One

Massachusetts Ave., N.W., Washington, DC 20001, with a copy sent by electronic and

certified mail to Anne Marie Estevez and Beth Joseph, Morgan, Lewis & Bockius LLP,

200 South Biscayne Boulevard, Suite 5300, Miami, FL 33131-2339.

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52. Amtrak will not be in violation of this Agreement where Amtrak’s delay to make a station facility accessible is due to a private entity’s failure to provide written consent or approval required for Amtrak to perform its compliance activities on the property (including a private freight company owner of a passenger platform’s refusal or delay in providing written consent for Amtrak to construct a passenger platform that allows for level-entry boarding where required by 49 C.F.R. § 37.42), as long as Amtrak notifies the private entity of its obligation to cooperate under 42 U.S.C. § 12162(e)(2)(C) and 49 C.F.R. § 37.57 and the private entity refuses, obstructs, or otherwise causes delays, and Amtrak subsequently notifies DOJ through its reporting obligations as set forth in this Agreement of the private entity’s refusal, obstruction, or delay in providing the needed written consent. DOJ may argue that the failure to receive reasonable cooperation required by 42 U.S.C. § 12162(e)(2)(C) shall not be a defense to a claim of discrimination under the ADA but also may agree that the obstruction, including obstruction that causes the safety of Amtrak employees to be at risk, may be a defense to compliance with this Agreement. Once the private entity cooperates, and subject to exceptions in this Agreement, then Amtrak must make that station facility accessible in accordance with the DOT Standards and this Agreement.

53. For the duration of this Agreement, the United States may also seek compensation in the future for individuals with disabilities aggrieved by non-compliance with this Agreement by restoring the present Civil Action to the Court’s active docket, consistent with Paragraph 51. The parties agree the Court should have jurisdiction to decide any related compensation claims brought by the United States, and any defenses by Amtrak to any such compensation claims.

54. Failure by either party to enforce any provision or deadline of this Agreement is not a waiver by either party to enforce any provision or deadline in this Agreement.

55. The Parties agree that, as of the Effective Date of this Agreement, litigation is not “reasonably foreseeable” concerning the matters described in Paragraph 1. To the extent that either Party previously implemented a litigation hold to preserve documents, electronically stored information (ESI), or things related to the matters described in

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Paragraph 1, the Party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either Party of any other obligations imposed by this Agreement.
56. This Agreement will remain in effect for three years from the Effective Date of this Agreement, except for the terms related to station accessibility (Paragraphs 8-19, 29-31, 34, 36 (A) and (B), and 38). The terms on station accessibility, to the extent that the Parties do not mutually agree to change them and/or the law changes such that the provision is not required, will remain in effect for 10 years from the Effective Date of this Agreement. However, this Agreement will terminate earlier, by consent of the Parties, if all existing stations for which Amtrak is responsible are made readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs, per the DOT Standards.
57. This Agreement, including Exhibits, constitutes the entire agreement between the Parties relating to the Civil Action and Department of Justice No. 204-16-128, and no other previous statement, promise, or agreement, either written or oral, made by either Party or agents of either Party, that is not contained in this written Agreement will be enforceable. This Agreement does not purport to remedy any other potential violations of the ADA or any other federal law not included in the Agreement and its attached and incorporated exhibits. This Agreement does not affect Amtrak’s continuing responsibility to comply with all applicable aspects of Title II of the ADA.
58. If any term of this Agreement is determined by any Court to be unenforceable, the other terms of this Agreement will remain in full force and effect.
59. Nothing in this Agreement will preclude the United States from filing a separate action under the ADA for any alleged violation not covered by this Agreement. Before filing a separate action under the ADA for any alleged violations not covered by this Agreement, the United States will give written notice (including reasonable, detailed particulars) to Amtrak of the alleged violations and the basis for the alleged violations (the “Violations Notice”). Amtrak must respond to the Violations Notice as soon as

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practicable but no later than 30 days thereafter. The United States and Amtrak will negotiate in good faith to resolve the allegations in a timely manner and will then (i) agree on any necessary or required actions to be taken by Amtrak, and any reasonable extension of time, (ii) agree that no additional actions are necessary or required by Amtrak, or (iii) disagree on matters set forth in the Violations Notice. If the Parties disagree or are unable to reach a mutually acceptable resolution within 60 days of Amtrak’s response and after making good faith attempts to resolve the matter, including through in person meetings and/or with a neutral person/party, the United States may seek court action. The Violations Notice must be provided by certified mail to Amtrak’s Chief Legal Officer (by the then current name of such person) and General Counsel (by the then current name of such person), One Massachusetts Ave., N.W., Washington, DC 20001 with a copy sent by electronic and certified mail to Anne Marie Estevez and Beth Joseph, Morgan, Lewis & Bockius LLP, 200 South Biscayne Boulevard, Suite 5300, Miami, FL 33131-2339.
60. In entering into this Agreement, the United States and Amtrak will bear their own costs, expenses, and attorneys’ fees in this matter, up to the date the case is restored to the Court’s active docket or any future case is filed related to this Agreement.
61. The Parties can amend this Agreement by mutual written consent, and any time limits for performance or other obligations imposed by this Agreement may be extended or abolished by the mutual written consent of the Parties.
62. The Parties agree that the United States District Court for the District of Columbia shall have jurisdiction and be a proper venue for disputes concerning this Agreement between the United Stated and Amtrak. Amtrak consents to venue and personal jurisdiction before the Court. This Agreement is intended to exclusively provide the ability to enforce this Agreement by Amtrak and the United States. It is not intended to provide any rights to any third party beneficiaries.
63. This Agreement may be executed in counterparts, each copy, email, or pdf of which will be considered an original and taken together constitute one agreement.

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64. The Effective Date of this Agreement is the date of the last signature below.

