## COMMUNICATIONS	SUB **- COMMITTEE**  **DRAFT SUMMARY**  **REPORT FEBRUARY	24,	2015**  **Preface** I	would	like	to	thank	all	of	the	members	of	this	committee,	the	Access	Board staff,		and	those	from	the	general	public	who	have	come	together	in	open dialogue	to	help	one another	better	understand	each	and	every	perspective	in relation	to	the	dissemination	of	information	through	the	nation’s	rail networks. 

## Principles These	guiding	principles	have	been	used	in	our	work. They	can	help	build	a more	inclusive	environment. 1. Information	being	conveyed	to	passengers	must	be	made	available	to	all passengers	regardless	of	disability. Whenever	feasible,	visual,	tactile, induction	loop,	described	video,	electronic	software,	and	other universally	accessible	means	should	be	used	so as	to	provide	maximum inclusion	of	all	people. 2. Audible	announcements	must	also	be	made	available	visually	and	via induction	loops. 3. Visual	announcements	(Variable	Message	Signs -VMS)	must	also	be made	available	audibly	and	via	induction	loop. If	the	technology provides	for	high	definition	video,	audio	description	and	ALS	should also	be	incorporated. 4. Pre - recorded	or	automated	announcements	are	recommended	over human	announcements. 

## Signage	Types **– Proposed	Requirements:**  **A. Directional	Signs**  (includes	directional	Exit	Signs )
– Visual**B. Designation	Signs	for	Spaces**  (includes	Exit	Signs)
– Tactile	&	Visual,

and	The	ISA	shall	be	provided	at	required	wheelchair	spaces	and priority	seating	and	be	located	________. **C. Designation	Signs	for	Elements** 
– Not	Required	to	meet	accessibility requirements. **D. Non**  **- Emergency	Informational	Signs** 
– Visual	and	Meet	the	size requirement	for	visual	characters	where	possible	(practicable). **E. Non**  **- Emergency	Operational	Signs** 
– Tactile	&	Visual,	and	Meet	the size	requirement	for	visual	characte rs	where	practicable.	Furthermore, where	instructions	for	door	latch/locks	are	provided	they	shall	be	both visual	and	tactile	and	be	located	_______. Where	a	pictogram	is	provided for	these	instructions	a	tactile	description	shall	be	provided	directly adj acent	to	it. **F. Emergency	Informational	Signs**  **–** Visual	&	Tactile **G. Emergency	Operational	Signs**  **-** Visual **H. Caution	and	Safety	Signs**  (includes	icons	and	logos) - Visual **I. Stop	Identification	Signs**  (includes	train	designation,	route,	and	final destination)
– VMS,	. All	cars	must	provide	variable	message	signs	in two	locations	so	that	at	least	one	sign	is	readable	from	every	part	of	the car.	The	variable	message	signs	must	provide	equal	information	as	what is	provided	aurally.	If	stops	are	announced,	the	signs	should announce stops,	if	emergencies	are	announced;	the	signs	should	announce emergencies,	and	so	forth.	Where	cars	provide	route	map	tracking	signs in	two	locations	so	that	at	least	one	sign	is	audible	and	visible	from every	part	of	the	car. **J. Menus	and	Director** **ies**
– At	least	one	menu/directory	must	comply **K. Employee	Only	Signs** 
– Not	Required	to	meet	accessibility requirements. 

## Additional	Notes:

 Assistive	listening - provide	assistive	listening	(induction	loops) throughout	the	train	in	bathrooms,	meal	cars,	bed rooms	and	in	bi level	rail	cars - [Subcommittee	has	agreed	to	this
– would	make caveat	that	it	is	to	be	provided	where	audible	announcements	are intended	to	be	heard]

