#  Cost Estimates for Automated Stop and Route Announcements 

**July 2010**

### Table of Contents

- Executive Summary
- Chapter 1. Background
- Chapter 2. Transit Agencies Affected
- Chapter 3. Cost Estimates
- List of Tables    - Table 1:   Transit Agencies That Directly Operate Buses in Fixed Route Sytems
  - Table 2:   Transit Agencies That Contract with Private Entities to Operate All the Buses in Their Fixed Route Systems
  - Table 3:   Transit Agencies That Contract with Private Entities to Operate Some of the Buses in Their Fixed Route Systems
  - Table 4:   Transit Agencies That Do Not Provide Automated Announcements 
  - Table 5:   Transit Agency Sample Data
  - Table 6:   Cost Factors
  - Table 7:   Transit Agency Sample Costs
  - Table 8:   Total Costs for Seven Transit Agencies That Do Not Provide Automated Announcements 
- Appendices
- End Notes

### Executive Summary

This report estimates the costs of a proposed change to the Access Board’s transportation vehicle accessibility guidelines regarding stop and route announcements.  The guidelines currently require buses that are more than 22 feet in length and operate in fixed route systems to provide a public address system for announcing stops.  The Department of Transportation adopted the guidelines as enforceable accessibility standards and requires stops and routes to be announced on vehicles that operate in fixed route systems.  Transit agencies can use vehicle operators or automated announcements to comply with the current regulatory requirements.  Failure of vehicle operators to announce stops and routes has been a frequent source of complaints to the Department of Transportation and lawsuits against transit agencies.

The Access Board proposes to change the guidelines to require transit agencies that are public entities (i.e., State or local government units) and operate 100 or more buses in annual maximum service in fixed route systems, as reported in the National Transit Database, to provide automated stop and route announcements on buses that are more than 22 feet in length and operate in fixed route systems.  The Department of Transportation will establish the effective date for this requirement when it adopts the revised guidelines as the updated accessibility standards for transportation vehicles.  The requirement will apply when buses are purchased, leased, or remanufactured.  Buses currently in service do not have to be retrofitted to meet the requirement. 

According to the National Transit Database, 87 transit agencies that are public entities operate 100 or more buses in annual maximum service in fixed route systems and will be affected by the proposed change to the guidelines.  More than 90 percent of these transit agencies currently provide automated stop and route announcements on buses.  The report assumes that transit agencies that currently provide automated announcements on buses will continue to do so in the future and will not incur any additional costs as a result of the proposed change to the guidelines.  Transit agencies are requested to comment on this assumption.  Based on the comments received, this report may be revised at the final rule stage.

Only 7 transit agencies that are public entities and operate 100 or more buses in annual maximum service in fixed route systems do not currently provide automated stop and route announcements on buses.  The total costs of the proposed change to the guidelines for these 7 transit agencies are presented below.

The cost estimates include one-time costs to equip new buses and to set-up backend systems for implementing automated announcements, and on-going maintenance and operation costs for the bus equipment and backend systems.  The low cost and high cost scenarios account for variables that can affect costs.

Forty (40) of the transit agencies that are public entities and operate 100 or more buses in annual maximum service in fixed route systems contract with private entities to operate some or all of the buses.  The Department of Transportation regulations require a private entity that acquires vehicles to operate in a fixed route system under contract with a public entity to comply with the accessibility standards applicable to the public entity. The report identifies the private entities that contract with the 40 transit agencies to operate buses in their fixed route systems.  These private entities would be affected by the proposed change to the guidelines if they acquire buses to operate in fixed route systems under contract with the transit agencies.  These private entities would not be affected by the proposed change to the guidelines if the transit agencies provide the buses to the private entities to operate, of if the private entities deploy buses from their existing fleets to operate in the fixed route systems under contract with the transit agencies.  Information is not available on whether any of the private entities that contract with the transit agencies acquire buses to operate in fixed route systems under contract with the transit agencies.  Private entities that acquire buses to operate in fixed route systems under contract with the transit agencies are requested to provide information on the number of buses acquired on an annual basis for operation under contract with the transit agencies, and whether the buses provide automated stop and route announcements.  Based on the information provided, this report may be revised at the final rule stage.