1 For purposes of this Agreement, “station” means a transportation facility, “located appurtenant to a right-of-way on which intercity… rail transportation is operated, where such portion is used by the general public and is related to the provision of such transportation,” including buildings (designated waiting areas, ticketing areas, restrooms, etc.), passenger platforms, and parking. 42 U.S.C. § 12161(6); 49 C.F.R. § 37.3.
2 Amtrak is not responsible for all facilities at all stations it serves in the United States. The entity responsible for accessibility compliance is designated in the ADA and its regulations. See 42 U.S.C. § 12161(5); 49 C.F.R. § 37.49 (responsible person). Amtrak is responsible for making some or all station facilities accessible at over 400 of the approximately 514 stations it serves. See Exhibit 3. The remaining station facilities are the responsibility of other public entities. 42 U.S.C. § 12161(5); 49 C.F.R. § 37.49. The Parties will update Exhibit 3 periodically throughout the duration of the Agreement. Amtrak will provide DOJ with any relevant changes approximately biannually and the Parties will agree on any corresponding changes to ADA responsibility for station facilities.
3 To the extent Amtrak has legal responsibility for ADA compliance at any of the following mega stations (or becomes legally responsible for them in the future), these stations are exempt from all remediation timelines set forth in this Agreement: New York Penn Station (NY); Washington Union Station (DC); Philadelphia 30th St. Station (PA); Chicago Union Station (IL); Los Angeles Union Station (CA); Boston South Station (MA); Sacramento Station (CA); Baltimore Penn Station (MD); Bakersfield (CA); Albany-Rensselaer Station (NY); Emeryville (CA); Providence Station (RI); Seattle King Street Station (WA); San Diego Downtown Station (CA).
4 “100% design” is the accepted term by Amtrak and FRA for the stage of design development where the design defines the full scope of ADA improvements required at
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a station. At 100% design, Amtrak develops a final construction cost estimate. FRA

and the host railroad (if required) perform an official review of the 100% design and

submit questions or requested changes to the 100% design to Amtrak. If necessary,

revisions to the 100% design are made as part of the Approval process.

5 Including this flat rate amount does not relieve Amtrak from its obligation to compensate Eligible Persons consistent with this Agreement through the Administrator.

6 The Parties acknowledge and agree that noncompliance with any agency guidance documents may not be asserted as a basis for establishing a violation of this Agreement or applicable law. However, nothing shall limit either Party to this Agreement from making arguments about its interpretation of Title II of the ADA and its implementing regulations, including interpretations previously articulated in agency guidance documents.

AGREED AND CONSENTED TO: FOR THE UNITED STATES DEPARTMENT OF JUSTICE:

MICHAEL R. SHERWIN Acting United States Attorney District of Columbia
DANIEL F. VAN HORN D.C. BAR # 924092 Chief, Civil Division
JOHN C. TRUONG D.C. BAR #465901 Assistant United States Attorney 555 4th Street, N.W. Washington, D.C. 20530 Tel: (202) 252-2524 John.Truong@usdoj.gov

ERIC S. DRIEBAND Assistant Attorney General Civil Rights Division
CYNTHIA M. McKNIGHT Deputy Assistant Attorney General Civil Rights Division
REBECCA B. BOND Chief KATHLEEN P. WOLFE Special Litigation Counsel KEVIN J. KIJEWSKI Deputy Chief Disability Rights Section Civil Rights Division

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/s/ DAVID W. KNIGHT FELICIA L. SADLER D.C. BAR #452011 Trial Attorneys Disability Rights Section Civil Rights Division U.S. Department of Justice 150 M Street, N.E. Washington, D.C. 20002 Tel: (202) 616-2110 David.Knight@usdoj.gov Felicia.Sadler@usdoj.gov
Dated: 12/2/20

FOR NATIONAL RAILROAD PASSENGER CORPORATION

/s/ DAVID HANDERA Vice President, Stations, Properties & Accessibility Amtrak 1 Massachusetts Ave. NW, Room 648 Washington, DC 20001 Tel: 202-906-2455 David.Handera@amtrak.com
Dated: 12/1/20
Exhibit 1 - Stations Originally Identified as Having Significant Known or Potential Accessibility Deficiencies

Code Station

State

GSC

Glenwood Springs

CO

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NRK Newark

DE

TCA

Toccoa

GA

CRF

Crawfordsville

IN

ABE Aberdeen

MD

HAZ

Hazlehurst

MS

PIC

Picayune

MS

ELK

Elko

NV

GAS Gastonia

NC

COT Coatesville

PA

LAB

Latrobe

PA

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MJY

Mount Joy

PA

PAO Paoli

PA

PAR

Parkesburg

PA

PHN Philadelphia - North

PA

TYR

Tyrone

PA

WLY Westerly

RI

MHL Marshall

TX

SND Sanderson

TX

ASD Ashland

VA

CLF

Clifton Forge

VA

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ALD

Alderson

WV

HFY

Harpers Ferry

WV

THN

Thurmond

WV

Exhibit 2 - Stations Where Amtrak is Installing Passenger Information Data Systems (“PIDS”)

Code Station

State

TCL

Tuscaloosa

AL

TUS

Tucson

AZ

SAC Sacramento

CA

OXN Oxnard

CA

DAV

Davis

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CA
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SNS

Salinas

CA

DEN Denver

CO

GSC Glenwood Springs

CO

LAJ

La Junta

CO

GJT

Grand Junction

CO

OSB Old Saybrook

CT

WAS Washington

DC

WIL

Wilmington

DE

SFA

Sanford

FL

JAX

Jacksonville

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FL
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WTH

Winter Haven

FL

TPA

Tampa

FL

MIA

Miami

FL

DLD Deland

FL

SAV

Savannah

GA

ATL

Atlanta

GA

BNL Bloomington-Normal

IL

CDL Carbondale

IL

CHI

Chicago

IL

GBB Galesburg

IL

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SPI

Springfield

IL

SOB South Bend

IN

RTE

RTE 128

MA

ABE Aberdeen

MD

BAL Baltimore

MD

NCR New Carrollton

MD

BTL

Battle Creek

MI

DET

Detroit

MI

ARB Ann Arbor

MI

KCY Kansas City

MO

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KWD Kirkwood

MO

WFH Whitefish

MO

JAN

Jackson

MS

GPK East Glacier Park

MT

SBY Shelby

MT

HAV

Havre

MT

FAY

Fayetteville

NC

RMT Rocky Mount

NC

WLN Wilson

NC

FAR

Fargo

ND

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MOT

Minot

ND

WTN Williston

ND

OMA Omaha

NE

ABQ Albuquerque

NM

NYP New York Penn Station

NY

ROC Rochester

NY

ALB Albany

NY

SDY Schenectady

NY

HUD Hudson

NY

RHI

Rhinecliff

NY

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SAR

Saratoga Springs

NY

BUF Buffalo-Depew

NY

UCA Utica

NY

KFS

Klamath Falls

OR

EUG Eugene

OR

SLM Salem

OR

ALY

Albany

OR

PDX Portland

OR

JST

Johnstown

PA

HAR Harrisburg

PA

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LNC

Lancaster

PA

PGH Pittsburgh

PA

PHL

Philadelphia

PA

PVD Providence

RI

KIN

Kingston

RI

FLO

Florence

SC

GRV Greenville

SC

CHS Charleston

SC

CLB Columbia

SC

MHL Marshall

TX

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HOS

Houston

TX

AUS Austin

TX

LVW Longview

TX

ELP

El Paso

TX

FTW Fort Worth

TX

LOR Lorton

VA

RVR Richmond Staples Mill Road

VA

ALX

Alexandria

VA

CVS Charlottesville

VA

FBG Fredericksburg

VA

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NPN

Newport News

VA

LYH

Lynchburg

VA

WBG Williamsburg

VA

SEA Seattle

WA

EVR Everett

WA

OLW Olympia/Lacey

WA

PSC Pasco

WA

BEL

Bellingham

WA

EDM Edmonds

WA

KEL

Kelso

WA

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HUN

Huntington

WV

PRC Prince

WV

Exhibit 3 - ADA Responsibility for Intercity Rail Station Element(s)