###  Evaluate	technical	feasibility	of	induction	loops	on	rail	cars -

Subcommitte e	already thinks	it	is	feasible.  VMS must	include	audible	versions  Stop	announcements,	and	other	audible	announcements	should	be	pre recorded,	high	quality	messages.  Human	announcements	should	be	kept	to	a	minimum. This	is	especially important	with	station	stop	announcements.  Service	animal	relief	area	information	should	be	made	available	on	the inside wall	nearest	wherever	ISA	is	placed.  All	cars	must	provide	variable	message	signs	in	two	locations	so	that	at least	one	sign	is	readable	from	every	part	of	the	car.	The	variable message	signs	must	provide	equal	information	as	what	is	provided aurally.	If	stops	are	announced,	the	signs	should	announce	stops,	if emergencies	are	announced;	the	signs	should	announce	emergencies, and	so	forth.2.	Where	cars	provide	route map	tracking	signs	in	two locations	so	that	at	least	one	sign	is	audible	and	visible	from	every	part of	the	car.  Meet	the	size	requirement	for	visual	characters	where	practicable.  Where	instructions	for	door	latch/locks	are	provided	they	shall	be	both vis ual	and	tactile	and	be	located	10	inches	of	the	latch/lock. o Where	a	pictogram	is	provided	for	these	instructions	a	tactile description	shall	be	provided	directly	adjacent	to	it.  The	ISA	shall	be	provided	at	required	wheelchair	spaces	and	priority seati ng.  At	least	one	menu	or	directory	shall	comply	with	accessibility	standards.  

### Examine	what	factors	should	be	used	to	determine	equivalency	of audible	and	visible	messages.		Oral	announcements	need	to	have the	same	level	of	clarity	as	visual	announcements. This	is	why	pre recorded	announcements	are	generally	better.  

### [make	recommendation	to	the	Board	to	do	research	on	speech intelligibility	and	rail	car	acoustics  Variable	message	signs	legibility	(e.g.,	font,	case,	style,	and	location)

- [reference	the	ANSI A117.1	technical	requirements	for	VMS Displays]		A  Emergency	Notification	Announcements	must	be	available	via Back- up	power

###  Visual	emergency	alerts	(flashing	fire	alarms	and	such)	in	all	parts

of	the	rail	cars -- compartments,	main	area,	restrooms,	etc. recommend	NFPA	72	requirements	with	the	use	of	VMS;	what	db level	is	in	NFPA	72.		Is	it	too	loud?	alarms	can	cause	disorientation and	additional	dangers	to	people	who	are	blind	or	have	cognitive disabilities.  

## Lighting - Recommend	the	Board	do	research	o n	lighting	as	there is	no	requirements	in	the	Standard	for	general	or	task	lighting other	than	in	elevators	and	at	bus	entry	points. o Lighting	in	circulation	areas,	restrooms,	sleeping	compartments, step	wells,	and	in	any	other	areas.		Step	wells	in	particular	raise issues:	1.	Because	they	may	or	may	not	be	level	platforms;	2.		It may	or	may	not	be	a	paved	surface	one	is	stepping	down	on	to; 3.		Distance	to	platform	varies;	and	gaps	may	be	difficult especially	at	night. o Task	lighting	and	on - demand	passenger controls  New	Technologies
– Examine	the	potential	for	providing	messages on	hand - held	devices	such	as	smartphones
– tri - mode communication

## Draft	Report	with	annotated	comments

**Principles** These	guiding	principles	have	been	used	in	our	work. They	can help	build	a more	inclusive	environment. 1. Information	being	conveyed	to	passengers	must	be	made	available	to	all passengers	regardless	of	disability. Whenever	feasible,	visual,	tactile, induction	loop,	described	video,	electronic	software,	and	other universally	accessible	means	should	be	used	so	as	to	provide	maximum inclusion	of	all	people. 2. Audible	announcements	must	also	be	made	available	visually	and	via induction	loops. [F.	Maldari: Audible	announcements	must	also	be	made	available	visually	and via	in duction	loops to	the	extent	practical . ] 3. Visual	announcements	(Variable	Message	Signs -VMS)	must	also	be made	available	audibly	and	via	induction	loop. If	the	technology provides	for	high	definition	video,	audio	description	and	ALS	should also	be	incorporated. [F.	Maldari: Visual	announcements	(Variable	Message	Signs -VMS)	must	also be	made	available	audibly	and	via	induction	loop to	the	extent	practical . ] 4. Pre - recorded	or	automated	announcements	are	recommended	over human	announcements. [L . Hamlin: 2. Audible announcements must also be made available visually and via delivered	to	a	hearing induction	loop system . 3. Visual announcements (Variable Message Signs -VMS) must also be made available audibly and via a hearing induction loop system . I f the technology provides for high definition video, audio description and ALS the hearing induction loop system should also be incorporated. NAD specifically asked to include	ALS	if	high	definition	is	available. 4. Pre - recorded or automated announcements should be provided whenever possible and appropriate, so long as the recording or automated announcement is high quality so the sound is clear and clean, and are preferable to live announcements . .are recommended over human announcements. ] [A. Philips: 1. Information being conveyed to passengers must be made available to all passengers regardless of disability. Whenever feasibleExcepting extreme situations resulting in undue burdens, such information