###  1.  Background 

- 1.1 Introduction 
- 1.2 Current Regulatory Requirements 
- 1.3 Compliance with Current Regulatory Requirements 
- 1.4 Proposed Change to Guidelines 

####  1.1 Introduction 

The Access Board prepared this report to estimate the costs of a proposed change to the transportation vehicle accessibility guidelines regarding stop and route announcements.  The Volpe National Transportation Systems Center produced the data presented in the tables and appendices under interagency agreement with the Access Board. 

####  1.2  Current Regulatory Requirements 

 The Americans with Disabilities Act requires the Access Board to issue guidelines for transportation vehicles that are readily accessible to and usable by individuals with disabilities.1  The guidelines establish minimum requirements for enforceable accessibility standards issued by the Department of Transportation that apply to the acquisition of new, used, and remanufactured transportation vehicles, and the remanufacture of existing transportation vehicles covered by the Americans with Disabilities Act.2

The Access Board issued transportation vehicle accessibility guidelines in 1991.3  The guidelines require buses that are more than 22 feet in length and operate in fixed route systems to provide a public address system for announcing stops.4  The Department of Transportation issued regulations in 1991 that adopted the guidelines as enforceable accessibility standards.5  The Department of Transportation regulations require stops and routes to be announced on vehicles that operate in fixed route systems.6

####  1.3  Compliance with Current Regulatory Requirements 

 Transit agencies can use vehicle operators or automated announcements to comply with the current regulatory requirements.  Transit agencies that use vehicle operators to announce stops and routes have to systematically monitor vehicle operators and enforce disciplinary procedures to ensure compliance.7  Failure of vehicle operators to announce stops and routes has been a frequent source of complaints to the Department of Transportation and lawsuits against transit agencies.8  Compliance reviews conducted by the Department of Transportation show that vehicle operator compliance with the current regulatory requirements is rarely above 50 percent.9  Individuals with disabilities continue to identify failure of vehicle operators to announce stops and routes as a major problem.10

####  1.4 Proposed Change to Guidelines 

 Many transit agencies have deployed intelligent transportation system technologies during the past decade that can be used to provide automated stop and route announcements.  The number of buses that provide automated announcements has increased from 10 percent in 2001 to 45 percent in 2008.11  Automated announcements provide standardized messages, and lessen the need to rely on vehicle operators for compliance.12

The Access Board made available for public review draft revisions to the transportation vehicle accessibility guidelines.13  The draft revisions considered requiring buses that are more than 22 feet in length and operate in fixed route systems to provide automated stop and route announcements. The American Public Transportation Association commented that the cost of providing automated announcements would pose a hardship for small transit agencies, and recommended that transit agencies operating fewer than 100 buses in peak service periods be exempted from the requirement.  Based on the comments, the Access Board proposes to change the transportation vehicle accessibility guidelines to require transit agencies that are public entities (i.e., State or local government units) and operate 100 or more buses in annual maximum service in fixed route systems, as reported in the National Transit Database, to provide automated stop and route announcements on buses that are more than 22 feet in length and operate in fixed route systems.  The Department of Transportation will establish the effective date for this requirement when it amends its regulations to adopt the revised guidelines as the updated accessibility standards for transportation vehicles.  The requirement will apply when buses are purchased, leased, or remanufactured.14  Buses currently in service do not have to be retrofitted to meet the requirement.