State Code Station

Station Structures

Platforms

Parking Facilities

AL

ATN

Anniston

Amtrak

AL

BHM Birmingham

Amtrak

Amtrak

AL

TCL

Tuscaloosa

Amtrak

Amtrak

Amtrak

AR

ARK

Arkadelphia

Amtrak

Amtrak

Amtrak

AR

HOP Hope

Amtrak

Amtrak

AR

LRK

Little Rock

AR

MVN

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Malvern

Amtrak

Amtrak

Amtrak

Amtrak

Amtrak

Amtrak

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AR

TXA

Texarkana

Amtrak

Amtrak

Amtrak

AR

WNR Walnut Ridge

Amtrak

Amtrak

AZ

BEN

Benson

Amtrak

Amtrak

AZ

FLG

Flagstaff

AZ

KNG Kingman

Amtrak

Amtrak

Amtrak

AZ

MRC Maricopa

Amtrak

Amtrak

Amtrak

AZ

TUS

Tucson

Amtrak

AZ

WLO Winslow

Amtrak

Amtrak

Amtrak

AZ

YUM Yuma

CA

ANA

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Anaheim

Amtrak

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CA

ACA

Antioch-Pittsburg

CA

ARN Auburn

Amtrak

Amtrak

Amtrak (partial1)

CA

BFD

Bakersfield

CA

BAR

Barstow

Amtrak

CA

BKY

Berkeley

Amtrak

CA

BUR Burbank (Airport)

CA

CML Camarillo

Amtrak shares responsibility2

CA

CPN Carpinteria

CA

CWT

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Chatsworth

Amtrak

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CA

CIC

Chico

Amtrak

CA

COX Colfax

Amtrak

Coliseum/

CA

OAC

Oakland Airport

TBD

CA

COC Corcoran

Amtrak

CA

DAV

Davis

Amtrak

CA

DUN Dunsmuir

Amtrak

Amtrak

Amtrak

CA

EMY Emeryville

Fairfield-

CA

FFV

Vacaville

CA

FMT

Fremont

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Amtrak shares

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responsibility

CA

FNO Fresno

Amtrak

CA

FUL

Fullerton

Amtrak

CA

GDL

Glendale

CA

GTA

Goleta

Amtrak

Amtrak

CA

GVB Grover Beach

Amtrak

Amtrak (partial)

CA

GUA Guadalupe

Amtrak

Amtrak

Amtrak

CA

HNF

Hanford

Amtrak

CA

HAY

Hayward

Amtrak

CA

IRV

Irvine

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LOD

Lodi

Amtrak

CA

LPS

Lompoc-Surf

Amtrak

Amtrak

Amtrak

CA

LAX

Los Angeles

CA

MDR Madera

CA

MTZ

Martinez

Amtrak

CA

MCD Merced

Amtrak

CA

MOD Modesto

Amtrak

CA

MPK Moorpark

CA

NDL

Needles

CA

OKJ

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Oakland (Jack London Square)

Amtrak Amtrak

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CA

OSD Oceanside

CA

ONA Ontario

Amtrak

CA

OXN Oxnard

Amtrak shares responsibility

CA

PSN

Palm Springs

Amtrak

CA

PRB

Paso Robles

Amtrak

CA

POS Pomona

Amtrak

CA

RDD Redding

Amtrak

Amtrak

Amtrak

CA

RIC

Richmond

Amtrak

Amtrak

CA

RIV

Riverside

https://www.ada.gov/amtrak_sa.html

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Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

RLN

Rocklin

Amtrak

CA

RSV

Roseville

Amtrak

Amtrak

Amtrak (partial)

CA

SAC

Sacramento

CA

SNS

Salinas

Amtrak

CA

SNB

San Bernardino

Amtrak (partial)

San Clemente

CA

SNP

Pier

San Diego -

CA

SAN

Downtown

Amtrak

Amtrak

San Diego - Old

CA

OLT

Town

CA
https://www.ada.gov/amtrak_sa.html

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SJC

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak
San Jose

San Juan

CA

SNC

Capistrano

Amtrak

CA

SLO

San Luis Obispo Amtrak

Amtrak

Amtrak

CA

SNA

Santa Ana

CA

SBA

Santa Barbara

Amtrak

Santa Clara

CA

GAC

(Great America)

Amtrak shares responsibility

Santa Clara

CA

SCC (University

Station)

CA

SIM

Simi Valley

CA

SOL

https://www.ada.gov/amtrak_sa.html

Solana Beach

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Stockton

CA

SKT

ACE Station

Amtrak

Stockton - San

CA

SKN

Joaquin St.

