American's with Disabilities Act (ADA) Paratransit Eligibility Policy


Introduction

Titles II and III of the Americans with Disabilities Act (ADA) of 1990 provides that no entity shall discriminate against an individual with a disability in connection with the provision of transportation service. The law sets forth-specific requirements for vehicle and facility accessibility and the provision of complementary ADA paratransit service.

The ADA is a civil rights bill which prohibits all entities from discriminating against individuals with disabilities. A final rule to implement the transportation provisions of ADA was issued on September 6, 1991 by the Department of Transportation. Among the general requirements are:

Public agencies operating fixed-route services are required to establish policies and procedures that ensure compliance to the transportation provisions of the Americans with Disabilities Act. The policies and procedures include the following areas of compliance:
The purpose of this project is to establish internal and external operating policies and procedures for Sunset Empire Transportation District (SETD) to meet the requirements of the Americans With Disabilities Act, as defined by 49 CFR Part 37, "Transportation Services for Individuals with Disabilities" and 49 CFR Part 38, "Americans with Disabilities Act (ADA) Accessibility Specifications for Transportation Vehicles."
Executive Summary
Compliance Issues

A review of all SETD activities to determine compliance with provisions of 49 CFR Part 37 and 49 CFR Part 38 was conducted. It was determined that SETD is largely compliant with all provisions of the aforementioned laws and needs only minor improvements to be fully compliant. Procedures are in place and an active ADA advisory committee exists.

The following are areas where SETD needs to be alert and institute activities: First, SETD exceeds typical service parameters often found in a rural setting for elderly and disabled persons. SETD has a county wide dial-a-ride accessible service which provides a safety net of mobility services for those who do not live within an easy distance of a fixed route or for those who chose a more personalized mode of transit. In addition to the county wide dial-a-ride service, SETD provides complementary ADA paratransit. This has caused some confusion, and led some people to think (before examining the service more closely) that the service is out of compliance. SETD is not out of compliance but SETD's efforts at communicating information about the services have not always been clear.

More than one person has been confused by the fact that SETD provides both county-wide dial-a-ride and complementary ADA service. People have from time to time read information about the dial-a-ride fares and the dial-a-ride trip priorities and wrongly assumed that these applied to the complementary ADA paratransit service. SETD must use extra care in advertising and information sharing about the dial-a-ride and the complementary ADA service. ADA eligible residents of Clatsop County have excellent mobility choices with the availability of accessible dial-a-ride and ADA complementary paratransit, but everyone needs to understand that there are different rules for each service and many of the ADA service rules do not apply to the dial-a-ride.

Data Issues

The service currently does not collect all the data that would be helpful in managing an ADA program. While this is not directly a compliance issue, the service needs to adopt a stance of "data driven" decision making. Since the number of ADA certified people is small the data collection and monitoring should not be burdensome.

Training Issues

In some respects the weakest element of the ADA service is the lack of a systematic training program for new drivers and the lack of refresher courses for existing drivers. While again this is not directly a compliance issue, it can lead to compliance issues. It should be noted that appropriate training does occur and updates do happen, but they are not systematic nor part of an over all driver curriculum.

The remainder of this report sets out information to help remedy the minor compliance issues and meet the terms of the ODOT agreement number 20201.

Background
ADA Service Description Summary

At one time the bus was able to advertise and meet ADA requirements by making available route deviations up to ¾ of a mile on each side of every route. Since traffic has increased and run times are tighter it is no longer realistic to have deviations on all routes. Therefore, a fully compliant and rider ready ADA program is a must.

It should be noted that exceptional service to the elderly and disabled is provided in the service area by means of a county-wide dial-a-ride (DAR) program. This means that even where there is no fixed route service dial-a-ride service is available.

A strong clarification needs to be made between the requirements and the availability of DAR and ADA. The ADA service meets the minimum requirements and is "curb to curb" - an ADA eligible person boards an ADA complementary paratransit vehicle and is taken to a route bus and either completes the trip on the route bus or, after riding on the regular fixed route bus, meets another ADA vehicle to complete their trip.

The DAR service is door to door and has priorities which extend service first to the elderly and disabled and then carries other passengers on a space available basis. Through the combination of ADA service and DAR service residents of the service area who are elderly or disabled enjoy an excellent level of mobility. To help differentiate the three types of service offered by SETD the following table describes the highlights of each service.



Table 1: Sunset Empire Transportation District's Three Services
  ADA Paratransit Service Dial-A-Ride Service Fixed Route Service
Target Population Service for ADA eligible persons (persons with special needs of any age) living within ¾ of a mile of a fixed route. Open to the public though in some areas specific populations such as the elderly or others will be targeted and receive relevant information. General Public.
Type of Service Curb to curb service within ¾ mile of fixed routes. Door to door service throughout Clatsop County. Point to point service. Passengers may board and be dropped off only at designated stops
Assistance to Riders Drivers assist passengers as needed. Drivers may assist passengers with boarding and alighting. Drivers assist only passengers using the lift.
Trip Purpose ADA trips may be for any purpose. Trips may be for any purpose but some priorities for the elderly and disabled and travel to jobs, school or health care may be imposed as the need arises. Trips may be for any purpose.
How Service is Accessed 24 hour advance reservations required and can be made up to 14 days in advance. Drivers do not accept or change reservations. 48 hour advance reservations required and can be made up to 14 days in advance. Drivers do not accept or change reservations. The public may board at any bus stop.
Destination Will take passengers to a transfer point to fixed route service. Will take passengers to their destinations. Will take passengers to a stop along the route.
Late Passengers Driver will wait 5 minutes for passengers except dialysis patients are allowed 20 minutes Driver will not wait for passengers. Driver will not wait for passengers.
Certification Yes Required No Certification No Certification
Fares Twice (2x) fixed route fare Varies by distance $1.25 per bus boarded.
Days of Service Monday-Saturday Monday-Friday Monday-Saturday

To serve the transit needs of those persons qualifying for ADA service SETD operating as "the bus" must address the following three areas:
Compliance
The service must comply with all the regulations of the Americans with Disabilities Act as they apply to the provision of transit.
Readiness
The service must be "ADA Paratransit Rider Ready." That is, the service must be easily accessible by ADA qualified persons and the service must address all those elements that make a service "ADA Paratransit Rider Ready" such as well trained drivers, operable equipment, stops near curb cuts, and a general awareness of the needs of the ADA Paratransit Rider.
Implementation
After the service is fully compliant and ADA Paratransit Rider Ready, all the elements of the service must come together for smooth implementation of services. Brochures and materials in alternative formats, community outreach and partnering, and regular oversight and evaluation mean the program will be a success.
The remainder of this report sets out the necessary approach to achieve compliance, ADA Paratransit Rider Readiness, and implementation for the bus.
Compliance
In general the bus meets the principal requirements of ADA. Complementary ADA paratransit is provided and a process exists to certify individuals. There are several areas where the service could improve compliance and these are noted in the review below. The following questions cover the principal areas of compliance.