###  2.  Transit Agencies Affected 

- 2.1 Eighty-Seven Transit Agencies Are Affected 
- 2.2 Seventy-Nine Transit Agencies Directly Operate Buses 
- 2.3 Forty Transit Agencies Contract with Private Entities to Operate Buses 
- 2.4 Eighty Transit Agencies Provide Automated Announcements 
- 2.5 Seven Transit Agencies Do Not Provide Automated Announcements 

####  2.1 Eighty-Seven Transit Agencies Are Affected 

 The proposed change to the transportation vehicle accessibility guidelines requires transit agencies that are public entities (i.e., State or local government units) and operate 100 or more buses in annual maximum service in fixed route systems, as reported in the National Transit Database, to provide automated stop and route announcements on buses that are more than 22 feet in length and operate in fixed route systems. 

Transit agencies are required to report the number of vehicles operated in annual maximum service (VOMS) to the National Transit Database.15  VOMS is the number of vehicles operated during the peak season of the year on the week and day that maximum service is provided.16  Transit agencies report both the number of VOMS directly operated by the transit agency and the number of VOMS operated by contractors.17

According to the National Transit Database, 87 transit agencies that are public entities operate 100 or more bus VOMS in fixed route systems and will be affected by the proposed change to the guidelines.  It is assumed that the number of transit agencies that operate 100 or more bus VOMS in fixed route systems will remain stable in the near future.

####  2.2 Seventy-Nine Transit Agencies Directly Operate Buses 

 Seventy-nine (79) of the affected transit agencies directly operate buses in fixed route systems.  The transit agencies and number of bus VOMS directly operated by the transit agency are listed in Table 1. 

####  2.3 Forty Transit Agencies Contract with Private Entities to Operate Buses 

 Forty (40) of the affected transit agencies contract with private entities to operate some or all of the buses in the fixed route systems.  The Department of Transportation regulations require a private entity that acquires vehicles to operate in a fixed route system under contract with a public entity to comply with the accessibility standards applicable to the public entity.18  The Department of Transportation regulations do not subject private entities to the requirements applicable to public entities because they receive an operating subsidy from, are regulated by, or are granted a franchise or permit to operate by a public entity.19  Thus, private entities would be affected by the proposed change to the guidelines if they acquire buses to operate in fixed route systems under contract with the transit agencies.  Private entities would not be affected by the proposed change to the guidelines if the transit agencies provide the buses to the private entities to operate, of if the private entities deploy buses from their existing fleets to operate in the fixed route systems under contract with the transit agencies.20

Eight (8) of the affected transit agencies contract with private entities to operate all the buses in their fixed route systems.  The transit agencies, contractors, and number of bus VOMS are listed in Table 2. 

The other 32 transit agencies contract with private entities to operate some of the buses in their fixed route systems.  The transit agencies, contractors, and number of bus VOMS are listed in Table 3.

####  2.4 Eighty Transit Agencies Provide Automated Announcements 

 Eighty (80) of the affected transit agencies currently provide automated stop and route announcements.21  These transit agencies are indicated by shaded rows in Tables 1 and 2.  This information was obtained from transit agency websites, vendor websites, and other sources listed in Appendix A.  These transit agencies typically provide automated announcements as part of a broader deployment of intelligent transportation system technologies.  It is assumed that these transit agencies will continue to provide automated announcements when the transit agencies purchase, lease, or remanufacture buses in the future, regardless of whether the transit agencies directly operate the buses or contract with private entities to operate the buses.  Based on this assumption, these transit agencies will not incur any additional costs as a result of the proposed change to the accessibility guidelines.  Transit agencies are requested to comment on this assumption.  Based on the comments received, this report may be revised at the final rule stage.

Information is not available on whether any of the private entities that contract with the transit agencies listed in Tables 2 and 3 purchases, leases, or remanufacturesacquire buses to operate in fixed route systems under contract with the transit agencies.  Private entities that purchase, lease, or remanufactureacquire buses to operate in fixed route systems under contract with the transit agencies listed in Tables 2 and 3 are requested to provide information on the number of buses purchased, leased, or remanufacturedacquired on an annual basis for operation under contract with the transit agencies, and whether the buses provide automated stop and route announcements.  Based on the information provided, this report may be revised at the final rule stage.