Amtrak

Station

Amtrak

Amtrak

CA

SUI

Suisun

Amtrak

CA

TRU

Truckee

Amtrak

CA

TRK

Turlock-Denair

Amtrak

Amtrak

Amtrak

CA

VNC Van Nuys

CA

VEC

Ventura

Amtrak

CA

VRV

Victorville

CA

WAC

https://www.ada.gov/amtrak_sa.html

Wasco

Amtrak

Amtrak

Amtrak

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CO

DEN Denver

CO

FMG Fort Morgan

Amtrak

Amtrak

Amtrak

Glenwood

CO

GSC

Springs

Amtrak

Amtrak

CO

GRA Granby

Amtrak

Amtrak

CO

GJT

Grand Junction

Amtrak

Amtrak

CO

LAJ

La Junta

Amtrak

Amtrak

Amtrak

CO

LMR Lamar

CO

TRI

Trinidad

Amtrak Amtrak

Amtrak

Winter

CO

WIP

Park/Fraser

https://www.ada.gov/amtrak_sa.html

Amtrak

Amtrak

Amtrak
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CO

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak
WPR Winter Park

CT

BER

Berlin

CT

BRP

Bridgeport

CT

HFD

Hartford

CT

MDN Meriden

CT

MYS Mystic

Amtrak

Amtrak

CT

NHV New Haven

CT

NLC

New London

Amtrak shares responsibility

Amtrak

CT

OSB Old Saybrook

Amtrak

Amtrak

CT

STM

https://www.ada.gov/amtrak_sa.html

Stamford

Amtrak
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CT

WFD Wallingford

Amtrak

Amtrak

CT

WND Windsor

Amtrak

Amtrak

Amtrak

CT

WNL Windsor Locks

Amtrak

Amtrak

DC

WAS Washington

Amtrak shares responsibility

Amtrak shares responsibility

Amtrak shares responsibility

DE

NRK Newark

Amtrak

DE

WILL Wilmington

Amtrak

Amtrak

FL

DFB

Deerfield Beach

FL

DLD

Deland

Amtrak

FL

DLB

Delray Beach

https://www.ada.gov/amtrak_sa.html

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FL

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

FTL

Fort Lauderdale

FL

HOL

Hollywood

FL

JAX

Jacksonville

Amtrak

Amtrak

Amtrak

FL

KIS

Kissimmee

FL

LAK

Lakeland

FL

MIA

Miami

Amtrak

Amtrak

Amtrak

FL

OKE Okeechobee

Amtrak

Amtrak

Amtrak

FL

ORL

Orlando

FL

PAK

Palatka

FL

SFA

https://www.ada.gov/amtrak_sa.html

Sanford (Auto Train)

Amtrak

Amtrak

Amtrak
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FL

SBG Sebring

Amtrak

Amtrak

Amtrak

FL

TPA

Tampa

Amtrak

Amtrak (partial)

West Palm

FL

WPB

Beach

FL

WTH Winter Haven

Amtrak

Amtrak

Amtrak

FL

WPK Winter Park

GA

ATL

Atlanta

Amtrak

Amtrak

Amtrak (partial)

GA

GNS Gainesville

Amtrak

Amtrak

Amtrak

GA

JSP

Jesup

GA

SAV

https://www.ada.gov/amtrak_sa.html

Savannah

Amtrak

Amtrak

Amtrak

Amtrak
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GA

TCA

Toccoa

Amtrak

IA

BRL

Burlington

Amtrak

IA

CRN Creston

Amtrak

Amtrak

Amtrak

IA

FMD Fort Madison

Amtrak

Amtrak

Amtrak

IA

MTP Mt. Pleasant

Amtrak

Amtrak

Amtrak

IA

OSC Osceola

Amtrak

IA

OTM Ottumwa

Amtrak

Amtrak

Amtrak

ID

SPT

Sandpoint

Amtrak

Amtrak

Amtrak

IL

ALN

Alton

IL

BNL

Bloomington-

https://www.ada.gov/amtrak_sa.html

Amtrak

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Normal

IL

CDL

Carbondale

Amtrak

Amtrak

Amtrak (partial)

IL

CRV Carlinville

IL

CEN Centralia

Amtrak

Amtrak

Champaign-

IL

CHM

Urbana

Amtrak

Chicago - Union

IL

CHI

Amtrak

Station

Amtrak

Amtrak

IL

DQN Du Quoin

Amtrak

IL

DWT Dwight

IL

EFG

Effingham

Amtrak

Amtrak

Amtrak

https://www.ada.gov/amtrak_sa.html

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IL

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

GBB Galesburg

Amtrak

IL

GLM Gilman

Amtrak

Amtrak

Amtrak

IL

GLN

Glenview

IL

HMW Homewood

Amtrak shares responsibility

Amtrak shares responsibility

IL

JOL

Joliet

IL

KKI

Kankakee

Amtrak

IL

KEE

Kewanee

Amtrak

IL

LAG

La Grange

Amtrak shares responsibility

Amtrak shares responsibility

Amtrak

IL

LCN

Lincoln

https://www.ada.gov/amtrak_sa.html

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IL

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

MAC Macomb

Amtrak

Amtrak

Amtrak

IL

MAT

Mattoon

Amtrak

IL

MDT Mendota

Amtrak

Amtrak

Amtrak

IL

NPV

Naperville

IL

PLO

Plano

Amtrak

IL

PON Pontiac

IL

PCT

Princeton

Amtrak

Amtrak

Amtrak

IL

QCY Quincy

Amtrak

IL

RTL

Rantoul

Amtrak

Amtrak

Amtrak

IL

SPI

Springfield

https://www.ada.gov/amtrak_sa.html

Amtrak

Amtrak

Amtrak
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IL

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

SMT Summit

Amtrak shares responsibility

IN

COI

Connersville

Amtrak

Amtrak

IN

CRF

Crawfordsville

Amtrak

Amtrak

Amtrak

IN

DYE

Dyer

Amtrak

Amtrak

Amtrak

IN

EKH

Elkhart

Amtrak

Hammond-

IN

HMI

Whiting

Amtrak

Amtrak

Amtrak

IN

IND

Indianapolis

IN

LAF

Lafayette

Amtrak

IN

MCI

Michigan City

Amtrak

https://www.ada.gov/amtrak_sa.html

Amtrak

Amtrak
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IN

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

REN Rensselaer

Amtrak

Amtrak

Amtrak

IN

SOB South Bend

Amtrak

IN

WTI

Waterloo

Amtrak

Amtrak (partial)

KS

DDG Dodge City

Amtrak

KS

GCK Garden City

Amtrak

KS

HUT

Hutchinson

Amtrak

Amtrak

Amtrak

KS

LRC

Lawrence

Amtrak

Amtrak

KS

NEW Newton

Amtrak

Amtrak

Amtrak (partial)