Table 2: Complementary ADA Service Overview
1. Please describe how complementary ADA paratransit service is provided. Who administers the program? Who determines eligibility? Who takes the calls? Schedules the trips? Dispatches the drivers? Provides the trips? Provides employee training? Is the service provided in-house or are contractors used? How are contractors monitored to ensure that they comply with FTA and Sunset Empire requirements? Complementary ADA paratransit is provided by SETD staff and vehicles.

Dispatcher administers program. Telephone receptionist answers phone and passes call to dispatcher who schedules the trip.

Training is provided by Operations Supervisor and HR supervisor.

No contractors provide ADA service.
2. What is the process to resolve the complaints regarding complementary ADA paratransit service? Who reviews and responds to the complaints? Compliant policy is to respond within 4 hours and resolve within 48 hours by Operations Supervisor.

Complaint information is reviewed by ADA Advisory Committee and SETD Board of Directors.
3. Does an ADA advisory committee or process exist? How is it structured? What is its role? How frequently does it meet? Advisory Committee meets six times per year and has officers and SETD staff assigned to send out notices and take minutes which are approved by the committee. The committee reviews complaints and any denials of service.
4. Besides ADA eligible persons, what groups are eligible to ride the ADA paratransit service? Only ADA eligible persons ride the ADA vehicles.
5. How many residents are currently eligible for the complementary ADA paratransit service? How many were eligible in each of the last five years? Currently there is one person certified eligible for ADA and five years ago there were no persons eligible.
6. Please describe the fixed route transit system. Days and hours of service? Commuter versus full service routes? Evening and night service? Saturday and Sunday service? Monday through Saturday 6:00 am to 8:20 P.M. service on various routes.

No commuter or Sunday service.


Table 3: Planning and Budgeting
1. Does an ADA complementary paratransit service plan exist? Is the plan being followed? How are client and ADA ridership projections developed? Do projections account for expressed demand, that is, total trips requested including those not served? Since the scope of this service is modest planning for the service that takes place during the budget cycle. Results of this review will form the basis of corrective actions and future activities.
2. Please describe the process used to develop the ADA paratransit budget. Who is responsible for developing the budget? Does the board approve the budget? Executive Director estimates incomes and expenses and submits these to a formal budget committee. The committee takes action and the board approves the budget.
3. Are service standards used to guide the development of the budget? What are the service standards? No. Service standards will be prepared as a result of this review.

(Action: Track on time performance)
4. Is the budget prepared in sufficient time to allow full review and interaction by the board? Yes
5. If any ADA paratransit service is purchased from other entities, what is the nature, duration and method of procurement? No purchased services.


Table 4: Eligibility Determination
1. Does the application, brochure, or another document fully describe eligibility, the application process, and right of appeals? Do the materials state the time frames for deciding eligibility and appeals? No

(Action: New brochure is being developed to better describe service.}
2. Are ADA complementary paratransit eligibility decisions made within 21 days of receipt of a complete application? If no, is presumptive eligibility granted? Are data maintained that indicate that eligibility decisions are made within 21 days? If yes, to whom are the data distributed? Yes
3. Who makes eligibility decisions? Are eligibility decisions based solely on a note from a physician? Dispatcher in charge of ADA makes decision and denials are reviewed by Executive Director and Advisory Committee

Yes
4. Is eligibility strictly enforced or are have ineligible people been allowed to certified as eligible? No ineligible people have been certified.
5. Are ADA riders periodically required to reapply for eligibility? Annually
6. Are picture IDs issued? Who issues the IDs? Card with names.
7. Are persons who are denied eligibility given notice of their right of appeal? Is presumptive eligibility granted if the appeal is not decided within 30 days until eligibility is denied? Yes


Yes
8. Is complementary ADA paratransit service provided to ADA eligible individuals and their personal care attendants (PCA)? Is the PCA charged a fare? Yes PCA is provided service. No fare is charged.
9. Is complementary ADA paratransit service provided to ADA eligible individuals and at least one companion? Additional companions if space permits? What fares are charged to the companions? As space allows

(Action: Need fare policy for more than one companion.)
10. Is complementary ADA paratransit provided to ADA-eligible visitors for up to 21 days? 30 days
11. Is eligibility granted permanently? Are eligibility time limits established for acute disabilities? Is eligibility determined on a trip specific basis? No

Update annually

Temporary disabilities are reviewed every six months (i.e. broken leg)


Table 5: Marketing Materials
1. Is there a ADA rider handbook, a service brochure, or other document that explains how trips are requested and service is provided? Yes, but handout is not 12 point.

(Action: Make sure type is large enough and easy to read.)
2. Are system brochures, application forms, ADA rider handbooks, and occasional bulletins available in alternative formats upon request? Stated in new time tables and in handout. (Action: Make sure availability is mentioned in all materials.)
3. Is the system's TDD number printed on all public materials where your voice telephone number appears? Yes
4. Do the materials state the policy regarding transporting personal care attendants and companions? No

(Action: Include statement in materials.)
5. Do materials explain that ADA paratransit riders are eligible to ride other systems for up to 21 days? No

(Action: Include statement in materials.)


Table 6: Reservations
1. Is next day service provided? If yes, what percent of reservations are made for the next day? Yes

Small percentage not currently measured due to small scope of services.
2. How far in advance can reservations be made? 14 days in advance
3. Are requests for reservations accepted during normal business hours on all days prior to days of service, even if the administrative office is closed? Yes requests are taken during normal business hours and for Monday service on Sunday a tape recorder is used.
4. Has a standard for telephone capacity/performance been established? If yes, what is the standard? Did the board approve the standard? How are data tabulated and reported? Are data reported separately for different times of the day, including peak times, and by type of ADA paratransit rider? What percentage of calls meet the standard? The small demand for this service means there is no wait time on the telephone. Someone always picks up the phone. The standard in place is "No wait time." (Action: Need to establish tracking of calls and service standards.)
5. Are trips scheduled within one hour of requested trip time? Yes
6. Are ADA paratransit rides that are not scheduled in a one-hour window tracked as denials even if the ADA paratransit rider accepts an alternative time? When one leg of a trip cannot be reserved, is it tracked as two denials when the ADA paratransit rider declines the trip? Even the Lot attendant and mechanic have CDLs so no denials.

(Action: Track trips that are not scheduled within one hour of requested time.)
7. What percentage of trips are wait listed? None
8. What is the average telephone wait time for a reservation? 0.