####  2.5 Seven Transit Agencies Do Not Provide Automated Announcements 

 Seven (7) of the affected transit agencies listed in Table 4 do not currently provide automated announcements. 

| TX | Fort Worth Transportation Authority (The T)                 | 123 | 3   | 126 |
|----|-------------------------------------------------------------|-----|-----|-----|
| NE | Omaha Transit Authority (MAT)                               | 128 | 0   | 128 |
| VA | Fairfax County (Fairfax Connector)                          | 0   | 149 | 249 |
| NY | Central New York Regional Transportation Authority (CNYRTA) | 183 | 0   | 183 |
| KY | Transit Authority of River City (TARC)                      | 190 | 7   | 197 |
| CT | Connecticut Department of Transportation (CTTransit)        | 317 | 23  | 340 |
| CA | San Diego Metropolitan Transit System (MTS)                 | 200 | 216 | 416 |

###  3.  Cost Estimates 

- 3.1 Transit Agency Sample Data 
- 3.2 Cost Factors 
- 3.3 Transit Agency Sample Costs 
- 3.4 Total Costs 

####  3.1 Transit Agency Sample Data 

 The cost estimates of the proposed change to the transportation vehicle accessibility guidelines regarding stop and route announcements are based on sample data for the 7 transit agencies listed in Table 4 that do not currently provide automated announcements.  Data for each of the transit agencies is presented in Appendix B, and the sample data used to estimate the costs is presented in Table 5.

| Buses Available for Annual Maximum Service | 273 |
|--------------------------------------------|-----|
| Fixed Bus Routes                           | 70  |
| Garages                                    | 5   |
| Vehicle Operators                          | 520 |
| Mechanics                                  | 124 |

####  3.2 Cost Factors 

 The factors used to estimate the costs for providing automated stop and route announcements are presented in Table 6.  The factors include one-time costs to equip new buses and to set-up backend systems for implementing automated announcements, and on-going maintenance and operation costs for the bus equipment and backend systems.  Mid-life software upgrade costs for the bus equipment and backend systems are listed as separate factors.  Training costs for vehicle operators and mechanics are included under one-time costs.  Low and high cost scenarios account for variable that can affect some of the costs.  Some of the low cost scenarios apply to transit agencies that deploy automatic vehicle location technology.22  Four (4) of the transit agencies that do not currently provide automated announcements deploy automatic vehicle location technology.23

####  3.3 Transit Agency Sample Costs 

 The low cost and high cost scenarios for a transit agency to provide automated announcements based on the transit agency sample data in Table 5 and cost factors in Table 6 are presented in Appendices D and E, and summarized in Table 7.24  It is assumed that the transit agency will replace one-twelfth of its buses each year based on the 12 year minimum useful life policy for large, heavy-duty buses established by the Federal Transit Administration.25

####  3.4 Total Costs 

 The total costs of the proposed change to transportation vehicle accessibility guidelines regarding stop and route announcements for the seven transit agencies that do not currently provide automated announcements based on the transit agency sample costs in Table 7 are presented in Table 8.26

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###  Appendices 

- Appendix A:  Sources Confirming Transit Agencies Provide Automated Announcements
- Appendix B:  Transit Agency Data
- Appendix C:  Labor Cost Sources
- Appendix D:  Low Cost Scenario – Transit Agency Sample Costs
- Appendix E:  High Cost Scenario – Transit Agency Sample Costs

  

  

  

  