KS

TOP

Topeka

KY
https://www.ada.gov/amtrak_sa.html

Amtrak

Amtrak

Amtrak

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AKY

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak
Ashland

KY

FTN

Fulton

Amtrak

Amtrak

Amtrak

KY

MAY Maysville

Amtrak

Amtrak

Amtrak

South Shore-

KY

SPM South

Portsmouth

Amtrak

Amtrak

Amtrak

LA

HMD Hammond

Amtrak

Amtrak

Amtrak

LA

LFT

Lafayette

Amtrak

LA

LCH

Lake Charles

Amtrak

LA

NIB

New Iberia

Amtrak

Amtrak

LA

NOL

New Orleans

LA

SCH

https://www.ada.gov/amtrak_sa.html

Schriever

Amtrak

Amtrak

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LA

SDL

Slidell

Amtrak

Boston - Back

MA

BBY

Bay

Boston - North

MA

BON

Station

Boston - South

MA

BOS

Station

MA

FRA

Framingham

MA

GFD Greenfield

MA

HHL

Haverhill

MA

HLK

Holyoke, MA

MA

NHT

https://www.ada.gov/amtrak_sa.html

Northampton

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MA

PIT

Pittsfield

MA

RTE

Route 128

Amtrak

Amtrak

MA

SPG Springfield

Amtrak

Amtrak

MA

WOB Woburn

MA

WOR Worcester

MD

ABE

Aberdeen

Amtrak

Amtrak

Amtrak

Baltimore - Penn

MD

BAL

Amtrak

Station

Amtrak

BWI Thurgood

MD

BWI

Marshall Airport

Amtrak

MD

CUM Cumberland

Amtrak

https://www.ada.gov/amtrak_sa.html

Amtrak

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MD

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

NCR New Carrollton

Amtrak

Amtrak

MD

RKV

Rockville

Amtrak shares responsibility for two platforms

ME

BRK

Brunswick

ME

FRE

Freeport

Old Orchard

ME

ORB Beach

(Seasonal)

Amtrak

Amtrak

ME

POR Portland

ME

SAO Saco-Biddeford

ME

WEM Wells

https://www.ada.gov/amtrak_sa.html

TBD

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MI

ALI

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

Albion

Amtrak

Amtrak

(partial)

MI

ARB

Ann Arbor

Amtrak

Amtrak

MI

BAM Bangor

Amtrak

MI

BTL

Battle Creek

Amtrak

MI

DER Dearborn

MI

DET

Detroit

Amtrak

MI

DOA Dowagiac

Amtrak

MI

DRD Durand

Amtrak

MI

LNS

East Lansing

MI

FLN

https://www.ada.gov/amtrak_sa.html

Flint

Amtrak

Amtrak (partial)

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MI

GRR Grand Rapids

MI

HOM Holland

Amtrak

MI

JXN

Jackson

Amtrak

Amtrak

MI

KAL

Kalamazoo

MI

LPE

Lapeer

Amtrak

Amtrak (partial)

MI

NBU New Buffalo

Amtrak

MI

NLS

Niles

Amtrak

Amtrak

Amtrak

MI

PNT

Pontiac

MI

PTH

Port Huron

Amtrak

Amtrak

Amtrak

https://www.ada.gov/amtrak_sa.html

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MI

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

ROY Royal Oak

Amtrak

MI

SJM

St. Joseph

Amtrak

Amtrak

MI

TRM Troy

MN

DLK

Detroit Lakes

Amtrak

Amtrak

Amtrak

MN

RDW Red Wing

Amtrak

Amtrak

MN

SCD St. Cloud

Amtrak

Amtrak

Amtrak

St.

MN

MSP

Paul/Minneapolis

MN

SPL

Staples

Amtrak

Amtrak

Amtrak

MN

WIN

Winona

Amtrak

Amtrak

Amtrak

MO

ACD Arcadia

https://www.ada.gov/amtrak_sa.html

Amtrak

Amtrak
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MO

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

HEM Hermann

Amtrak

MO

IDP

Independence

Amtrak

Amtrak (partial)

MO

JEF

Jefferson City

Amtrak

MO

KCY

Kansas City

Amtrak

Amtrak

Amtrak

MO

KWD Kirkwood

Amtrak

MO

LAP

La Plata

Amtrak

Amtrak

Amtrak

MO

LEE

Lee’s Summit

Amtrak

Amtrak

MO

PBF

Poplar Bluff

Amtrak

Amtrak

Amtrak

MO

SED

Sedalia

MO

STL

https://www.ada.gov/amtrak_sa.html

St. Louis

Amtrak

Amtrak

Amtrak

Amtrak

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(partial)

MO

WAR Warrensburg

Amtrak

TBD

MO

WAH Washington

Amtrak

MS

BRH Brookhaven

MS

GWD Greenwood

Amtrak

Amtrak

Amtrak

MS

HBG Hattiesburg

Amtrak

MS

HAZ

Hazlehurst

Amtrak

MS

JAN

Jackson

Amtrak

MS

LAU

Laurel

Amtrak

MS

MKS Marks

Amtrak

https://www.ada.gov/amtrak_sa.html

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MS

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

MCB McComb

Amtrak

MS

MEI

Meridian

Amtrak

MS

PIC

Picayune

Amtrak

MS

YAZ

Yazoo City

Amtrak

Amtrak

Amtrak

Browning

MT

BRO

(Seasonal)

Amtrak

Amtrak

Amtrak

MT

CUT

Cut Bank

Amtrak

Amtrak

Amtrak

East Glacier

MT

GPK

Amtrak

Park (Seasonal)

Amtrak

Amtrak

MT

ESM Essex

Amtrak

MT

GGW Glasgow

MT

HAV

https://www.ada.gov/amtrak_sa.html

Havre

Amtrak

Amtrak

Amtrak

Amtrak

Amtrak

Amtrak

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MT

LIB

Libby

Amtrak

Amtrak

Amtrak

MT

MAL

Malta

Amtrak

Amtrak

Amtrak

MT

SBY

Shelby

Amtrak

Amtrak

Amtrak

MT

WGL West Glacier

Amtrak

Amtrak

MT

WFH Whitefish

Amtrak

Amtrak

Amtrak

MT

WPT Wolf Point

Amtrak

Amtrak

Amtrak

NC

BNC Burlington

NC

CYN Cary

NC

CLT

Charlotte

NC

DNC

https://www.ada.gov/amtrak_sa.html

Durham

Amtrak

Amtrak

Amtrak

Amtrak

Amtrak

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NC

FAY

Fayetteville

Amtrak

NC

GAS Gastonia

Amtrak

Amtrak

Amtrak

NC

GRO Greensboro

NC

HAM Hamlet

Amtrak

NC

HPT

High Point

NC

KAN

Kannapolis

NC

RGH Raleigh

NC

RMT Rocky Mount

Amtrak

NC

SAL

Salisbury

NC

SSM

https://www.ada.gov/amtrak_sa.html

Selma

Amtrak

Amtrak
Amtrak
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NC

SOP Southern Pines

NC

WLN Wilson

Amtrak

ND

DVL

Devils Lake

Amtrak

Amtrak

Amtrak

ND

FAR

Fargo

Amtrak

Amtrak

Amtrak

ND

GFK

Grand Forks

Amtrak

Amtrak

Amtrak

ND

MOT Minot

Amtrak

Amtrak

Amtrak

ND

RUG Rugby

Amtrak

Amtrak

Amtrak

ND

STN

Stanley

Amtrak

Amtrak

Amtrak

ND

WTN Williston

NE

HAS

https://www.ada.gov/amtrak_sa.html

Hastings

Amtrak

Amtrak

Amtrak

Amtrak

Amtrak

Amtrak
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NE

HLD

Holdrege

Amtrak (partial)