(Action: Total service and ADA would benefit from telephone call management system showing hold times, volume, calls answered, and calls abandoned by time of day.)
9. For next day service, at what time of day are reservations cut off? 5:00 P.M.
10. What are the peak times for reservations? At peak times, can a caller reach the reservation office? Yes, an additional call taker/dispatcher is scheduled during the peak time of 9:00 am - 11:00 am.
11. Are standing order or subscription trips permitted? What is the procedure for booking subscription trips? Yes. Similar to Dial-A-Ride: a rider calls 2 days prior to first trip, provides trip and billing information, and dispatcher tells person how soon rides are available. Rider calls once at the end of the month to confirm rides for next month. Coast Rehabilitation is excepted from this as they have an annual contract.
12 If non-ADA eligible riders are permitted to use the ADA paratransit service, do ADA paratransit riders have priority? ADA priority for subscription trip status? Yes
13. Has a separate telephone number been established for cancellations? Yes


Table 7: Scheduling
1. How are initial trips scheduled? Are trips scheduled by reservation agents or separate schedulers? Reservation agents (the dispatcher) schedules the trip at a specific time.
2. How are return trips scheduled? "Will call" process is used with a tentative time pre-set at time of scheduling initial trip.
3. Are requests that cannot fit into a run put on a holding run and then manually scheduled? No denials exist for this system.
4. What types of checks of runs are conducted? Does a scheduling supervisor or lead scheduler review the schedules? Are runs reviewed to ensure that they are not overbooked and that ADA paratransit riders are assigned to vehicles that are appropriately equipped to serve them? Yes, Driver Supervisor reviews runs.
5. Are exception reports developed for trips that exceed ADA paratransit time or other standards? Currently there is no standard for ADA paratransit time and no complaints about the service. (Action: Establish standards for ADA paratransit time.)
6. If trips are added manually, what is done if the additions change the time of trips already on the run? If pickup or drop-off times are moved beyond the pickup window, are callbacks to ADA paratransit riders made? ADA paratransit times are not changed once scheduled. All ADA paratransit riders are called the day before their scheduled trip to confirm their trip time
7. What data appear on the drivers' manifest? Are original agreed upon pickup times shown, or are scheduled times shown? Actual agreed upon scheduled time and appointment time is shown on the manifest.
8. How are changes in time handled as subsequent calls are received? ADA paratransit riders are called to confirm times but, once scheduled, times are not changed.
9. If times originally given to ADA paratransit riders are changed, are they always kept within the pickup window? Times are not changed.
10. If times are adjusted outside the window, are callbacks made to customers? If yes, what is the success rate in reaching customers to change times? What is the policy if the customer cannot be reached? Written record of people called and contacted is maintained. Times are not changed.
11. What accommodations are made for people with hearing impairments? TDD


Table 8: Service Characteristics
1. Is complementary ADA paratransit service within ¾ miles of fixed routes and the core service area? On Saturdays, Sundays, and holidays? Yes service is offered during all times that regular service is offered.
2. At a minimum, is curb-to-curb service provided? Yes
3. Is service provided the same days and hours as fixed-route service? On Saturdays, Sundays, and holidays? Yes
4. Are the fares no more than twice the fares for fixed-route service? Yes
5. Are there restrictions or priorities based on trip purpose? No priorities or restrictions on trip purposes for ADA service.
6. Is there excess non-subscription capacity? If no, does subscription service exceed 50 percent of available resources? How is this capacity monitored? No. Capacity is monitored by dispatcher in charge of ADA.


Table 9: Service Policies
1. What is the policy for providing service if a mobility device cannot be secured? All secured - Upgraded all straps to new system.

(Action: Need policy on devices that can not be secured.)
2. Are wheelchair users required to transfer to a seat? Not required
3. Do drivers provide assistance to passengers as necessary and upon request with ramps, lifts, and securement devices? Yes
4. Are individuals that do not use wheelchairs permitted to use lifts? Yes
5. What is the policy regarding service animals? Yes service animals are welcome.
6. Is service provided to persons using respirators or portable oxygen? Yes
7. What is the policy regarding the time allowed for boarding and alighting? None. Passengers board and alight at a pace they feel comfortable with.
8. Are drivers required to make use of all available accessibility equipment? Yes
9. How are ADA policies conveyed to drivers? In service training and training before assigned to vehicle. (Action: Need more systematic training.)
10. How are ADA policies conveyed to contractors? No contractors.
11. What is the no-show policy? Is there a policy for suspending eligibility for persons who chronically do not show? No current policy.

(Action: Adopt three strikes rule of Dial-a-Ride.)


Table 10: Training
1. Please describe the training program for drivers. Customer Service, Defensive Driving, Drug & Alcohol, Passenger Assistance, CPR, First Aid
2. Are drivers trained in passenger assistance and sensitivity? How soon after being hired does the training occur? Passenger sensitivity training is provided in the first two weeks.
3. Are drivers trained in use of accessibility equipment? How soon after being hired does the training occur? Trained in their use immediately in initial training during first two weeks of employment before going on route.
4. How often do drivers receive refresher training? Annually

(Action: HR Director needs to track training more closely.)
5. Is there an ADA complementary paratransit operator's manual? Does it fully address ADA requirements? No

(Action: Prepare simple guide for drivers.)
6. How are drivers monitored to ensure that they comply with ADA requirements? Infrequent

(Action: Need systematic monitoring program.)
7. How are drivers who fail to comply with ADA and other service policies disciplined. Through standard disciplinary process but there have been no problems.
8. Please describe the training program for reservation agents. Not systematic.

(Action: Develop training for all staff who answer phones and work with ADA passengers.)
9. Are agents trained in passenger assistance and sensitivity? How soon after being hired does the training occur? No

(Action: Develop training.)
10. Do agents receive refresher training? How often? (Action: Develop training.)
11. Is there a policy or service manual for reservation agents? If not, how are policies documented and conveyed to the agents? (Action: Develop simple manual with checklist of key points.)
12. How are agents monitored to ensure that they comply with policies governing comportment and dealing with customers? Dispatchers have been known to make special efforts to meet each ADA paratransit rider so there is not concern for the issue in this question.

(Action: Develop monitoring program.)
13. How are agents that fail to meet requirements disciplined? Through standard disciplinary process but there have been no problems.
14. Has a travel training program been established for ADA-eligible riders who may be able to use the fixed route system for some trips? (Action: A travel training program should be developed.)
15. Who provides training to contractors? How are contractors monitored to ensure that proper training is provided to contractor employees? N/A
16. How are contractors monitored to ensure that they comply with ADA requirements? N/A


Table 11: Service Standards and Monitoring
1. Has a standard for trip denials been established? If yes, what is the standard? Did the board approve the standard? What percent of requests are denied? How are data to determine the number of denials collected and reported? Are data reported separately for different times of the day, including peak times? How are trip denials monitored? There are currently no denials.

(Action: Prepare standards for denials and tracking.)
2. Has a standard for on-time performance standard been established? If yes, what is the standard? Did the board approve the standard? How are data to determine the number of denials collected and reported? Are data reported separately for different times of the day, including peak times? How is on-time performance monitored? What is your on-time performance rate? On time performance has not been a problem.

(Action: Prepare standards for on time performance and tracking.)
3. Has a standard for missed trips been established? If yes, what is the standard? Did the board approve the standard? How are data to determine the number of missed trips collected and reported? Are data reported separately for different times of the day, including peak time? How are missed trips monitored? What percent of trips are missed? Missed trips have not been a problem.

(Action: Prepare standards for performance and tracking.)
4. Has a standard for excessively long trips been established? If yes, what is the standard? How are data to determine the number of missed trips collected and reported? Are data reported separately for different times of the day, including peak times? Did the board approve the standard? How is trip length monitored? Long trip performance has not been a problem.

(Action: Prepare standards for performance and tracking.)
5. Are data on performance routinely summarized for and reviewed by senior management? The board? Does the reporting system contribute to each level of management in terms of timely, accurate, appropriately detailed information required to support management action? (Action: Prepare standards for on time performance and tracking.)