should be conveyed through all means including but not l imited to: , visual, tactile, induction loop, described video, electronic software, and other universally accessible means should be used so as to provide maximum inclusion	of	all	people. 2. Audible announcements must also be made available visually and via induction	loops. 3. Visual announcements through (Variable Message Signs - (VMS) must also be made available audibly and via induction loop. I f the technology provides for high definition video, audio description and Assistive Listening Systems (ALS) should also be incorporated. Moreover, if high definition video is provided in cars, then announcements should also be made in American Sign Language. ] 

## Signage	Types **– Proposed	Requirements:**  **A. Directional	Signs**  (includes	directional	Exit	Signs )
– Visual **B. Designation	Signs	for	Spaces**  (includes	Exit	Signs)
– Tactile	&	Visual, and	The	ISA	shall	be	provided	at	required	wheelchair	spaces	and priority	seating	and	be	located	________. **C. Designation	Signs	for	Elements** 
– Not	Required	to	meet	accessibility requirements. **D. Non**  **- Emergency	Informational	Signs** 
– Visual	and	Meet	the	size requirement	for	visual	characters	where	possible	(practicable). **E. Non**  **- Emergency	Operational	Signs** 
– Tactile	&	Visual,	and	Meet	the size	requirement	for	visual	characters	where	practicable.	Furth ermore, where	instructions	for	door	latch/locks	are	provided	they	shall	be	both visual	and	tactile	and	be	located	_______. Where	a	pictogram	is	provided for	these	instructions	a	tactile	description	shall	be	provided	directly adjacent	to	it. **F. Emergency	In** **formational	Signs –**  Visual	&	Tactile [F.	Maldari:	...Visual	&	Tactile to	the	extent	practical.	Reduced	size	visual	and tactical	signs	are	permitted	when	necessary	due	to	space	constraints . ] **G. Emergency	Operational	Signs**  **–** Visual [F.	Maldari:	...Visual to	the extent	practical .] **H. Caution	and	Safety	Signs**  (includes	icons	and	logos) - Visual **I. Stop	Identification	Signs**  (includes	train	designation,	route,	and	final destination)
– VMS,	.	All	cars	must	provide	variable	message	signs	intwo	locations	so	that	at	least	one sign	is	readable	from	every	part	of	the