Amtrak

Amtrak (partial)

NE

LNK

Lincoln

NE

MCK McCook

Amtrak

Amtrak

Amtrak

NE

OMA Omaha

Amtrak

Amtrak

Amtrak

NH

CLA

Claremont

Amtrak

Amtrak

NH

DOV Dover

Amtrak

Amtrak

NH

DHM Durham

NH

EXR

Exeter

NJ

MET Metropark

NJ
https://www.ada.gov/amtrak_sa.html

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NBK

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak
New Brunswick

Newark - Penn

NJ

NWK

Station

Newark Liberty

NJ

EWR International

Airport

Princeton

NJ

PJC

Junction

NJ

TRE

Trenton

NM

ABQ Albuquerque

NM

DEM Deming

NM

GLP

Gallup

Amtrak

NM

LMY

Lamy

https://www.ada.gov/amtrak_sa.html

Amtrak

Amtrak
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NM

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

LSV

Las Vegas

Amtrak

NM

LDB

Lordsburg

Amtrak

NM

RAT

Raton

Amtrak

Amtrak

Amtrak

NV

ELK

Elko

Amtrak

Amtrak

Amtrak (partial)

NV

RNO Reno

NV

WNN Winnemucca

Amtrak

Amtrak

Amtrak

Albany-

NY

ALB

Rensselaer

NY

AMS Amsterdam

Amtrak

Amtrak

Amtrak

Buffalo -

NY

BFX

Exchange St.

https://www.ada.gov/amtrak_sa.html

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NY

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

BUF

Buffalo-Depew

Amtrak

NY

CRT

Croton Harmon

Fort Edward-

NY

FED

Glens Falls

Amtrak

Amtrak

NY

HUD Hudson

Amtrak

Amtrak

Amtrak (partial)

NY

NRO New Rochelle

New York - Penn

NY

NYP

Amtrak

Station

Amtrak

NY

NFL

Niagara Falls

NY

PLB

Plattsburgh

Amtrak

Amtrak

Amtrak

NY

POH Port Henry

https://www.ada.gov/amtrak_sa.html

Amtrak

Amtrak

Amtrak
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NY

PRK

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

Port Kent

Amtrak

Amtrak

Amtrak

(Seasonal)

NY

POU Poughkeepsie

NY

RHI

Rhinecliff

Amtrak

Amtrak

Amtrak

NY

ROC Rochester

Amtrak

Amtrak

Amtrak

NY

ROM Rome

Amtrak

NY

RSP

Rouses Point

Amtrak

Amtrak (partial)

Saratoga

NY

SAR

Springs

Amtrak

Amtrak

Amtrak

NY

SDY

Schenectady

Amtrak

Amtrak

Amtrak (partial)

NY

SYR

Syracuse

https://www.ada.gov/amtrak_sa.html

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NY

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

FTC

Ticonderoga

Amtrak

Amtrak

Amtrak

NY

UCA Utica

Amtrak

NY

WSP Westport

Amtrak

Amtrak (partial)

NY

WHL Whitehall

Amtrak

Amtrak

Amtrak

NY

YNY

Yonkers

OH

ALC

Alliance

Amtrak

Amtrak

Amtrak

OH

BYN

Bryan

Amtrak

Amtrak

OH

CIN

Cincinnati

Amtrak

OH

CLE

Cleveland

OH

ELY

https://www.ada.gov/amtrak_sa.html

Elyria

Amtrak

Amtrak

Amtrak

Amtrak
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OH

SKY

Sandusky

Amtrak

OH

TOL

Toledo

OK

ADM Ardmore

Amtrak

OK

NOR Norman

Amtrak

OK

OKC Oklahoma City

Amtrak

OK

PVL

Pauls Valley

Amtrak

OK

PUR Purcell

Amtrak

Amtrak

Amtrak (partial)

OR

ALY

Albany

Amtrak

OR

CMO Chemult

Amtrak

Amtrak

Amtrak

https://www.ada.gov/amtrak_sa.html

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OR

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

EUG Eugene

Amtrak

OR

KFS

Klamath Falls

Amtrak

Amtrak

Amtrak

OR

ORC Oregon City

Amtrak

OR

PDX

Portland

OR

SLM

Salem

Amtrak

PA

ALT

Altoona

Amtrak

PA

ARD Ardmore

Amtrak

Amtrak

Amtrak

PA

COT Coatesville

Amtrak

Amtrak

Amtrak

PA

COV Connellsville

Amtrak

Amtrak

Amtrak

Cornwells

PA

CWH

Heights

https://www.ada.gov/amtrak_sa.html

Amtrak

Amtrak

Amtrak (partial)
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PA

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

DOW Downingtown

Amtrak

Amtrak

Amtrak

PA

ELT

Elizabethtown

Amtrak

Amtrak

Amtrak

PA

ERI

Erie

Amtrak

Amtrak

Amtrak

PA

EXT

Exton

Amtrak

Amtrak

Amtrak

PA

GNB Greensburg

Amtrak

Amtrak

Amtrak (partial)

PA

HAR Harrisburg

Amtrak

Amtrak

Amtrak

PA

HGD Huntingdon

Amtrak

Amtrak

Amtrak

PA

JST

Johnstown

Amtrak

Amtrak

Amtrak

PA

LNC

Lancaster

PA

LAB

https://www.ada.gov/amtrak_sa.html

Latrobe

Amtrak

Amtrak

Amtrak

Amtrak

Amtrak

Amtrak

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PA

LEW Lewistown

Amtrak

Amtrak

Amtrak

PA

MID

Middletown

Amtrak

Amtrak

Amtrak

PA

MJY

Mount Joy

Amtrak

PA

PAO

Paoli

Amtrak

Amtrak

Amtrak (partial)