Table 12: Maintenance
1. Who maintains the vehicles? Where are they maintained? On site
2. Is there a written maintenance plan? Does the plan address maintenance of ADA accessibility features? Yes
3. What is the preventive maintenance program for lifts and other accessibility features? Does the program meet manufacturer minimum requirements? Meets manufacturer requirements.
4. Do preventive maintenance checklists address ADA accessibility features? Yes
5. Is there a regular system of checks for lifts? Do pre-trip inspections address lifts, tie-downs, web-cutters and other ADA accessibility and ADA-related safety features? Are lifts cycled as part of the pre-trip inspection? Yes

(Action: Need on board web cutters.)
6. Are deficiencies noted in pre-trip inspections repaired in a timely manner and properly reviewed by management? Yes
7. When a lift is found to be inoperative, is the vehicle taken out of service by the beginning of the next service day and repaired before returning it to service? If a vehicle with an inoperable lift is kept in service, is it repaired within 3 days from the day which the lift is found to be inoperable? Yes, if possible. Service has backups so lifts are always available..
8. Does the pre-trip inspection address safety; vehicle operation, appearance, and cleanliness; and passenger comfort? Yes
9. If vehicles are maintained by contractors, are written maintenance plans required? Have the plans been reviewed to ensure that the program complies with ADA requirements? How are contractors monitored to ensure that ADA fleets are maintained in accordance with Sunset Empire requirements? N/A


Table 13: Fleet Characteristics
1. What is the size of the ADA paratransit fleet? What percentage of the fleet is accessible? 100%
2. What is the spare ratio? The spare ratio equals c divided by b, where: .86
a = the number of revenue vehicles 26
b = the number of vehicles required for maximum service 14
c = the number of spare vehicles (a minus b) 12
3. If you have non-accessible vehicles in your complementary ADA paratransit fleet, how is it ensured that equivalent service is provided? N/A
4. Are all accessible vehicles marked with the blue accessibility symbol? No

(Action: Label all vehicles with lifts.)
5. Do all accessible vehicles have a securement system for wheelchairs? Yes
6. What is the average age of the fleet? 4 years
7. Is there a vehicle replacement plan? Yes


Table 14: Information Technology
1. Do deficiencies exist with the current computer software used to reserve, schedule, dispatch, and report ADA paratransit ridership? Vehicle maintenance? Yes - No GIS or vehicle locator system. Scheduling system is adequate to size of service and level of demand.
2. Do plans exist to upgrade the existing software or hardware? Nothing in budget
3. What training programs exist in the use of program software? No training
Summary of Action Areas from Complaince Checklist
This portion of the report summarizes the improvement recommendations for the ADA paratransit program at SETD.
Fundamentally, SETD's mission is to provide safe, reliable, responsive, and cost-effective ADA paratransit services that meet ADA rules and funding agency expectations. The challenges are to focus employee efforts, to anticipate problems, to empower staff to develop and implement improvements in a collaborative way, and to base decisions on hard facts.
Overall Recommendation:
Let data drive improvement. Focus employee effort on key measures of success. All employees need to be aware of the status of key performance data on a daily basis.
Peter Schauer Associates recommends the following data as key measures of success. SETD has procedures to collect this data and provides reports containing most of the information in summary fashion on a monthly basis. In order to influence the quality of daily operations, we recommend that the data be charted on a daily basis and monitored daily by employees with responsibility to act upon the information.
  1. Customer Service Quality:
    1. Missed Trips
    2. Excessively long trips (over 1 hour)
    3. Early/Late Trips (over 15 minutes)
    4. Blocked phone calls (all busy)
    5. Call wait time
    6. Complaints
    7. Accidents
    8. Response time to vehicle failure2
  2. Productivity:
    1. Total trips taken
    2. Passengers per vehicle hour of service
    3. Passengers per vehicle mile of service
    4. Average miles per passenger
    5. Average passengers per seat mile
    6. Number of passenger trips placed on taxis
    7. Passenger No shows
    8. Passenger Cancellations
  3. Cost Effectiveness2
    1. Cost per trip
    2. Cost per vehicle hour of service
    3. Cost per vehicle mile of service
    4. Revenue per vehicle hour of service
    5. Revenue per vehicle mile of service
    6. Cost Recovery (Revenue as a percent of cost)
    7. Operator pay hours per vehicle hour of service
In this context, the recommendations made in this report should be viewed as suggested actions designed to improve performance on the identified measures. Employee teams will probably identify many more detailed actions that will also contribute significantly to improvements in key measures.
Quality Assurance.
In order to improve service quality, schedulers and dispatchers need to implement a daily review of runs having missed trips, excessively long trips, and early/late trips, and to adjust schedules once a recurring problem is identified. Early/late trips are currently defined as 15 minutes prior to or beyond the promised pick up time. Management should empower a team consisting of a scheduler and a dispatcher who routinely handle ADA service to collect the data, conduct daily reviews, and implement improvement. Management should inspect the daily chart showing the number of missed, long, and untimely trips.
Role of Dispatchers/Scheduler.
SETD has at least one dispatcher on duty on weekdays between 7 A.M. and 5 P.M. and 1 dispatcher on duty Saturday between 8 A.M. and 4 P.M. The dispatchers complete all assignments and reports manually. Given the absence of ADA paratransit schedulers on Sunday SETD has an answering machine to take calls which is working satisfactorily. SETD also uses the answering machine satisfactorily for after hours calls.
Role of Drivers.
It is critical that drivers establish radio contact with dispatchers when they anticipate arriving for the next scheduled pickup more than 15 minutes early or late. This will enable the dispatchers/schedulers to improve the driver manifests quickly if warranted and to provide relief designed to get the run back on schedule. Although drivers are instructed to contact the dispatcher when the service is early or late, this does not appear to be happening.
Telephones.
Blocked calls and average call wait time are measures of adequate capacity and staffing of the phone system. No distinction is currently made among calls to cancel service, confirm service, book trips, obtain information, or file complaints and data on blocked calls or average wait time is not measured although anecdotally and by observation it appears it is not currently a problem.

In the future as call volume might warrant a new phone system should be acquired. Under any new phone system, it is recommended that ADA paratransit service institute a call directory process that segregates short cancellation calls, reservation calls, trip confirmation calls, and other calls. The directory should be voice activated.
Cancellations.
ADA paratransit cancellation data does not distinguish between a "harmless" cancellation, i.e. one that occurs before the scheduling process is complete, and a "late" cancellation. It is recommended that a new data category, "late cancellations" be established and monitored. A workable definition is any reservation that is cancelled after the trip is assigned to a specific run. ADA paratransit should develop a disciplinary process for customers who persistently cancel late.
ADA paratransit currently accepts reservations up to 14 days prior to the date of service. ADA paratransit does not currently track the frequency distribution of reservations during the 14 day period. ADA paratransit does not know the relationship between early reservations and late cancellations.

Federal ADA regulations require that reservations for next day service be accepted as long as the administrative offices are open and this is done Monday - Saturday
Customer Services
Several key customer service activities need to take place. A new brochure is needed outlining the ADA program and including several key elements including: Make sure type is large enough and easy to read in all printed material, Make sure alternative format availability is mentioned in all materials, Develop new brochure to better describe ADA service and differentiate from Dial-a-Ride, Include in materials a statement of policy regarding transporting personal care attendants and companions, Include statement in materials that ADA participants are eligible to ride other ADA paratransit systems for up to 21 days.