car.	The	variable	message	signs	must	provide	equal	information	as	what is	provided	aurally.	If	stops	are	announced,	the	signs	should	announce stops,	if	emergencies	are	announced;	the	signs	should	announce emergencie s,	and	so	forth.	Where	cars	provide	route	map	tracking	signs in	two	locations	so	that	at	least	one	sign	is	audible	and	visible	from every	part	of	the	car. [L.	Hamlin:	VMS:	All	cars	must	provide	variable	message	signs (VMS) in	two locations	so	that	at	least	one	sign	is	readable	from	every	part	of	the	car.	The VMS variable	message	signs must	provide information	that	is	equivalent	to that	which	is	provided	aurally: Please	see	my	note	below	in	order	to	cover both	visual	and	aural	information. I i f	stops	are	announced aurally,	VMS the signs should display	the announce d stops;	if	emergencies	are	announced aurally,VMS the	signs should display	the	same	emergency	information announce	emergencies,	and	so	forth.	Where	cars	provide	route	map	tracking signs, those	signs	should	be	placed in	two	locations	so	that	at	least	one	sign	is audible	and	visible	from	every	part	of	the	car.] [A.	Phillips: Stop	Identification	Signs Variable	Message	Signs (includes	train designation,	route, stops,	all announcements,	and	final	destination)
– VMS,	All cars	must	provide	variable	message	signs	in	two	locations	so	that	at	least	one sign	is	readable	from	every	part	of	the	car.	The	variable	message	signs	must provide	equal	information	as	what	is	provided	aurally.	If	stops	are	announced, the	signs	should	announce	stops,	if	emergencies	are	announced; the	signs should	announce	emergencies,	and	so	forth.	Where	cars	provide	route	map tracking	signs in	addition	to	Variable	Message	Signs,	such	signage	should	be provi ded in	two	locations of	the	car so	that	at	least	one	sign	is	audible		and visible	from	every	part	of	the	car.] [F.	Maldari: Stop	Identification	Signs		(includes	train	designation,	route,	and final	destination)
– VMS,	.	All	cars	must	provide	variable	message	signs	in at least two	locations	so	that	at	least	one	sign	is	readable	from	every	part	of	the car.	The	variable	message	signs	must	provide	equal	information	as	what	is provided	aurally to	the	extent	practical .	If	stops	are	announced,	the	signs should	anno unce	stops,	if	emergencies	are	announced;	the	signs	should announce	emergencies,	and	so	forth. In	instances	when	there	are	unexpected emergencies	the	information	provided	on	the	VMS	signs	does	not	need		to exactly	match	the	information	provided	aurally. Wh ere	cars	provide	route map	tracking	signs	in	two	locations	so	that	at	least	one	sign	is	audible	and visible	from	every	part	of	the	car.][A.	Gagne: All	cars	must	provide	variable	message	signs	in at	least two

locations	so	that	at	least	one	sign	is	readable from	every	part	of	the	car.	The variable	message	signs	must	provide	equal	information	as	what	is	provided aurally	.	If	stops	are	announced aurally,	the visual	message signs	should announce display stops ;	if	emergencies	are	announced aurally;	the visual message signs	should announce display emergencies,	and	so	forth.	Where	cars provide	route	map	tracking	signs in	two	locations	so	that	at	least	one	sign	is audible	and visible	from	every	part	of	the	car.] **J. Menus	and	Directories** 
– At	least	one	menu/directory must	comply **K. Employee	Only	Signs** 
– Not	Required	to	meet	accessibility requirements. 

## Additional	Notes:

 Assistive	listening - provide	assistive	listening	(induction	loops) throughout	the	train	in	bathrooms,	meal	cars,	bedrooms	and	in	bi level	rail	cars - [Subcommittee	has	agreed	to	this
– would	make caveat	that	it	is	to	be	provided	where	audible	announcements	are intended	to	be	heard] [L.	Hamlin: Assistive	listening system/hearing	induction	loop	system - provide	assistive	listening system	(hearing induction	loop system) throughout	the	train	in	bathrooms,	meal	cars,	bedrooms	and	in	bi - level rail	cars] [A.	Phillips: Assistive Ll istening Systems	(ALS) - provide	assistive listening	(induction	loops)	throughout	the	train	in	bathrooms,	meal	cars, bedroom s	and	in single	and bi - level	rail	cars - ] [F.	Maldari: Assistive	listening - provide	assistive	listening	(induction loops)	throughout	the	train	in	bathrooms,	meal	cars,	bedrooms	and	in	bi level	rail	cars to	the	extent	practical -]  Evaluate	technical	feasibility	of	induction	loops	on	rail	cars - Subcommittee	already	thinks	it	is	feasible. [L.	Hamlin: Evaluate	technical	feasibility	of hearing induction	loop system on	rail	cars - Subcommittee has	information	that	this already thinks	it is	feasible.]  VMS must include	audible	versions [F.	Maldari: VMS	must	include	audible	versions to	the	extent	practical][A.	Phillips: • Full	visual	access	must	always	be	provided	for	stop