PA

PAR

Parkesburg

Amtrak

Amtrak

Amtrak

Philadelphia -

PA

PHL

30th Street

Station

Amtrak

Amtrak

Amtrak

Philadelphia -

PA

PHN

North

Amtrak

Amtrak

Amtrak

PA

PGH Pittsburgh

Amtrak

Amtrak

Amtrak

https://www.ada.gov/amtrak_sa.html

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PA

TYR

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

Tyrone

Amtrak

Amtrak

RI

KIN

Kingston

Amtrak

RI

PVD

Providence

Amtrak

Amtrak

RI

WLY Westerly

Amtrak

SC

CAM Camden

Amtrak

Amtrak

Amtrak

SC

CHS Charleston

Amtrak

SC

CSN Clemson

Amtrak

SC

CLB

Columbia

Amtrak

SC

DNK Denmark

Amtrak

SC

DIL

Dillon

Amtrak

Amtrak

Amtrak

https://www.ada.gov/amtrak_sa.html

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SC

FLO

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

Florence

Amtrak

Amtrak

Amtrak

SC

GRV Greenville

Amtrak

Amtrak

Amtrak

SC

KTR

Kingstree

Amtrak

SC

SPB

Spartanburg

SC

YEM Yemassee

Amtrak

TN

MEM Memphis

Newbern-

TN

NBM

Dyersburg

Amtrak

TX

ALP

Alpine

Amtrak

Amtrak

Amtrak

TX

AUS

Austin

Amtrak

Amtrak

Amtrak

TX

BMT Beaumont

https://www.ada.gov/amtrak_sa.html

Amtrak

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TX

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CBR Cleburne

Amtrak

TX

DAL

Dallas

TX

DRT

Del Rio

Amtrak

TX

ELP

El Paso

Amtrak

Amtrak (partial)

TX

FTW Fort Worth

TX

GLE

Gainesville

Amtrak

TX

HOS Houston

Amtrak

Amtrak

Amtrak

TX

LVW Longview

Amtrak

Amtrak

TX

MHL Marshall

TX

MCG

https://www.ada.gov/amtrak_sa.html

McGregor

Amtrak

Amtrak

Amtrak

Amtrak

Amtrak

Amtrak

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TX

MIN

Mineola

Amtrak

TX

SAS

San Antonio

TX

SMC San Marcos

TX

SND Sanderson

Amtrak

Amtrak

TX

TAY

Taylor

Amtrak

Amtrak

TX

TPL

Temple

Amtrak

UT

GRI

Green River

Amtrak

Amtrak

Amtrak

UT

HER Helper

Amtrak

Amtrak

Amtrak

UT

PRO Provo

Amtrak

Amtrak

UT

SLC

https://www.ada.gov/amtrak_sa.html

Salt Lake City

Amtrak
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shares responsibility

VA

ALX

Alexandria

Amtrak shares responsibility

VA

ASD

Ashland

Amtrak

VA

BCV

Burke Centre

VA

CVS

Charlottesville

Amtrak

Amtrak

VA

CLF

Clifton Forge

Amtrak

Amtrak

Amtrak

VA

CLP

Culpeper

Amtrak

VA

DAN Danville

VA

FBG

Fredericksburg

https://www.ada.gov/amtrak_sa.html

Amtrak shares responsibility

Amtrak shares responsibility

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Lorton (Auto

VA

LOR

Train)

Amtrak

Amtrak

Amtrak

VA

LYH

Lynchburg

Amtrak

VA

MSS Manassas

Amtrak shares responsibility

Amtrak (partial)

VA

NPN Newport News

Amtrak

Amtrak

Amtrak (partial)

VA

NFK

Norfolk

Amtrak

VA

PTB

Petersburg

Amtrak

Amtrak

Amtrak

VA

QAN Quantico

VA

RNK

https://www.ada.gov/amtrak_sa.html

Roanoke

Amtrak shares responsibility

Amtrak shares responsibility

Amtrak

Amtrak

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Richmond - Main

VA

RVM

St.

Richmond -

VA

RVR

Amtrak

Staples Mill Rd.

Amtrak

Amtrak

VA

STA

Staunton

Amtrak

Amtrak

Amtrak

VA

WBG Williamsburg

Amtrak

VA

WDB Woodbridge

Amtrak shares responsibility

VT

BLF

Bellows Falls

Amtrak

VT

BRA

Brattleboro

Amtrak

VT

CNV Castleton

VT
https://www.ada.gov/amtrak_sa.html

Amtrak

Amtrak

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ESX

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Essex Junction

Amtrak

Amtrak

Amtrak

VT

MPR Montpelier

Amtrak

Amtrak

Amtrak

VT

RPH Randolph

Amtrak

Amtrak

Amtrak

VT

RUD Rutland

VT

SAB

St. Albans

Amtrak

Amtrak

Amtrak

VT

WAB Waterbury

Amtrak

Amtrak

Amtrak

VT

WRJ White River Jct.

VT

WNM Windsor

Amtrak

WA

BEL

Bellingham

Bingen-White

WA

BNG

Salmon

https://www.ada.gov/amtrak_sa.html

Amtrak

Amtrak

Amtrak
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WA

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

CTL

Centralia

Amtrak

WA

EDM Edmonds

Amtrak shares responsibility

Amtrak

WA

EPH

Ephrata

Amtrak

WA

EVR

Everett

Amtrak shares responsibility

WA

KEL

Kelso-Longview

Amtrak

Amtrak

WA

LWA

Leavenworth

WA

MVW Mount Vernon

Amtrak

WA

OLW Olympia/Lacey

WA

PSC

https://www.ada.gov/amtrak_sa.html

Pasco

Amtrak Amtrak

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Seattle - King

WA

SEA

Street Station

Amtrak

WA

SPK

Spokane

WA

STW Stanwood

Amtrak

WA

TAC

Tacoma

Amtrak

Amtrak

Amtrak

WA

TUK

Tukwila

Amtrak shares responsibility

WA

VAN

Vancouver

Amtrak

Amtrak

WA

WEN Wenatchee

Amtrak

Amtrak

WA

WIH

Wishram

WI

CBS

https://www.ada.gov/amtrak_sa.html

Columbus

Amtrak

Amtrak

Amtrak

Amtrak

Amtrak
Amtrak
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WI

LSE

La Crosse

Amtrak

Amtrak

Amtrak

WI

MKE Milwaukee

Milwaukee -

WI

MKA General Mitchell

Intl. Airport

WI

POG Portage

Amtrak

Amtrak

Amtrak

WI

SVT

Sturtevant

Amtrak

WI

TOH Tomah

Amtrak

Amtrak

Amtrak

WI

WDL Wisconsin Dells

Amtrak

Amtrak

WV

ALD

Alderson

Amtrak

WV

CHW Charleston

https://www.ada.gov/amtrak_sa.html

Amtrak

Amtrak

Amtrak
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WV

HFY

Settlement Agreement between the United States and National Passenger Railroad Corporation - Amtrak

Harpers Ferry

Amtrak

Amtrak

Amtrak

shares

shares

shares

responsibility responsibility

responsibility

WV

HIN

Hinton

Amtrak

Amtrak

WV

HUN Huntington

Amtrak

Amtrak

Amtrak

WV

MRB Martinsburg

Amtrak (partial)

WV

MNG Montgomery

Amtrak

Amtrak

WV

PRC Prince

Amtrak

Amtrak

Amtrak

WV

THN

Thurmond

Amtrak

Amtrak

White Sulphur

WV

WSS

Springs

Amtrak

Amtrak

Amtrak

1 “Partial” is used to indicate instances where multiple platform or parking facilities exist and Amtrak does not have responsibility for all of them, or where Amtrak occupies
https://www.ada.gov/amtrak_sa.html

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just part of a larger station structure.

