The National Federation of the Blind of Maryland knows that blindness is not the characteristic that defines you or your future.
2020 Comments on Regional Transit Plan for Central Maryland
Subject: Comments on Regional Transit Plan for Central Maryland
To: MDOT/MTA
From: Members of the National Federation of the Blind of Maryland
Contact: Sharon Maneki, Director of Legislation and Advocacy
National Federation of the Blind of Maryland
9013 Nelson Way
Columbia, MD 21045
Phone: 410-715-9596
Email: nfbmdsm@gmail.com
Date: June 18, 2020
The National Federation of the Blind of Maryland offers the following comments on “Connecting Our Future: A Regional Transit Plan for Central Maryland”. Our comments surround the three themes of accessibility, quality, and equity. We applaud the goals and objectives listed in this plan. However, to reach these goals, the plan must also address needed policy changes if they are really to be achieved.
Throughout our comments, we have identified several considerations missing from this plan. Because of these omissions, we strongly recommend that a blind person from a consumer organization, who has knowledge and experience with using multiple forms of transportation be appointed to the committee who will further develop the plan.
Accessibility:
If you want input from the public, you should provide a website that is accessible to all of the public, including the blind. The Connecting our Future website ( https://rtp.mta.maryland.gov/ ) was difficult to read. Graphics were poorly labeled, if labeled at all, and the PDF document was very unwieldy. While we appreciate the value that online comments can offer, it was much too difficult for a person using a screen reader to find the appropriate space for the comment, and it could not be done without using sighted assistance. Using instructions such as “click here” does not help a blind person since we cannot use the mouse and must use keyboard commands. The captcha in the website designed to prove that you are not a robot is completely inaccessible and unusable by people using screen readers. Since we cannot use the collaborative tools provided, we are preparing a separate document outlining our concerns.
In Chapter 3, on page 17, the plan states that objectives will be achieved through initiatives. One of the initiatives mentioned is the category of strategies which are specific actions. Accessibility should be listed as one of these strategies. Throughout the document, there is mention of accessible transportation which is definitely appropriate. However, accessibility is broader than just physical access. Websites, phone apps, and signage are also part of accessibility. The document does not address these accessibility issues, and it should.
In Chapter 4, on page 21, the objective “provide faster, more reliable service to both serve existing customers and to attract new riders” offers another example where accessibility should be considered as a strategy to reach these criteria. All ticket vending machines, fare card readers, mobile payment apps, must be accessible to all of the public including the blind. Accessibility requirements must be issued as part of any proposed methods of off-board or on-board fare collection. When phone apps or websites are upgraded, efforts must be made to maintain accessibility. For example, the MARC Train app used to be accessible but now it is no longer accessible due to such upgrades.
Quality:
Goal 2 of this plan is to “optimize existing transit services.” One explanation given in the plan about this goal is “improve service quality, customer experience, and safety on existing services.” If the plan is really to achieve this goal, thought must be given to the unintended consequences created by policies. For instance, in Chapter 4: Strategies, on page 21 under the objective, “Provide faster more reliable service” the plan describes how to improve bus speed and reliability. One of the suggestions for improvement is to create dedicated bus lanes. We do not object to dedicated bus lanes but believe the plan should ensure that pedestrian safety is part of the consideration when bus lanes are created. If a blind person or any other pedestrian has to negotiate traffic to get to or find the bus lane, are you really improving the customer experience? We also do not object to transit signal prioritization. However, how are you considering the needs of pedestrians who must cross the streets?
We applaud the use of technology mentioned throughout the plan. Technology can solve many problems if it is properly used and can improve the customer experience. Automated bus announcement technology should not have been omitted from the plan because it provides valuable information to customers. Policies and practices can reduce the effectiveness of technology so planning must consider how to mitigate these consequences. For instance, bus announcement technology has not been as effective because bus operators can turn it off. The plan should address this problem. Another example is the unintended consequence caused by instructing bus operators not to open the front door of the bus due to concerns about the COVID-19 virus. Blind people no longer know which bus is at the stop. The automated bus announcement does not work unless the front door opens. Transportation service providers must find a way to meet both the concerns for the safety of the bus operator as well as providing needed information to the customer.
We certainly applaud the objective “Increase Access to Jobs and Opportunities” listed in chapter 4. On page 29, one of the strategies offered to reach this objective is “Integrate Shared Mobility options (e.g., microtransit, scootershare, bikeshare, carshare, and rideshare) to complement existing services.” While it is reasonable to promote the use of bicycles and electric scooters for transportation to the bus stop or train station, the plan does not consider the need for protecting pedestrian access. For instance, there must be parking pens for dockless scooters in the train station so that they do not impede pedestrian access. Dockless scooters should never be permitted on the train platform because of the hazard they will create for pedestrians. Bicycles and micro-mobility devices have their place in the transportation realm, but their use must be regulated so that they do not impede the access and safety of pedestrians.
Equity:
We applaud the plan’s recommendations in Chapter 4 under the heading “Improve Transit Accessibility” on page 36. We also applaud the recommendations under the heading “Improve the Paratransit Trip.” However, the plan needs additional paratransit recommendations. There should be reciprocity between jurisdictions concerning eligibility. Riders who use paratransit from multiple jurisdictions such as MTA Mobility and RTA, should not be forced to file separate applications, obtain doctor information, and go for an interview to use the service in every jurisdiction of the region. If traffic signals and bus locations can be synchronized, then databases in different jurisdictions should also be able to talk to each other.
Paratransit scheduling needs to be more efficient. For instance, dispatchers will send two vehicles to the same household to take two individuals to the same location. Sometimes, policies create inefficiencies. For example, RTA will not take individuals to Johns Hopkins Hospital if they are not Howard County residents. Consequently, they will take a person from Laurel to Arundel Mills Mall, then the person must take MTA mobility the rest of the way to Johns Hopkins. This is an inefficient use of resources and inefficient for the customer as well.
Too many jurisdictions limit the hours of daily paratransit trips, do not operate on the weekend, and restrict destinations. People who must use paratransit service should not be penalized by such restrictions. Turning paratransit into an on-demand service is paramount. The plan should study how to achieve on-demand service by developing community partnerships and using ride-sharing systems such as Uber and Lyft. People who must use paratransit should have the same freedom to travel as people have when using other forms of public transportation.
Conclusion:
Since the needs of blind persons were not addressed in this plan, we strongly recommend that a blind person from a consumer organization, who has knowledge and experience with using multiple forms of transportation be appointed to the committee who will further develop the plan.
Chapter 7: Next Steps does not address milestones for improving the customer experience for transit users with disabilities. The “Tracking Our Progress” section on page 66 should include accessibility milestones for each of the six objectives. The plan as currently drafted will leave persons with disabilities, including the blind, behind if accessibility strategies and milestones are not clearly defined in the plan.
The plan covers the needs of persons with disabilities primarily when discussing paratransit rather than when discussing all forms of transportation. Persons with disabilities, especially the blind, can and want to use all forms of public transportation. For instance, pedestrian safeguards should be part of every implementation target of the plan. The needs of persons with disabilities should be considered when discussing all six objectives or they will never be achieved.
Currently, paratransit systems are separate and unequal forms of transportation. Persons with disabilities deserve the same high-quality standard of transportation available to the nondisabled public. The goal of equal transportation for all citizens should be added to this plan.
Thank you for considering the views of the National Federation of the Blind of Maryland.
MS word copy of this document can be found here.