One of the most helpful customer service activities for SETD to offer is a travel training program for Clatsop County residents. The travel training program would help make people more comfortable with the fixed route service and lessen the demand for ADA paratransit services.
Implementation and Policy Issues
There is a need for a policy for more than one companion. In the federal regulations, a personal care attendant (PCA) is defined as someone designated or employed specifically to help the eligible individual meet his or her personal needs and is eligible to rider free. These needs do not have to include facilitating travel. Federal regulations provide a distinction between a companion and a PCA. A companion does not count as a PCA unless the eligible individual regularly makes use of a PCA and the companion is functioning as the PCA.
Recommended Policy:
The bus defines a Personal Care Attendant (PCA) as a person traveling as an aide to an ADA eligible rider. During the ADA certification process the bus certifies whether an eligible individual is approved to travel with a PCA. PCA's always ride free as they accompany the eligible ADA passenger. All certified ADA riders may also travel with a companion (s) as space is available but the companion must pay the same fare." There is a need for a policy on devices that cannot be secured.
Recommended Policy:
"Wheelchairs must be secured during transport as a condition of receiving service to protect both the wheelchair passenger and other passengers in case of an accident. However, service cannot be denied on grounds that a mobility device cannot be secured to an operator's satisfaction.. When transporting users of thee-wheeled wheelchairs, scooters or other mobility devices that pose a securement problem operators should request and encourage the user to transfer to a seat because of the general instability of these devices. However, users are not required to transfer to a seat.
Demand for Services
There are two principal ways to estimate demand for services. First through modeling and statistical manipulation of appropriate data. Second and more reliably, but more costly, is to run a demonstration and see what demand develops. In fact the SETD has been running a demonstration by being in operation for some years and generating one ADA certified individual. Five years ago no one was certified and the apparent reason is straightforward. Most persons who seek public mobility solutions and who might be ADA eligible have been using the Dial-a-Ride services and indeed "SETD has signed-up 1,150 elderly and disabled clients to use the service" (Public Transportation Comprehensive Transportation Plan, SETD, April 11, 2001 Page 2-13).
The Public Transportation Comprehensive Transportation Plan prepared for SETD in 2001 did not estimate the demand for ADA enrollment, ridership or general public ridership.
For estimation purposes data from a survey conducted in Seattle. (Forecasting Demand for Paratransit Required by Americans with Disabilities Act. David Koffman and David Lewis. Transportation Research Record Number 1571. Transportation Research Board. National Research Council. Page 68-69.) The survey revealed that 1.8 percent of the population is eligible for ADA services and while the transference of urban data to a rural setting is not completely satisfactory, no rural statistics are available and hence the following formula presents the estimated number of ADA eligible persons living within ¾ of a mile of either side of the fixed routes.


Table 15: Estimated ADA Eligible Persons
Total Population of Clatsop County 35,586
Estimated Population living within ADA fixed route catchment area 25,586
1.8 Percent Estimated Eligible Persons 461
60 Percent Estimated "would use ADA" 277
Additional visitors for the Lewis and Clark Commemoration are estimated by one study to be 200,000 persons (Lewis & Clark Shuttle Feasibility Study. Lewis & Clark Bicentennial Transportation Committee. October 2000. Page 1-2.) and using a modal split of .5 percent for visitors traveling to Clatsop County using public transportation modes gives an estimated number of additional potential transit riders of 1000. Using the Seattle data to estimate the number of ADA eligible riders gives us 18 persons.
Total estimated ADA eligible persons living and visiting in the SETD ADA catchment area is 295 persons. This number of persons can be served with the current service structure of SETD and especially as long as the ambitious dial-a-ride service is continued. If any major restructuring or elimination of the dial-a-ride service was conducted a major increase in the number of ADA certifications could be predicted. Until such time as that happens the low rate of ADA certifications is likely to continue and the service and ADA policies in place are adequate.
Application and Appeals Process
An application and appeals process exists and is contained in Appendix C
. Public Information.
Public information about the ADA service is contained in the time table for the bus. It is identified in the colors blue and white to signal ADA information. An additional special ADA brochure is contained in Appendix D.
Monitoring Fixed Route Compliance
In order to monitor compliance with fixed route activities that are key to ADA compliant service, the Operations Manager (or designee) will observe and ride with each driver at least two times per year. In addition, twice annual random checks will be conducted by the Executive Director (or designee). Observation of checking of lifts, announcements of stops, and use of lifts will be observed and notes entered into a road observation report which will become part of the driver's personnel record. Finally, as part of the overall community involvement, ride check sheets will be distributed to members of the ADA advisory committee, and they will be encouraged to return check sheets at the quarterly (or more frequent) advisory meetings.
Monitoring of Lift and Equipment Maintenance
The lifts must be properly maintained and records indicating inspections and repairs must be kept. The operations manager should review on a daily basis the availability of lifts in the fleet, breakdowns of a repetitive nature, repairs and recall notices. These items should be added to the daily maintenance report received by the Operations Manager from the mechanic.
Facility Plan
All current facilities of the bus are accessible. As accessibility features are added to the new or remodeled facilities maintenance checklists should be added to the regular preventative maintenance programs conducted by the mechanic. These features might include elevators, automatic doors and other features. None of these features currently exist at the bus but if they are added the Operations Manager should add these to the regular preventative maintenance and daily inspection programs in place.
Complaints, Incidents and Lawsuits
A compliant process exists but it is in need of refinement to ensure a more rapid response.
Recommended Policy:
Within one hour of receiving any complaint the bus staff will contact the person making the complaint, seek additional information, and inform them that an initial resolution will be received by them within 24 hours.
If the person making the complaint is not satisfied with the initial resolution they can request a meeting with the executive director and director of human resources which will occur within seven days after the first "24 hour" resolution attempt. If the person making the complaint is not satisfied with the meeting and written explanation or resolution offered by the executive director the person making the complaint may choose to submit their complaint in writing to the SETD Board of Directors, 465 N. E., Skipanon Drive, Warrenton, OR 97146 for resolution. The person making the complaint, at their request, will have the right to meet with the Board to present additional information and arguments at an open, public meeting. Anyone needing special accommodations may contact the District Offices for assistance. (1-800-776-6406)
The decision of the Board of Directors must be made within 30 days and will be in writing or in an accessible format, and include the reasons for the finding. The decision of the governing body is final.
A record of action taken on each request or complaint must be maintained as a part of the records or minutes at each level of the grievance procedure.
The right of the person making the complaint to a prompt and equitable resolution of the complaint must not be impaired by the pursuit of other remedies, such as the filing of a complaint with the Department of Justice or other appropriate federal agency or the filing of a suit in state or federal court. Use of this procedure is not a prerequisite to the pursuit of other remedies.
All complaints which are filed with the Board of directors will also be filed with ODOT and FTA as appropriate.
Certain incidents such as deaths resulting from activities associated with FTA funded activities must be filed promptly with the appropriate FTA regional office. ODOT and other funding agencies should also be promptly notified of serious incidents resulting in significant property damage or loss of life.
Recommended Policy:
Within two hours of any loss of life resulting from activities associated with FTA or ODOT funded activities, the SETD board of directors, appropriate FTA and ODOT officials will be notified. Within two days any property damage over $5,000 will be communicated to the SETD board of directors and appropriate ODOT, FTA and other relevant agencies.
Advisory Committee
During the period of the research and preparation for this report an ADA advisory committee was established and their activities have been especially helpful in implementing requirements of ADA. The advisory committee has reviewed service efforts, prepared public information in support of ADA activities and reviewed the compliance report which was presented at one of their regular meetings. The continuation and active involvement of the ADA advisory committee is critical to continuing services that are responsive to the needs of the community and several on going tasks should be shared with the committee. The tasks are
Compliance Review
At least every three years SETD should request an outside ADA review by ODOT representatives or contract to have a review conducted by competent caring professionals.


