Location: Arlington, VA 
Date of Final Review: May 13, 2009

Arlington Transit (ART) - Lift Maintenance Transmittal Letter

May 13, 2009

Mr. Stephen J. Del Guidice
Transit Bureau Chief
Division of Transportation
Department of Environmental Services
Arlington County
2100 Clarendon Boulevard, Suite 900
Arlington, VA 22201

Dear Mr. Del Guidice:

Thank you for the cooperation that you and your staff provided during the Americans with Disabilities Act of 1990 (ADA) compliance review of the Arlington Transit’s (ART) fixed route services, initiated on March 10, 2008. Enclosed is the Final Report of the ADA review conducted by Planners Collaborative, Inc. As of the date of this letter the Final Report became a public document and is subject to dissemination under the Freedom of Information Act of 1974.

Enclosed with this letter is a progress table listing FTA’s understanding of the corrective actions either planned or taken by ART in response to the preliminary findings contained in the draft report. If you feel that our summarization of corrective actions is inconsistent with your response, please inform us in writing as soon as possible.
Following most of the areas where findings were made, we have:

• Identified responses that adequately address the finding
• Requested documentation of results and outcomes
• Requested ART to clarify specific corrective actions based on ART’s response to the report findings

Please use the enclosed table as the format to report progress to FTA on the corrective actions that ART has completed or intends to implement as a result of our findings. Please identify each response by item number (e.g., A.1, etc.). The requested documentation, along with updates on the status of implementation of proposed corrective actions, should be provided in quarterly reports to FTA. Each report should include the planned and actual completion date of the corrective action; the current status and contact person information for each corrective action; and specific reporting requests cited in this letter and on the enclosed table. The first report will be due on April 15, 2009, and should include data for the months of January through March 2009, and any actions completed prior to that date that have not already been addressed. Additional reports will be due by July 15, 2009 and October 15, 2009 and each calendar quarter thereafter until FTA releases ART from this reporting requirement.

We recognize the progress that you have made in responding to the findings of the review as presented in your January 23, 2009, letter. In addition to these efforts, we request that your first progress report more fully respond to the following findings, which are also addressed in the progress table. This is not an exhaustive list of open findings, for that, please see the progress table. D. Bus Operations

5. Finding: Operator interviews and ride-alongs both suggest that, compared with operators who rarely encounter wheelchairs on their routes, operators who frequently encounter wheelchairs on their routes have a better understanding of how to communicate with customers with disabilities, better facilitate bus placement, and better understand the boarding, deboarding and securement processes. However, during actual field observations on a route where wheelchairs are common, an operator was not able to demonstrate full proficiency in the securement process.

6. Finding: All bus operators interviewed said they had received training in wheelchair boarding and securement. However, responses on what to do in the event that a wheelchair lift failed to operate varied, indicating that the training is insufficient.

7. Finding: The review team observations of boarding/deboarding wheelchair customers during the ride-alongs indicate that current hands-on training is insufficient to maintain even a basic level of proficiency, particularly among operators who rarely see wheelchair customers. A lack of proficiency in securement of wheelchairs - evidenced by taking much too long and being unable to complete securement without direction from the passenger or a supervisor regarding where to attach the securements - is the most serious deficiency. 

ART 1/30/2009 Corrective Action for Findings D.5, D.6, and D.7: The operator training program and periodic retaining emphasize the operation of lift and securement equipment. Drivers are instructed to record on the DVIR and report immediately all lift and securement equipment failures including those during pre-trip inspection. Refresher training is conducted quarterly – last completed November 2008.

The County will resume quality control reviews in 2009 using “mystery” riders to ensure that operators have the ability to operate lifts and securement equipment properly. The County will conduct the next mystery rider quality assessment in Spring 2009

Clarification of Corrective Action: These findings are particularly important, as they concern the actual performance of bus operators in serving customers with disabilities. Therefore, the results of the mystery rider assessment are needed to assess the effectiveness of the corrective actions, particularly training. ART should consider having some of the mystery riders board with wheelchairs, both on NABI-served routes that frequently see wheelchair customers and on routes served by lift-equipped Fords.

Further Reporting: Please provide all mystery rider reports in the quarterly progress report following the observations.

We appreciate the cooperation and assistance that you and your staff have provided us during this review. Should you have any questions about the enclosed report, the reporting table, or this letter, please contact Ms. Susan Clark, Equal Opportunity Specialist, at 202-493-0511 or at her email address: susan.a.clark@dot.gov.

It would be helpful if you would provide a copy of all correspondence to this office via e-mail to Ms. Deborah Haines, the FTA Regional Civil Rights Officer, at deborah.haines@dot.gov, or Ms. Sandra McCrea, Chief of External Operations, at sandra.mccrea@dot.gov.

Sincerely,

Cheryl L. Hershey
Director
Office of Civil Rights

Enclosures
Ms. Letitia A. Thompson, FTA Region III Administrator
Deborah Haines, FTA Region III Civil Rights Officer