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communicate with the vehicle manufacturer about its design, manufacture feasibility and timing; or to<br />

ensure that a realistic schedule is produced in a reasonable period so that opportunities for action are<br />

not foreclosed.<br />

Review the Project Sponsor’s package outlining its proposed method to meet the DOT’s ADA<br />

regulations concerning level boarding for all stations.<br />

6.3 Final Design, FFGA, Construction, Revenue Operations<br />

Upon a determination of feasibility by <strong>FTA</strong>, review the project’s plans and specifications, and conduct<br />

site visits during construction and revenue operations to verify compliance with the Project Sponsor’s<br />

approved level boarding solution for all stations.<br />

6.4 General Information<br />

Concept of “undue burden”<br />

Additional costs associated with achieving level boarding are generally not a factor in the DOT’s<br />

determination of feasibility. However, if these costs become so high that they create an “undue<br />

burden” to the Project Sponsor, these costs would be considered in the DOT’s determination of<br />

feasibility. (Undue burden means that some burden is “due” or expected of the Project Sponsor.<br />

An increase to costs may not rise to the level of undue burden or infeasibility.) There is no<br />

specific cost threshold for an “undue” burden.<br />

DOT’s Level Boarding Team<br />

DOT’s Level Boarding Team includes representatives from OST, <strong>FTA</strong> and FRA. The primary<br />

points of contacts are as follows:<br />

• OST: Assistant General Counsel for Regulation and Enforcement, Office of<br />

General Counsel 202-366-4723<br />

• <strong>FTA</strong>: Director, Office of Civil Rights, 202-366-4018<br />

Chief Counsel, Office of Chief Counsel, 202-366-4063<br />

Associate Administrator, Office of Program Management, 202-366-4020<br />

Associate Administrator, Office of Planning & Environment, 202-366-4033<br />

• FRA: Program Manager, Railroad Operations, Office of Railroad Development,<br />

202-493-6381<br />

Program Manager, Environmental Programs, Office of Railroad<br />

Development, 202-366-6381<br />

Associate Administrator, Office of Railroad Development, 202-493-6381<br />

The Level Boarding Team is a valuable resource that can help the Project Sponsor, PMOC,<br />

<strong>FTA</strong> regional and headquarters staff (i.e., New Starts Team members) identifies and resolves<br />

level boarding issues. Failure to communicate with the Level Boarding Team can result in<br />

project delays (usually at the most inopportune time).<br />

The determination of feasibility or infeasibility of the Project Sponsor’s level boarding<br />

proposal will be made by <strong>FTA</strong> after recommendations from FRA and DOT.<br />

OP 41 ADA Review – Level Boarding for Commuter Rail<br />

Revision 0, June 2008<br />

Page 5 of 6

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