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###  End Notes 

1  42 U.S.C. §12204.
2  42 U.S.C. §§12149.
3  56 Federal Register 45530, September 6, 1991 (codified at 36 CFR §1192).
4  36 CFR §1192.37.
5  56 Federal Register 45584, September 6, 1991 (codified at 49 CFR Part 38).
6  49 CFR §37.167 (b) and (c).
7  American Public Transportation Association, Draft Recommended Practice for a Fixed Route Stop Announcement and Route Identification Program (April 2, 2008) at 7-10.  The document is available at: http://www.aptastandards.com/Portals/0/Accessibility/StopAnnc/FRSA_draft_1_from_editor_1%20July%203%202008.pdf. 
8  Tandy v. City of Wichita, 380 F. 3d 1277 (10 Cir. 2004); Martin v. Metropolitan Atlanta Rapid Transit Authority, 225 F. Supp. 2d 1362 (N.D. Ga. 2002); Neff v. VIA Metropolitan Transit Authority, 178 F.R.D. 185 (W.D. Tex. 1998).  See also Daniels-Finegold v. Massachusetts Bay Transportation Authority, C.A. No. 02 CV 11504 MEL (U.S. Dist. Ct. Mass. filed July 25, 2002) alleging system-wide problems in providing accessible public transportation, including failure to announce stops and routes. 
9  The compliance review reports are available at: http://www.fta.dot.gov/civilrights/ada/civil_rights_3899.html. 
10  National Council on Disability, Current State of Transportation for People with Disabilities in the United States (June 13, 2005).  The report is available at: http://www.ncd.gov/newsroom/publications/2005/current_state.htm. 
11  American Public Transportation Association, 2009 Public Transportation Fact Book at 17.  The document is available at: http://www.apta.com/gap/policyresearch/Documents/APTA_2009_Fact_Book.pdf.
12  Vehicle operators will have to announce stops and routes if automated announcements fail.
13  The draft revisions to the transportation vehicle accessibility guidelines and public comments on the draft revisions are available at: http://www.access-board.gov/transit. 
14  49 CFR §§ 37.71, 37.73, 37.75 and 38.21 (a). 
15  49 U.S.C. §5335; 49 CFR Part 630.
16  VOMS does not include atypical days (e.g., July 4th holiday) or one-time special events (e.g., political convention).  NTD Glossary at: http://www.ntdprogram.gov/ntdprogram/Glossary.htm.
17  Vehicles operated by contractors are reported as “purchased transportation services” in the National Transit Database.  NTD Glossary at: http://www.ntdprogram.gov/ntdprogram/Glossary.htm.
18  49 CFR §37.23 (b).
19  49 CFR §37.37 (a).
20  If the transit agencies provide the buses to the private entities to operate, the transit agencies are responsible for providing the automated announcements.  If the private entities deploy buses from their existing fleets to operate in the fixed route systems under contract with the transit agencies, the buses are not required to be retrofitted with automated announcements, but the vehicle operators would have to announce stops and routes. 
21  Transit agencies that recently received federal grants to provide automated announcements or are in the process of procuring automated announcements are included among the transit agencies that currently provide automated announcements.
22  Automatic vehicle location (AVL) technology uses global position satellite (GPS) receivers to calculate the real-time location of a vehicle, and transmits the data to a central facility by radio or other wireless communications systems.  The data is used to monitor on-time performance and improve adherence to schedules.  Automated stop and route announcements can be integrated with AVL technology.
23  The Omaha Transit Authority, Transit Authority of River City, Central New York Regional Transportation Authority, and San Diego Metropolitan Transit System deploy AVL technology. 
24  The cost estimates in Appendices C and D do not include GPS receivers since 4 of the transit agencies that do not currently provide automated announcements equip their buses with GPS receivers.
25  The bus equipment spare parts costs are assumed to be incurred in the 1st year of the 12 year bus replacement cycle, and the mid-life software upgrade costs are assumed to be incurred in the 7th year of the 12 year bus replacement cycle. 
26  The cost estimates in Table 7 include the costs for GPS receivers for the 3 transit agencies that do not equip their buses with GPS receivers.