*This post was edited on February 25 after I noticed an error in the spreadsheet. The percentage of accessible stations changed from 21.4 to 20.2 after this correction.
Manhattan Borough President, Gale Brewer’s office recently conducted a study of The Current State of the MTA’s Accessible Stations, citing 114 stations out of 472 total stations, or 24% (as of September 2018.) That percentage is only true if you believe that Times Square is not one station, but five. If you think it is one station, then the subway only has 424 stations. Many transit nerds are well aware of this MTA quirk, but it’s much more problematic than it seems. When it comes to an honest accounting of the state of accessibility, the MTA has obfuscated the real number of stations, falling back on the argument that our system was once made up of three companies, as if it’s impossible to change the mode of counting stations to international standards. Their counting methods are also wildly inconsistent, with parts of some station complexes still being officially counted as one, including Union Square, N/Q/R/W and L as one station (4/5/6 is a separate station that’s still inaccessible). West 4th Street counts as one station despite having two sets of tracks and two lines.
This quote from Brewer’s report caught my attention, “…ruling out stations that provide accessibility in only one direction, as well as stations that do not provide accessible transfers between other lines, would reveal a true percentage of accessible stations that is substantially lower than 24 percent.” Well, it just so happens I have been working on a Google map of accessible subway entrances and saw that the number of stations functionally shrank as I saw multiple train lines served by one street elevator. As it seems no one has already done this analysis, I started using a different method, by counting station complexes as unique stations, then calculating the percent of complexes for each unique station in the key station list. For example, 34 Street-Herald Square (N/Q/R/W) and 34 Street-Herald Square (B/D/F/M) each count as 50% of 1 station instead of two stations.
(See the expandable legend at the top left corner to enable or disable these layers: accessible stations, partly accessible stations, stations denied accessibility upgrades in the Enhanced Station Initiative and several proposals for future station upgrades)
In the process, I realized that the MTA included three Staten Island Railroad (SIR) stations in its 100 key station agreement—the famed 1994 lawsuit settlement that the MTA has treated as their exemption from the Americans With Disabilities Act. But, the MTA doesn’t count SIR in their official station total. Doing so would bring total stations to 493. When counting unique stations and including SIR there are 445 subway stations. New York City Transit is four separate rail companies, not three. Is this merely evidence of sloppy record keeping or intentional inflation? It is pretty irresponsible to forget every station in an entire borough even if they are not integrated with the rest of the system. If it wasn’t intentional to pad the key station list with the same uncounted stations in Staten Island, it’s incorrect and misleading and the MTA should correct the record.
For the 100 key station agreement, if Times Square counts as one station instead of five, how many stations did the MTA actually agree to make accessible by 2020?
- When accounting for duplicate stations and partly accessible station complexes, the 100 key station agreement (per a 2008 report to the FTA, page 35) makes about 78 stations accessible. Nearly 68 are now complete (MTA counts 87 stations complete as of June 2018).
- MTA claims to have built 31 more non-key stations, but when excluding duplicates and correcting for partial stations, it’s only 22. Eleven of their non-key stations are at ground level, have ramps, or are new construction (which makes it harder to shirk ADA requirements). Five non-key stations are part of key station complexes and five have routes that are accessible in only one direction.
- The MTA counts 118 stations accessible (87 key + 31 non-key), but the current number of unique accessible stations is only 90 (68 key + 22 non-key).
- As a percentage of total unique stations including SIR (445), 20.2% are wheelchair accessible.
Even though this is a change of only a few percentage points, it’s still important that we accurately count our accessible stations (and all stations if we dare to dream of having a subway that’s 100% accessible). Wheelchair users already have little faith in existing subway elevators because they are often out of service and lack real-time status updates. Having partially accessible stations only adds to the perception that the subway is off-limits, discouraging people from taking advantage of the accessible stations that exist.
One thing to note, I counted the Shuttle to Times Square’s only two stations as zero. Even though they are two of the key stations in the agreement, the 7 train is accessible today and makes the same connection between the two stations. Currently, only the Grand Central platform is accessible. The Times Square platform will be made ADA compliant by 2022. I am hoping that there is a discussion of the MTA’s plans to spend $228 million on this phase of the project before construction begins and that the money goes toward making many other stations accessible instead.