announcements,	last	calls	for	food,	drinks,	boarding,	disembarking,	and promotions	as	well as	other	audible	announcements.	This	kind	of	access	must be	provided	through	the	variable	message	signs,	preferably	using	prerecorded messages.]  Stop	announcements,	and	other	audible	announcements	should	be	pre recorded,	high	quality	messages. [A.	Phillips: Stop	announcements	and	other	audible	announcements	should	be pre - recorded,	high	quality	messages with	corresponding	visual	messages provided	simultaneously.]  Human	announcements	should	be	kept	to	a	minimum. This	is	especially important	with station	stop	announcements. [L.	Hamlin: { Human} Live announcements from	the	crew should	be	kept to	a minimum.]  Service	animal	relief	area	information	should	be	made	available	on	the inside	wall	nearest	wherever	ISA	is	placed.  All	cars	must	provide variable	message	signs	in	two	locations	so	that	at least	one	sign	is	readable	from	every	part	of	the	car.	The	variable message	signs	must	provide	equal	information	as	what	is	provided aurally.	If	stops	are	announced,	the	signs	should	announce	stops,	if eme rgencies	are	announced;	the	signs	should	announce	emergencies, and	so	forth.2.	Where	cars	provide	route	map	tracking	signs	in	two locations	so	that	at	least	one	sign	is	audible	and	visible	from	every	part of	the	car. [L.	Hamlin: All	cars	must	provide	variable	message	signs	in	two	locations	so that	at	least	one	sign	is	readable	from	every	part	of	the	car.	The	variable message	signs	must	provide	equal	information	as	what	is	provided	aurally.	If stops	are	announced,	the	signs	should	announce	stops,	if	emergencies	are announced;	the	signs	should	announce	emergencies,	and	so	forth.2.	Where cars	provide	route	map	tracking	signs	in	two	locations	so	that	at	least	one	sign is	audible	and	visible	from	every	part	of	the	car. • VMS:All cars	must	provide	variable	message	signs	(VMS)	in	at	least	two locations	so	that	at	least	one	sign	is	readable	from	every	part	of	the	car.	The VMS	must	provide	information	that	is	equivalent	to	that	which	is	provided aurally:	if	stops	are	announced	aurally,	VMS	should	display	the	announced stops;	if	emergencies	are	announced	aurally;	VMS	should	display	the	same emergency	information,	and	so	forth.	Where	cars	provide	route	map	tracking signs,	those	signs	should	be	placed	in	two	locations	so	that	at	least	on e	sign	is audible	and	visible	from	every	part	of	the	car.		We	need	to	say	this	in	a	waythat	it	also	means	the	reverse.		With	the	growing	use	and	popularity	of	VMS,

less	and	less	is	audible.		The	necessary	information	(not	the	advertisements) need	to	be	equally	available. ] [A.	Phillips: All	cars	must	provide	variable	message	signs	in	two	locations	so that	at	least	one	sign	is	readable	from	every	part	of	the	car.	The	variable message	signs	must	provide	equal	information	as	what	is	provided	aurally.	If sto ps	are	announced,	the	signs	should	announce	stops,	if	emergencies	are announced,;	the	signs	should	announce	emergencies,	and	so	forth. 2	. Where cars	provide	route	map	tracking	signs	, such	signage	should	be	provided in two	locations of	the	car so	that	at least	one	sign	is	audible	and	visible	from every	part	of	the	car.] [F.	Maldari: All	cars	must	provide	variable	message	signs	in	two	locations	so that	at	least	one	sign	is	readable	from	every	part	of	the	car.	The	variable message	signs	must	provide	equal	information	as	what	is	provided	aurally.	If stops	are	announced,	the	signs	should	announce	stops,	if	emergencies	are announced;	the	signs	should	anno unce	emergencies,	and	so	forth . However for	emergency	announcement	there	may	be	additional	information	provid ed aurally	that	is	not	transmitted	via	VMS . ]  Meet	the	size	requirement	for	visual	characters	where	practicable. [A.	Phillips: All	visual	announcements	must	meet	or	exceed Meet the	size requirement	for	visual	characters where	practicable . ]  Where	instructions	for	door	latch/locks	are	provided	they	shall	be	both visual	and	tactile	and	be	located	10	inches	of	the	latch/lock. [A.	Gagne: Where	instructions	for	door	latch/locks	are	provided	they	shall	be both	visual	and	tactile	and	be	located within 10	inches	of	the	latch/lock.] o Where	a	pictogram	is	provided	for	these	instructions	a	tactile description	shall	be	provided	directly	adjacent	to	it.  The	ISA	shall	be	provided	at	required	wheelchair	spaces	and	priority seating.  At	least	one	menu	or directory	shall	comply	with	accessibility	standards.  