2 “Shared” responsibility is noted where Amtrak and commuter rail service both have responsibility for a rail station element.

Exhibit 4 - Notice of Amtrak Claims Fund Under the ADA
Amtrak has entered into a Settlement Agreement with the U.S. Department of Justice to resolve a lawsuit brought under the Americans with Disabilities Act (“ADA”). The Settlement Agreement resolves alleged violations of the ADA.
If you were harmed by Amtrak’s lack of accessible transportation services between July 27, 2013, and [insert Effective Date of the Settlement Agreement] you may be eligible to receive payment from a compensation fund established by Amtrak. To be eligible for consideration for possible payment, you must submit a claim by [insert date]. You may obtain information on how to submit a claim in several ways: (1) by sending an email with your name, address, and telephone number to [insert email address to be designated by Fund Administrator], or (2) by calling the Fund Administrator at [insert toll free voice and TTY telephone numbers to be designated by Settlement Administrator].
A copy of the Settlement Agreement between the U.S. Department of Justice and Amtrak is available at [website]. For further information about the ADA, visit www.ada.gov or call the Department of Justice’s toll-free ADA Information Line at 1-800-514-0301 (voice) or 1-800-5140383 (TTY).
Exhibit 5 - Issue Stations

Code Station

State

https://www.ada.gov/amtrak_sa.html

ABE Aberdeen

MD

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ALP

Alpine

TX

ASD Ashland

VA

Bingen-White

BNG

WA

Salmon

BRL Burlington

IA

CNV Castleton

VT

CEN Centralia

IL

CHW Charleston

WV

CLF

Clifton Forge

VA

COT Coatesville

PA

CBS

Columbus

WI

https://www.ada.gov/amtrak_sa.html

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COI

Connersville

IN

CRF Crawfordsville

IN

CRN Creston

IA

CUM Cumberland

MD

CUT Cut Bank

MT

DLK Detroit Lakes

MN

DVL

Devils Lake

ND

DIL

Dillon

SC

DOW Downingtown

PA

GPK

East Glacier Park

MT

https://www.ada.gov/amtrak_sa.html

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EFG Effingham

IL

EKH Elkhart

IN

ELK

Elko

NV

FMG Fort Morgan

CO

GNS Gainesville

GA

GLM Gilman

IL

GSC Glenwood Springs

CO

GRA Granby

CO

HMI

Hammond-Whiting

IN

https://www.ada.gov/amtrak_sa.html

HFY

Harpers Ferry

WV

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HER Helper

UT

HIN

Hinton

WV

HLD Holdrege

NE

HMW Homewood

IL

HUD Hudson

NY

JSP

Jesup

GA

JST

Johnstown

PA

KEL

Kelso-Longview

WA

KWD Kirkwood

MO

https://www.ada.gov/amtrak_sa.html

LAP

La Plata

MO

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LCH Lake Charles

LA

LEW Lewistown

PA

MAL Malta

MT

MHL Marshall

TX

MAT Mattoon

IL

MAY Maysville

KY

MCG McGregor

TX

MPR Montpelier

VT

MTP Mount Pleasant

IA

NRK

Newark

DE

https://www.ada.gov/amtrak_sa.html

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NEW Newton

KS

NSL

Niles

MI

OSB Old Saybrook

CT

PAR

Parkesburg

PA

PTB

Petersburg

VA

PIC

Picayune

MS

PLO Plano

IL

PLB

Plattsburgh

NY

PBF

Poplar Bluff

MO

POH Port Henry

NY

https://www.ada.gov/amtrak_sa.html

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PCT

Princeton

IL

RTL

Rantoul

IL

Richmond Staples

RVR

VA

Mill Road

South Shore-South

SPM

KY

Portsmouth

SCD St. Cloud

MN

SPL

Staples

MN

SMT Summit

IL

TCA Toccoa

GA

TOH Tomah

WI

https://www.ada.gov/amtrak_sa.html

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TOP

Topeka

KS

TCL

Tuscaloosa

AL

WTI

Waterloo

IN

WLY Westerly

RI

WND Windsor

CT

WNL Windsor Locks

CT

WIH

Wishram

WA

YUM Yuma

AZ

Exhibit 6 - Individual Release of Claims

If I, __________________________, am found to be an Eligible Person who participates in the Compensation Fund, by timely submitting a Claims Form that is approved by the Administrator and negotiating (e.g., cashing or depositing) a settlement check, then I agree to fully release and forever discharge the National Passenger Railroad Corporation (“Amtrak”) from any and all liability for any claim, legal or equitable, that may exist or have accrued as of the date I sign this Individual Release

https://www.ada.gov/amtrak_sa.html

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of Claims, including any claims under Title II and Title III of the Americans with Disabilities Act,

any state or local law, or any regulation, standard, or guideline promulgated under any such law, I

may have against Amtrak arising out of the facts identified in the United States’ Complaint, filed in

the United States District Court for the District of Columbia, No. XX-cv-XXXX (D.D.C.), including

all claims, known or unknown, relating to Amtrak’s failure to make existing stations in its intercity

rail system readily accessible to and usable by individual with disabilities by no later than July 26,

2010.

UNKNOWN CLAIMS/CALIFORNIA CIVIL CODE SECTION 1542: To ensure a full and complete release and discharge of the claims described above, each Person who submits a Claims Form confirms that he or she has been advised to consult with legal counsel, is familiar with, and expressly waives any and all rights conferred by California Civil Code Section 1542, or by other statute or common law principles of similar effect, which provides: “A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party.”

ADA Enforcement Page | ADA Home Page

https://www.ada.gov/amtrak_sa.html

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