The MTA has had an about-face in regards to accessibility in the past year. Unfortunately, their funny accounting continues. At a recent meeting to get community input on the next 50 accessible stations, NYCT leadership presented 23 stations they say are already funded and moving forward in the next 1-3 years. But, when excluding duplicates and a station already listed as accessible (and the Times Square S “station”) there are 19 slated for accessibility upgrades. Of these, 10 are key stations (many of which are behind schedule) and the other 9 are new since the key station agreement. They also presented 20 stations they see as a priority for Fast Forward. Excluding duplicates and accounting for partially accessible stations, that number is actually 12.4 stations. Does this mean that Fast Forward promises far fewer than 50 accessible stations in the next 5-year plan? Only time will tell.
*Update: After reading a recent NYDN report that the real number of elevators will be 36 instead of 50, I consulted my notes and noticed that the February 6 presentation for the next 50 stations included 24 groupings of 4 or more stations. Selecting one from each of these groupings would create accessibility “no more than 2 stations away.” Coincidentally (or not) 12.5 unique stations + 24 = 36.5. Are they hedging on their promise of 50 stations by falling back on this 2-station away plan and applying their creative accounting techniques?
The proposed station upgrades are not funded yet, and the budget will impact the number of stations that are made accessible. Maybe the MTA is just hedging their bets to appear that they can still make good on their promise of 50 more stations. However, correcting half-accessible stations should not count as entire new stations when they’re already counted as accessible stations. As the MTA weighs ridership at different stations in their decision-making process, they must have an accurate comparison based on entire stations. Brewer’s report highlights that other ADA features like communication of service information and accessible wayfinding for people with sensory disabilities are lacking in supposedly 100% accessible stations. The MTA must adopt a precise definition of “fully accessible” in both the subways and buses and not exaggerate or inflate the current state of ADA compliance.
FWIW, every system in the country was given two requirements by the ADA:
(a) all new construction and all renovations must be fully accessible
(b) a list of “key stations” must be made accessible, even if there were no plans to renovate them.
NY and Philadelphia had “grandfathered” lists of key stations dating back to the 1980s lawsuits, but NO exemption from the rule that all renovations must be fully accessible.
Every other system in the United States had a key stations list established in 1993, and every other city in the US — including Philadelphia — has finished its key stations list.
Absolutely unique and alone in the US, New York has engaged in scofflaw behavior, renovating stations without making them accessible. Every other city has made stations accessible when they were renovating them for other reasons, as they are required to by law. This is why Philadelphia, Boston, and Chicago already have many, many non-“key stations” accessible.
Only New York broke the law. New York has about 50 stations which were renovated after 1993 and were legally required to be made accessible but were not due to the criminal mindset at the MTA.
Andy Byford, who came from London where they obey the law, is telling the MTA that it’s time to obey the law now. But make no mistake: the MTA has flat out been breaking the law with gigantic renovations of dozens of Brooklyn stations which illegally omitted ADA accessibility. The section of the law which requires accessibility during renovations has nothing to do with the key stations rule, and the MTA’s mentioning the key stations in those lawsuits is frivolous and legally irrelevant.
Thank you for the clarification. I edited to reflect that MTA treats the 100 key station like an exemption, but you are correct that it is not. The Key station agreement grew out of lawsuits, and became an amendment to Section 51 of the Public Buildings Law in 1994 (increasing the number from a 1984 amendment requiring 54 key stations). The MTA is likely to miss their deadline to complete even the 100 key the stations by July 26, 2020.
I agree that the MTA has completely ignored the law, which has finally landed them in court for a pattern of discrimination. They haven’t even pretended to try in most cases, just claiming that it would be too expensive without scoping costs. This has also been an unacceptable excuse given that the ADA requires that stations must be made wheelchair accessible despite the cost when entrances are renovated.
They can only delay for so long. In the most recent lawsuit hearing, in which MTA brought their outside counsel after in-house lawyers were unable to get the case dismissed, the judge made it clear that they need to figure out a timeline to achieve full accessibility.
Specifically, Sec. 37.43 and 37.45 are the sections which require accessibility when any renovations are done. They have nothing to do with the key stations requirements.