### Examine	what	factors	should	be	used	to	determine	equivalency	of audible	and	visible	messages.		Oral	announcements	need	to	have the	same	level	of	clarity	as	visual	announcements.		This	is	why	pre recorde d	announcements	are	generally	better. [L.	Hamlin: 

### Examine	what	factors	should	be	used	to	determine equivalency	of	audible	and	visible	messages.		Oral	announcements need	to must have	the	same	level	of	clarity	as	visual	announcements.][A.	Phillips: Oral	announcements	need	to	have	the	same	level	of	clarity	as

visual	announcements as	well	as	vice	versa .		This	is	why	pre - recorded announcements	are	generally better superior. ]  

### [make	recommendation	to	the	Board	to	do	research	on	speech intelligibility	and rail	car	acoustics  Variable	message	signs	legibility	(e.g.,	font,	case,	style,	and	location)

- [reference	the	ANSI	A117.1	technical	requirements	for	VMS Displays]  Emergency	Notification	Announcements	must	be	available	via Back- up	power. [A.	Phillips: Emergency	Notification	Announcements, both	aural	and visual,	must	be	available	via B b ack- up	power.]  Visual	emergency	alerts	(flashing	fire	alarms	and	such)	in	all	parts of	the	rail	cars -- compartments,	main	area,	restrooms,	etc. recommend	NFPA	72	require ments	with	the	use	of	VMS;	what	db level	is	in	NFPA	72.		Is	it	too	loud?	alarms	can	cause	disorientation and	additional	dangers	to	people	who	are	blind	or	have	cognitive disabilities. [L.	Hamlin: Visual	emergency	alerts	(flashing emergency	alerts fire alarms	and such)	in	all	parts	of	the	rail	cars ...] [A.	Phillips: Visual	emergency	alerts	(flashing	fire	alarms	and	such)	in	all	parts of	the	rail	cars -- compartments,	main	area,	restrooms,	etc. are recommende d		to	comport	with NFPA	72	requirements	with	the	use	of	VMS; what	db	level	is	in	NFPA	72. [Is	it	too	loud?	alarms	can	cause	disorientation and	additional	dangers	to	people	who	are	blind	or	have	cognitive disabilities.] ] 

###  Lighting 

## - Recommend	the	Board	do	research	on	lighting	as	there	is no	requirements	in	the	Standard	for	general	or	task	lighting	other than	in	elevators	and	at	bus	entry	points. [L.	Hamlin: Recommend	the	Board	do	research	on	lighting	as	there is are no	requirements in	the	Standard for	general ...] o Lighting	in	ci rculation	areas,	restrooms,	sleeping	compartments, step	wells,	and	in	any	other	areas.		Step	wells	in	particular	raise issues:	1.	Because	they	may	or	may	not	be	level	platforms;	2.		It may	or	may	not	be	a	paved	surface	one	is	stepping	down	on	to; 3.		Distance	to	platform	varies;	and	gaps	may	be	difficult especially	at	night.

