Green Line accessibility public hearing

Thursday, July 10, 6-8 pm
Argenziano School
290 Washington St (map)

On Thursday, July 10, 2014, the MBTA will hold a public hearing to review an Equivalent Facilitation Request by the Green Line Extension (GLX). The hearing will be held at the Dr. Albert F. Argenziano School at Lincoln Park, 290 Washington Street, Somerville, MA from 6:00 pm-8:00 pm in the cafeteria. Submittal of the Equivalent Facilitation Request is required as part of the project’s application for a Full Funding Grant Agreement with FTA.

“Equivalent facilitation” is the means by which the Federal Transit Administration (FTA) and the Americans with Disabilities Act (ADA) regulations accommodate innovation in accessible design; it is intended to permit the development of improvements in vehicle, facility, or equipment design that provides for equal or greater accessibility, but would not strictly meet the required design standards. It does not, however, represent a mechanism for obtaining a waiver from compliance. Equivalent facilitation is covered under federal law by 49 CFR Part 37.

Although the GLX project has been designed to provide significant mobility and accessibility improvements within Cambridge, Somerville and Medford, a determination of equivalent facilitation is required for several isolated situations near the GLX stations, mostly relating to points where the project improvements interface with the existing sloping roadway conditions that are familiar to GLX area residents and visitors.

The United States Department of Transportation (DOT) ADA regulations contain specific requirements governing the process for requesting a determination of equivalent facilitation as well as conditions that must be met before a determination can be made. Section 37.9(d) of 49 CFR Part 37 describes the procedures and requirements for seeking a determination of equivalent facilitation for transportation facilities. No departures from these specific requirements can be made without a determination of equivalent facilitation from the FTA Administrator.

A formal determination of equivalent facilitation from the FTA Administrator permits departures from the specific technical and scoping requirements for specific facilities where the alternative designs and technologies used will provide substantially equivalent or greater accessibility and usability.

The requirement for an affirmative determination of equivalent facilitation serves two purposes. First, it ensures that the facilitation provision does not become a mechanism for amending the regulations outside of the Federal rulemaking process. Second, and perhaps more important, it provides a degree of assurance that any departure from the required standard fulfills the same function to an equal or greater degree.

This hearing on July 10 is to review the elements of this GLX request and solicit public comment before it is made final and submitted to FTA. Download the GLX Equivalent Facilitation Request draft.

- - -

What does all this mean in normal English? Here's an explanation thanks to Ken Krause...

MassDOT/MBTA is asking FTA's concurrence for variances from ADA at several stations, primarily due to the existing topography of the surrounding streets and proximity of existing buildings, which they say has made it practically impossible to meet the letter of the regulations and guidelines.

Station by station:

LECHMERE - No accessible pathway issues are expected

WASHINGTON STREET - Seeking a state variance on the slope of the crosswalk at Tufts Street, which is 2% and is not being reconstructed.

UNION SQUARE - Seeking state variances and FTA concurrence for five conditions where Prospect Street bridge roadway slopes exceed regulations.

GILMAN SQUARE - Seeking five variances where the sidewalks slope exceeds regulations and one for where the public elevators are not in the direct circulation path due to site constraints. Two of variances mention the Community Path:

Gilman Square Variance #3
While the Community Path leading to the station has compliant cross slopes of about 1%, at its juncture with School Street the existing sidewalk slopes are about 8.7%. Due to the continuous steep slopes along School Street, creating a level landing on the sidewalk at the community path interface is not feasible. Therefore a transitional zone is necessary where the path slope will gradually increase from 1% to 8.7% in order to meet the sidewalk slope. Since the Community Path cross slopes exceed 2% at its School Street entrance (east side), to match existing running slopes at the street sidewalk. The GLX project is therefore requesting a state variance from 521 CMR 20.00 - Accessible Route and FTA concurrence with respect to 36 CFR 1191 Appendix D, paragraph 403.3 - Slope.

Gilman Square Variance #4
Due to the continuous running slopes of about 8.5% along School Street, creating a level landing at the sidewalk where the future community path meets the sidewalk, will not be feasible. Therefore a transitional zone is necessary where the path slope will gradually increase from less than 2% to approx. 8.5% in order to meet the existing sidewalk slope. Since the Community Path cross slopes exceed 2% at its School Street entrance (west side), to match existing running slopes at the street sidewalk. The GLX project is therefore requesting a state variance from 521 CMR 20.00 - Accessible Route and FTA concurrence with respect to 36 CFR 1191 Appendix D, paragraph 403.3 - Slope.

LOWELL STREET - Seeking three variances where the sidewalks slope exceeds regulations and one for where a handrail is being omitted due to it creating a potential safety hazard.

BALL SQUARE - Seeking three variances where the sidewalks slope exceeds regulations, one for where a handrail is being omitted due to it creating a potential safety hazard, and one to allow a non-uniform stair riser height.

COLLEGE AVENUE - Seeking three variances where the sidewalks slope exceeds regulations, one for where a handrail is being omitted due to it creating a potential safety hazard, and one to allow a non-uniform stair riser height.