CAT ADA Compliance Review - November 7, 2012
Location: Savannah, GA
Date of Final Report: November 7, 2012
Chatham Area Transit (CAT) Transmittal Letter
November 7, 2012
Dear Mr. Kaigler:
This letter concerns the Federal Transit Administration's (FTA) Americans with Disabilities Act (ADA) Complementary Paratransit Service Revie'' of Chatham Area Transit (CAT) conducted from December 7-9. 2009. FTA would like to thank CAT staff and contractors for the cooperation provided to the review team during the on-site review. Enclosed is a copy or the Final Report which will be posted on FTA' website on our ADA page. CAT's responseto the Draft Report, which we received on September 21, 2012, is included as Attachment A.
The Federal Transit Administration (FTA) Office or Civil Rights is responsible for Civil Rights compliance and monitoring which include ensuring that providers of public transportation are in compliance' with the Americans with Disabilities Act or 1990 (ADA). Section 504 or the Rehabilitation Act or 1973, and the Department of Transportation’s (DOT) implanting regulations at -19 CFR '27 . 37. 38 and 39.
With the transmission of the enclosed Final Report, the follow-up repor1ing period has now begun. At this time, we ask CAT to provide a written response within 30 da) s of the date or this letter listing its proposed corrective actions (and implementation dates). FTA will use these time lines and milestones to monitor CAT's progress as CAT works to resolve the deficiencies.
In addition to the findings described in the report several additional issues have been identified through staff review of CAT public information or otherwise brought to our attention. Because these items were discovered after the on-site visit they are not addressed in the Fin al Report and will be addressed outside of the compliance review process: however many of these additional issue are relevant to the findings contained in this report. Whether CAT elects to add res these additional issues in its corrective action in concert with the report findings or in a separate document is a matter for CAT to determine.
Upon review of CAT public information and/or as discussed in telephone conversations with CAT start: the following items were noticed: the Teleride Manager and CAT's Director of Human Resources agreed to provide additional information to the FTA when CAT entered follow-up reporting:
- Change from Door- to-Door to Curb-to-Curb
- Eligibility Determination Process
- No More “Call Back” Procedure
- No-show/Late Cancel updated policy
In addition, we have also been made aware of reports that CAT ma) be planning to replace accessible paratransit vehicles that have exceeded their useful life with inaccessible vehicles. Please confirm CAT’s vehicle replacement plans: as discussed in Chapter 10 of this report, we have concerns about the age and condition of the Teleride fleet at the time of the review, as well as a lack of capital expenditures for the preceding three years and CAT’s ability to cover peak Telcride runs. As the fixed-route provider, CAT has an obligation to plan, budget and operate its ADA paratransit system according to expected demand. This includes vehicle and fleet maintenance, which if not performed may result in prohibited capacity constraints. Asexplained in Appendix D to the DOT ADA regulations: “ ... if the entity regularly does not maintain its vehicles well, such that frequent mechanical breakdowns result in missed trips or late arrivals, a pattern or practice may exist.”
We are asking that CAT also respond to these concerns and include a copy of its current fleet roster and fleet replacement plan discussed in Recommendation 10.10.1 on Page 86 of the enclosed report.
Please provide CAT’s corrective action plan and responses electronically within 30 day of the date of this letter to Susan Clark, Equal Opportunity Specialist, via email at email@example.com. with a copy to Carlos Gonzalez. FTA Region 4 Civil Rights Officer, at firstname.lastname@example.org. Thank you.
John R. Day
ADA Team Leader
FTA Office of Civil Rights
cc: Dr. Chadwick Reese. CAT Raymond Robinson, CAT
Yvette Taylor -Regional Administrator, FTA Region 4
Carlos Gonzalez, Regional Civil Rights Officer, FTA Region 4
Christopher White, Program Manager, FTA Region 4
Parris Orr, Community Planner. FT A Region 4 Erica Matos. Attorney-Advisor. FTJA Region 4
Monica McCallum, Regional Operations Division Chief, Office Civil Rights