### o Task	lighting	and	on - demand	passenger	controls

 New	Technologies
– Examine	the	potential	for	providing	messages on	hand - held	devices	such	as	smartphones
– tri - mode communication . [L.	Hamlin: Examine	the	potential	for	providing	messages that	are viewed	on	VMS	to	also	be	available	and	accessible on	hand - held	devices such	as	smartphones
– tri - mode	communication .] [A.	Phillips: New Technologies Ways	to	Provide	Access
– Examine	the potential	for	providing	messages on	platforms	such	as	smartphones, tablets,	and	wearables hand - held	devices	such	as	smartphones
– tri mode	communication accessibility	must	be	provided	in	all	modes	of communication. ] [A.	Gagne: http://www.google.ca/imgres?imgurl=http://images.nycsubway.org/maps/calcagno

2010-06 - 28c.gif&imgrefurl=http://www.nycsubway.org/wiki/New_York_City_Subway_Route_Map_by_Michael_ Calcagno&h=1522&w=1172&tbnid=GoxqmAhi6wuSfM:&zoom=1&do cid=Ty5EtWeep5rKnM&ei=
- jLaVIqsAonnUp_TgvgF&tbm=isch&ved=0CDIQMygAMAA ] [J.	Lintz: 

### A	couple	of	the	alphabetized	sections	could	be	concentrated	into one,	eg	current	D	and	E,	and	F	and	G. B	seems	a	bit	vague.	More	on	the	lines	of:	"Designation	Signs	for wheelchairs	and	priority	seating:	tactile,	visual	and	ISA	should	be	located at	eye	and	hand	level."		Some	of	the	descriptive	terms	aren't	very	clear	to me.		For	example,	"Designation	signs	for	Elements."	This	is	perhaps clearer	to	experts	reading	the	text? Use"station" for the somewhat ambiguous "stop?" K Employees Only signs -- - "no requirements." Do any employees have disabilities? Most of the Notes are repetitious. Maybe only save the following: Service animals relief areas; acoustics -- - standards; backup power; visual and audible alarms -- - ( not too bright or too loud); Good lighting and clear voices; Use of smart phones and other current technology. We need to ensure that the main cars have induction loops as well. The bedroom cars probably should be called sleeper cars. ] [G.	Millis: The	Washington	Metrorail	system	has	invested	in	accessibility in	order	to	ensure	the	disability	community	in	the	DC	service	area	has access	to	mass	transit.		We	congratulate	the	RVAAC	on	its	work	to

### improve	accessibility	in	rail	service,	particular	inter- city	service	for

people	with	disabilities. Any	rule	changes	that	have	application	to	any	particular	rail	mode	need to	expressly	state	on	which	mode	the	change	will	be	required.		For example,	menus	and	animal	service	areas	could	be	limited	to	inter- city service.		They	have	no	application	on	subway	service. Technology	can	assist	in	making	rail	station	and	rail	cars	more accessible.		That	technology	though	must	be	available	and	must	be	able to	perform in	complex	environments. Environment	can vary significantly	depending	on	if	the	rail	service	is	subway,	commuter	or inter- city	railroad.		The	technology	must	also	be	financially	feasible	and operationally	sustainable. For	example,	rail	cars	for	each	type of	service	may	require	significant differences	in	order	to	install	inductive	listening	technology.			Rail stations	are	also	different	varying	from	complex,	such	as	multi - level multi	line	stations	such	as	Gallery	Place	Metro	to	simple	outdoor	stations serving	a	single	line.				More	information	on	the	feasibility	and	cost	of installing	inductive	loops	in	rail	facilities	and	cars	is	needed	if	this	rule	is to	be	proposed. Similarly	the	language	on	signage	also	may	pose	technical	challenges	and operational	con cerns .				An	operational	concern	is	that	a	variable messaging	sign	providing	audible	announcements	must	operate	in environments	with	rail	car	noise,	station	announcements	and announcements	make	by	trains.		Given	the	background	noise	level, announcements	ma de	by	a	variable	messaging sign	is likely	not	to	be heard	and	especially	as	distance	increases	from	the	sign.		A	technical concern	is	that	there	is	not	room	in	Metrorail	cars	to	install	some	of	the signage	discussed	such	as	at	end	doors	of	subway	cars. ]