Table 16: Summary of ADA Recommendations for SETD the bus
Goal Key Measures Strategies Tasks Responsibility
Customer Service Quality: Reliability Number Missed Trips Track and monitor performance Create scheduler-dispatcher team to chart key measure data daily. Place in visible location. Scheduler-dispatcher team
Number Excessively long trips (over 1 hour) data Initiate daily quality assurance reviews Review daily performance, revise manifests, develop improvement strategies Scheduler-dispatcher team
On-time performance (% >15 min. +/-) Create time for daily quality assurance reviews of previous and next day runs Schedule service 2 days in advance rather than 1 day Operations Manager
Identify and correct operational problems on the road Train drivers to call in late or long trips as they occur. Revise work assignments to restore schedule. Dispatchers
Customer Service Quality: Responsibility Number Blocked phone calls (% all busy by time of day) Adjust manpower to call demand. Purchase Automated Call Distributor (ACD) devise to monitor call volume Assistant to Director
Call wait time (% answered within 1 min.) Direct calls by type (cancel/revise existing, schedule new, complaint) based on estimated call length Chart and review ACD data daily. Revise manpower to reduce delay. Operations Manager
Customer Service Quality: Safety Number of Accidents   Chart and review Operation Manager
Response time to vehicle failure Chart and review Operations Manager
Productivity Total trips taken Schedule trip to maximize customer trips per unit of service Track and monitor performance on key productivity measures daily Operations Manager
Passengers per vehicle hour of service
Passengers per vehicle mile of service
Average passengers per seat mile
Review all runs on regular basis to improve poor performing runs Operations Manager
  Passenger No shows Minimize the Negative impact of no shows and cancellations on service productivity Track, Chart and monitor no shows and cancellations daily Dispatcher
Modify manifests as cancellations are received. Schedulers and dispatchers
Passenger Cancellations Adjust scheduler and dispatcher coverage to revise manifests and notify drivers of changes Operations Manager
Cost Effectiveness Cost per trip
Cost per vehicle hour of service
Cost per vehicle mile of service
Revenue per vehicle hour of service
Revenue per vehicle mile of service
Cost Recovery (Revenue as a percent of cost)
Operator pay hours per vehicle hour of service.
Monitor Service Chart and Review Data Operations Manager and all staff
Customer Service Make sure type is large enough and easy to read in all printed material Review all printed material directed to elderly and disabled persons Use 12 point type or larger Assistant to Director
Make sure alternative format availability is mentioned in all materials.   Implement procedure Executive Director
Develop new brochure to better describe ADA service and differentiate from Dial-a-Ride   Adopt recommended brochure Executive Director
Include in materials a statement of policy regarding transporting personal care attendants and companions   Adopt recommended policy Executive Director
Customer Service Include statement in materials that ADA participants are eligible to ride other ADA paratransit systems for up to 21 days.   Adopt recommended policy Executive Director
A travel training program for Clatsop County residents should be developed.)   Adopt recommended policy Executive Director
Implementation and Policy Need fare policy for more than one companion.   Adopt recommended policy Executive Director
Need policy on devices that can not be secured.   Adopt recommended policy Executive Director
For no-shows adopt three strikes rule of Dial-a-Ride   Adopt recommended policy Executive Director
Label all vehicles with lifts with international symbol for accessibility   Adopt recommended policy Executive Director
Need more systematic training drivers, call takers and dispatchers and tracking of training.   Adopt recommended policy HR Director
Prepare simple guide for drivers on ADA service   Adopt recommended policy  Executive Director
Need on board web cutters.   Purchase web cutters and provide training in use Operations Manager
Road Observation reports for fixed route drivers to ensure ADA compliance Compliance with ADA procedures Ensure that Operations Manager (twice a year) and ADA Advisory Committee (quarterly or as needed) are completing road observation reports HR Director
Lift Maintenance and records Adequate number of lift equipped vehicles must be available during all service hours. Add data entries to daily maintenance report prepared by mechanic for review by operations manager. Operations Manager
Maintenance of Accessible Facilities Compliance with ADA and functioning accessibility features As accessibility features are added to new or remodeled facilities create monitoring, inspection and maintenance programs Operations Manager
Complaint process Goal is speedy and responsible resolution of all complaints Adopt and implement recommended complaint process Executive Director
Reporting of Accidents, incidents and complaints to appropriate officials, Inform appropriate officials of significant accidents, incidents and complaints. Adopt and implement recommended accident, incident and complaint official notification process. Executive Director
Active ADA Advisory Committee Make sure committee is inclusive of all appropriate community groups Meet at least quarterly with ADA advisory committee and facilitate real tasks for committee such as monitoring service, rider training and community information sharing. Executive Director
Periodic Comprehensive Review of ADA activities ODOT or other reviewer ensure compliance with ADA At least ever three years conduct an outside review of compliance and performance of ADA activities. SETD Board of Directors


Appendix A Recommended ADA Driver Training


Recommended ADA Driver Training
Program Elements Suggested Hours Comment
Customer relations 2 Classroom to include welcome, general orientation to the bus and how to relate to customers.
Drug and Alcohol 1 One hour required by law.
Sensitivity and orientation to passenger disabilities and needs 8 Four hours of classroom and four hours of behind the wheel training.
Defensive driving 8 Four hours classroom and Four hours behind the wheel.
Passenger handling and care 4 One hour classroom and three hours behind the wheel
Vehicle handling and care and emergency procedures (vehicle evacuation and more) 6 Two hours classroom and four hours behind the wheel
Loading, unloading and securing wheel chairs and more 6 Two hours classroom and four hours behind the wheel.
Service area familiarity and map-reading 1 One hour classroom and also covered during behind the wheel training.
CPR and infant CPR 4 Classroom
Seizure and infant seizure 4 Classroom
Emergency first aid and blood-borne pathogens 4 Classroom
Record-keeping and incident/accident reporting 4 Two hours classroom and two hours during behind the wheel
Radio procedures and communications (including 10 codes) 2 One hour classroom and one hour behind the wheel
Total hours designated to topics 54 22 of 54 hours covered in behind the wheel training
Total hours for behind the wheel one on one training 88 (minimum) 32 hours classroom and 110 hours behind the wheel
Net Training Hours 120 15 days of training


Appendix B Driver Guidelines for ADA Service


Over 40 million people in the U.S. have some form if physical or mental impairment which limits major life activities. The Americans with Disabilities Act of 1990 (ADA) is a civil rights law for people with disabilities which ensures equal access to public transportation. As transportation professionals, we deal with people with a wide range of these disabilities including individuals with mental retardation, hearing and visual impairments, and mobility problems requiring wheelchairs, canes, etc. The special needs of these individuals require simple courtesy, patience, and consideration as well as an understanding of our responsibilities under the law as bus operators. SETD's policies for transporting the disabled follows:
  1. Operators must check and test the lift and securement system on all wheelchair runs before pulling out of the garage in the morning and lift failures must be reported immediately.
  2. If the lift does not operate properly for passengers in wheelchairs, operators must contact the dispatcher or a supervisor for further instructions. The passenger must be informed of the action to be taken to resolve the transportation problem.
  3. Wheel Chair Procedures:
    1. When boarding, passengers in wheelchairs or three wheel scooters should be encouraged to back onto the lift to facilitate lift operation.
    2. Wheelchairs must be secured during transport as a condition of receiving service to protect both the wheelchair passenger and other passengers in case of an accident. (Service cannot be denied on grounds that a mobility device cannot be secured to an Operator's satisfaction.)
    3. A wheelchair passenger may refuse the seat and shoulder belts but Operators should encourage their use. (Seat belt and shoulder harness cannot be used in lieu of the other securement belts.)
    4. Federal regulations require passengers in flipseats over the wheelchair locations to move for wheelchair passengers, upon request of the driver.
  4. When transporting users of three-wheeled wheelchairs, scooters, or other mobility devices that pose a securement problem, operators should request and encourage the user to transfer to a seat because of the general instability of these devices. Users, however, are not required to transfer to a seat.
  5. Priority seating for the disabled and elderly is available at the front of every bus and federal regulations require other passengers to move from these seats to accommodate the elderly/disabled.
  6. Operators upon request or whenever needed should use the kneeling device on the bus for all individuals who have difficulty using the front stairs.
  7. Individuals with walkers, canes, crutches, etc. who cannot enter the bus using the stairs must be allowed to use the wheelchair lifts on all buses with the exception of the 8500 series bus.
  8. Operators shall not refuse a passenger the use of a lift to disembark at any designated stop unless the lift cannot be deployed, damaged if deployed, or conditions at stop preclude the safe use of stop by all passengers.
  9. Operators must allow adequate time to allow individuals with disabilities to complete boarding or disembarking from their vehicle.
  10. Stop Announcement
    1. Operators must make announcements of at least transfer points, major intersections and destination points, and intervals along the route to permit individuals with visual impairments or other disabilities to be oriented to their location.
    2. Operators must announce any stop upon request of an individual with a disability.
    3. Operators must announce the route they are operating at all major stops, where more than one route serves the same stop.
  11. Individuals with disabilities are all allowed to travel with service animals, including guide dogs and other animals trained to assist them. Individuals are also allowed to travel with respirators, portable oxygen, and other portable life support equipment.
  12. Service for any passenger can only be refused if a rider engages in violent, seriously disruptive, or illegal conduct. Seriously disruptive behavior does not include behavior or appearance that only offends, annoys, or inconveniences other riders or employees.


Appendix C: SETD Application and Appeal


SUNSET EMPIRE TRANSPORTATION DISTRICT
SETD Special Services

Application

By Filling out this application we can determine if you are eligible for the following special services offered by the SETD:

PART 1. PERSONAL INFORMATION Please Print Clearly

Name_____________________________ __________________________ ____________________

Last Name First Name Middle Initial

Address_____________________________________ ______________________________________

Street Address & Apartment Number (if any) Complex/Building Name (if any)

City_________________________________ State_______________ Zip Code________________

Social Security Number (Optional) _____ _____ ________ Date of Birth______________________

Home Phone___________________________ Work Phone__________________________________

PART 2. MOBILITY EQUIPMENT AIDS OR ASSISTANCE

1.     Will you use a wheelchair or scooter when riding?   Yes   No    Sometimes

a. If yes or sometimes, which device will you use?

Manual Wheel Chair    Motorized Wheelchair    Scooter

b. If yes or sometimes, can you transfer to a seat in a vehicle?    Yes    No

2.     Will you use any of these aids when riding? (check all that apply)

Cane, White Cane, Walker or Crutches    Portable Oxygen

Communication Aid Service    Animal    Other __________________________

3.     Will you be accompanied by a Personal Care Attendant (PCA) when riding?
(A person who may provide assistance during the ride or at the destination.)

Yes     No     Sometimes

Sunset Empire Transportation District 1-800-776-6406

PART 3. APPLICANT'S ABILITIES AND NEEDS

4.     What is your disability or health condition? (Please explain fully)









5.     Is your need for special services. . . . . .

Permanent? (Life-long)

Temporary? (Provide your best estimate in months ______________________________)

Other ? (Please explain) ___________________________________________________________

6.    Do you currently use SETD bus service?

No, never use    No, used to ride,     but stopped

Yes, for all trips     Yes, for some trips, or some of the time

7.     Indicate your ability to do each of the following on your own:

  1. Can you get on or off a bus by using the steps?
No I use a wheelchair or scooter. (If you marked this box – skip to question c.)

No     Yes Sometimes    Don’t Know
  1. Can you maintain your balance while standing?
No     Yes Sometimes    Don’t Know
  1. Can you get to or from the bus stop nearest to your home?
No     Yes Sometimes    Don’t Know
  1. Can you wait up to 15 minutes at a bus stop?
No     Yes Sometimes    Don’t Know
  1. Can you communicate with a bus driver yourself or with the help of an aid?
No     Yes Sometimes    Don’t Know
  1. Are there other conditions which limit your ability to use the bus?
I get confused or can’t remember where I am going

The ground is too uneven or steep

I am incontinent or need a restroom frequently

Other: Please Describe ______________________________________________________

8. How far can you walk or travel (with your wheelchair or scooter) by yourself?

  1. I can go _______city blocks on my best day.
  2. I can go _______city blocks on my worst day.
PART 4. CONTACT PERSON

Provide the name of a person we can contact about your rides or in an emergency.

Name of Contact(s) ______________________________________________________________________

Relationship to Applicant _________________________________________

Phone Number (s) ________________________________________________________________

Does the applicant require someone to receive them at the destination?     No     Yes

If yes, the contact person you listed above will be called if no one is available to receive the

Applicant at the destination.

PART 5. APPLICANTS CERTIFICATION

I certify that the information in this application is true and correct. I understand that providing false information may

result in denial of service as well as a penalty under the law. I understand all information will be kept confidential and disclosed only as needed in order to provide services.

I understand that it may be necessary for me to participate in an in-person evaluation to determine my eligibility for

SETD’s Special Service.

Applicant Signature: _____________________________________________ ____________________

(Signature of Applicant or Responsible Party) (Date Signed)

If someone completed this application for you or assisted with this application, please provide the following information:

Name of Person(s) __________________________________________________________

Relationship to Applicant ____________________________________________________

Phone Number(s) ___________________________________________________________

SETD may contact this person for additional information about the applicant.

PART 6.. PROFESSIONAL CERTIFICATION

It is necessary for SETD to contact a professional who is familiar with your disability or health condition and your abilities or limitations. Please list a professional we can contact. (Examples: Physician, Case Manager, Therapist, Social Worker)

Name and Title of Professional ______________________________________________________________________

Telephone Number of Professional ____________________________________________________________

I authorize the Professional listed above to release to SETD information about my disability or health condition and its effect on my ability to use a bus. I understand that I may revoke this authorization at any time.

Applicants Signature: ________________________________________________ Date ___________________

(Signature of Applicant or Responsible Party)





ADA Paratransit Eligibility Policy

Approved: _______________

Purpose:

This policy is required by rules administered by the Federal Transportation Administration to implement the provisions of the Americans with Disabilities Act (ADA) passed in 1990. The rules require fixed-route transit agencies to provide services for disabled passengers comparable to those offered other riders.

Definitions:

Paratransit
Means comparable transportation service required by the ADA for individuals with disabilities who are unable to use fixed route transportation systems.
Special Services
A SETD term used instead of complementary paratransit so as to be more understandable to the general public. These services include having a fixed route bus deviate off route, having Dial-A-Ride take a rider to the nearest bus stop, and /or giving a rider priority for Dial-A-Ride services, as determined by the Lead Dispatcher based on the ride request.

Eligibility
The process outlined in this policy, whereby a rider can apply to receive special services (complimentary paratransit).

ADA Compliance
The Sunset Empire Transportation District provides two transportation services to the citizens and visitors to Clatsop County. The first is "The Bus" fixed route bus service. The second is Dial-A-Ride, which provides demand response transportation to the general public with priority given to senior and disabled riders. All SETD vehicles are equipped with a wheelchair lift. The SETD offers complementary paratransit service to any disabled rider unable to utilized the fixed route service by deviating a bus off-route up to 1 ½ miles or dispatching an ADA complementary paratransit vehicle (Dial-A-Ride bus.) Complementary paratransit is also used to transport riders to the nearest bus stop for inter-city travel, except when a passenger’s disability makes bus travel impossible.

Application and Certification Process
When a rider contacts the district with a request for paratransit service they will be interviewed by the Dispatcher. If the Dispatcher feels that a disability exists or may possibly exist, that rider will be presumed to be eligible for Special Services for 21 days. An application form (attachment to this document) will be sent to all riders requesting Special Services whether or not the Dispatcher feels a disability exists. All eligibility material will be available in accessible formats upon request. This includes large print and audio cassette.

Once a completed application is received, the District shall have up to 21 days from receipt to make an eligibility determination. No application for Special Services shall be accepted for review by the District until all sections of the application are completed. All partially complete or illegible applications shall be returned to the applicant. The Lead Dispatcher shall review all completed applications to determine eligibility for Special Services including the category of service such as permanent, temporary, or conditional. If an initial determination is not made within 21 days of the individual’s request for service, they will be provided temporary services on a presumption of eligibility until eligibility is determined.

All applicants will receive notification of their eligibility or service denial in writing and in an accessible format if requested. Individuals who are certified as eligible will be provided with an identification card.

Denial of Service
If Special Services are denied the individual has the right to appeal this decision. The service denial will be in writing and will include the reasons for the denial and provide information about the process of appealing the decision. The denial decision will be reviewed by the Operations Manager, who will sign the denial notification letter.

Appeal Process
A grievance procedure must be initiated within 60 days of the date on the letter denying paratransit eligibility. The appellant will submit their complaint regarding access or discrimination in writing to the SETD Board of Directors, 900 Marine Drive, Astoria , OR 97103 for resolution. The appellant, at their request, will have the right to meet with the Board to present additional information and arguments at an open, public meeting. Anyone needing special accommodations may contact the District Offices for assistance. (1-800-776-6406)

The decision of the Board of Directors must be made within 30 days and will be in writing or in an accessible format, and include the reasons for the finding. The decision of the governing body is final. A record of action taken on each request or complaint must be maintained as a part of the records or minutes at each level of the grievance procedure.

The right of the appellant to a prompt and equitable resolution of the complaint must not be impaired by the appellant’s pursuit of other remedies, such as the filing of a complaint with the Department of Justice or other appropriate federal agency or the filing of a suit in state or federal court. Use of this procedure is not a prerequisite to the pursuit of other remedies.

Visitor Privilege
The district reserves the right to suspend from services any ADA qualified
Visitors will be allowed Special Services while staying in Clatsop County.
The individual should have a certification from their home of record. If they do not, the certification process will be used to determine eligibility. Visitor privilege will be provided by the SETD for no more than 30 days after first use.

Suspension of Services
Person who establishes a pattern or practice of missing scheduled trips and/or for violating the

Passenger conduct rules. The passenger conduct rules, rider no-show policy and penalties are stated in the Dial-A-Ride Use Policy and apply to all paratransit services. Repeated violations can result in services being revoked for up to a maximum of one year. All suspension decisions will be the responsibility of the Operations Manager, subject by appeal to the Board of Directors.

Personal Care Attendant
If it determined that a rider needs the assistance of a personal care attendant that attendant may ride free of charge. Other companions may ride as space allows and pay the normal fare. Eligibility Identification Cards:

Eligibility Identification Cards:
Eligibility Identification Cards will include the name of the eligible individual, transit provider (SETD), the telephone number of the District, an expiration date for eligibility if applicable, any conditions or limitations on the individual’s eligibility, and if there is need for a personal care attendant.


Temporary or Conditional Certification
The ADA qualified person will need to be recertified every six months, unless a longer time period is recommended by the physician and approved by the Operations Manager.


Appendix D. ADA Brochure


Note this brochure should be run as a reverse on blue for ease of reading and to signal ADA information. Minimum type size should be 12 and larger type 18 or larger should be provided as needed.


SUNSET EMPIRE TRANSPORTATION DISTRICT USER’S GUIDE FOR ADA PARATRANSIT SERVICE

The (SETD operating as the bus) has an Americans with Disabilities Act (ADA) paratransit service. The bus paratransit service will provide public transportation to persons with disabilities who are unable to use regular fixed route buses. Curb to curb paratransit service, in wheelchair lift equipped mini buses, will be comparable to existing SETD bus service operated within the designated service areas. Individuals certified conditionally eligible are also encouraged to use regular bus service whenever possible.
Service Information

Paratransit service is available at the same times and days as regular SETD buses are schedules, including Saturday. All trips must have an origination and destination within ¾ of a mile of a regular SETD bus route, not including commuter routes.

Scheduling a Trip Service Fares
The fare for the ADA paratransit service is twice (2x) the fixed route fare. The bus monthly passes are acceptable for ADA fare payment.

You will be reminded of the fare when your paratransit trip is scheduled. Please note that rides may be shared with passengers from other programs who may or may not be paying a fare directly to the driver.

Service Accommodations Cancellations, Missed Rides, and No Shows Questions and Comments
If you have any questions or comments, please feel free to call "The Bus" at 861-7433 or e-mail The Bus at dar@ridethebus.org.
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