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CDTA ADA Compliance Review - February 7, 2007

Location: Albany, NY 
Date of Final Review: February 7, 2007

Capital District Transportation Authority Transmittal Letter

February 7, 2007

Mr. Raymond J. Melleady
Executive Director
Capital District Transportation Authority
110 Watervliet Avenue
Albany, NY 12206

Dear Mr. Melleady:

Thank you for your response to the Federal Transit Administration’s (FTA) letter and preliminary report of findings of the Americans with Disabilities Act of 1990 (ADA) Stop Announcement and Route Identification Efforts compliance review conducted at Capital District Transportation Authority (CDTA) in March, 2006. Enclosed is the Final Report that incorporates CDTA’s official response by attachment. 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 CDTA 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 CDTA to clarify specific corrective actions based on CDTA’s response to the report findings

Please use the enclosed table as the format to report progress to FTA on the corrective actions that CDTA has completed or intends to implement as a result of our findings. Please identify each response by item number (e.g., 1.1, 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 16, 2007, and should include data for the months of January through March 2007, and any actions completed prior to that date that have not already been addressed. Additional reports will be due by July 15, 2007, October 15, 2007, January 15, 2008, and each calendar quarter thereafter until FTA releases CDTA from this reporting requirement.

We recognize the progress that you have made in responding to the findings of the assessment as presented in your December 18, 2006 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.

1.1 Efforts to Comply with Stop Announcements and Route Identification Requirements

1. Finding: CDTA periodically reminds its drivers of the requirements to announce stops and to make external route identifications through Transportation Department Notices. The most recent notice was issued on October 4, 2004. Based on these notices, there appears to be greater emphasis on stop announcements than route identification

Corrective Action Proposed by CDTA: CDTA has been informing each new operator during the training period the importance of making stop announcements. Additionally, visually impaired passengers have attended both training sessions as well as union meetings to emphasize the importance.

Clarification of Corrective Action: While CDTA’s emphasis on making stop announcements through use of Transportation Department Notices is an important component of operator training, the finding concerned the relative lack of attention being paid to route announcements in the Notices. 

Please explain how CDTA reminds operators of the importance of route announcements and what actions are being taken to ensure route announcements are given as much emphasis in operator notices as stop announcements.

2. Finding: CDTA does not appear to emphasize route identification in its driver training or its identification of driver responsibilities.

Corrective Action Proposed by CDTA: CDTA’s street supervisors have actively monitored its drivers compliance with on-board announcements, and the follow-up has been addressed with each of the respective Superintendents that manage the operations.

Clarification of Corrective Action: The finding related to driver training and identification of driver responsibilities, and not to street supervision.

Please explain how CDTA trains operators of the importance of route announcements and what actions are being taken to ensure route announcements are given as much emphasis in training and driver responsibilities as stop announcements.

Finding: CDTA has in-house procedures and an outside contractor to monitor stop announcements. CDTA has been collecting the forms completed by its employees but has not analyzed the data. The secret riders employed by the contractor rarely observed the drivers making stop announcements or route identifications.

Corrective Action Proposed by CDTA: CDTA has been tracking on-board stop announcement activities by operator through on-board observations conducted by Supervisors, as well as covert riders. Each operator’s performance is then documented and tracked.

Clarification of Corrective Action: CDTA’s response suggests that CDTA now documents and tracks each operators performance.

Please explain the results of this information tracking. How is this information used to instruct operators, discipline operators, or to inform other management decisions.

Please see 2.2, below.

1.2 Stop Announcements

Finding: Departments within CDTA have compiled separate lists for stop announcements; each list is different. The stop lists used as input to the automated announcement system appear to be the least comprehensive in terms of complying with the ADA regulations.

Corrective Action Proposed by CDTA: CDTA has defined stop announcements required as all major bus stops, and major intersections. The stop lists in the automated system reflect this guidance.

Clarification of Corrective Action: The finding was meant to be read in conjunction with the other findings of the report that suggested that the stop lists in the automated system are too restrictive. Rather than redo the lists, we meant to point out, as explained in finding 2.8, that the list already compiled by the CDTA operations department includes most of the stops required for compliance with the ADA regulations.

In the alternative, please provide the definitions and describe the procedures used by CDTA to determine which stops and intersections are “major” and included in the automated announcement list. Please also provide information on whether and how the list is updated, in response to this finding and 2.6 and 2.7 below.

Finding: Team members noted that the automated system did not announce all transfer points. In addition, cross streets were used to identify most stops. Landmarks were rarely used to identify stops.

Corrective Action Proposed by CDTA: CDTA’s automated announcement system identifies and announces all major bus stops. Transfer point announcements are the responsibility of the bus operator. CDTA is in the process of updating new maps for its scheduling application Hastus, and landmarks will be incorporated into the map as part of the update.

Clarification of Corrective Action: While CDTA asserts that transfer points announcements are the responsibility of the bus operator, these announcements were not observed being made. Other systems that utilize automated announcement systems have successfully incorporated transfer points and landmarks into their stop lists.

Additional Reporting: please provide an update on progress incorporating landmarks into the automatic announcement system, including the criteria being used to determine which landmarks to include in the list.

Finding: Team members also observed uneven intervals in the announcement of stops. When the automated system was working, intervals between announcements ranged from one minute to 26 minutes. The average (mean) interval between stop announcements on route segments that had a working automated stop announcement system was over six minutes.

Corrective Action Proposed by CDTA: CDTA will be adding additional stops into its automated stop announcement system that are above and beyond “major” bus stops in order to decrease the intervals in which stops are announced from the system.

Clarification of Corrective Action: We believe that adding additional stops is required to be in compliance with the requirement, found at 49 CFR §37.167(b)(1), that stops be announced at intervals along a route sufficient to permit individuals with visual impairments or other disabilities to be oriented to their location.

Additional Reporting: Please describe the criteria being used to determine which stops to include in the list. Please also provide data regarding how many new stops were added for each route and the mean time intervals between stops on each of the routes.

1.3 Route Announcements

Finding: The review team observed only one route announcement in 93 observations.

Corrective Action Proposed by CDTA: On-board observations by CDTA Supervisors and covert riders continue to emphasize the importance of stop announcements.

See findings 1.1, 1.2, and 1.3.

Clarification of Corrective Action: Please also note that as with 1.1 and 3.2, the issue here is route announcements, not stop announcements. Consequently, CDTA’s response, which addresses only stop announcements, does not respond to the finding.

Finding: During interviews CDTA drivers indicated that they make route announcements only when needed, i.e., when they see a visually impaired person or a person who seems confused or lost.

Corrective Action Proposed by CDTA: From training of initial operators to updated notices, and positive performance counseling, CDTA has been continually informing its operators that ADA bus stop announcements are not optional and that they are a required component of each bus operator’s duties.

Clarification of Corrective Action: As with 1.1 and 3.1, the issue here is route announcements, not stop announcements. Consequently, CDTA’s response, which addresses only stop announcements, does not respond to the finding.

Finding: CDTA plans to have all buses equipped to make automated external route announcements. At the time of the site visit, however, this feature was not working on any CDTA bus.

Corrective Action Proposed by CDTA: “NO RESPONSE REQUIRED”

Clarification of Corrective Action: CDTA responded “NO RESPONSE REQUIRED.” This was not the position of FTA. Please respond to this finding. In particular, CDTA should provide an update on progress toward equipping all buses with external route announcement capability. If not yet complete, CDTA should provide a timetable for doing so. Alternatively, if CDTA no longer plans to install the equipment or has an indefinite timeline, please explain. Please also identify a contact person for this finding.

We recognize the efforts that CDTA has already taken to correct the deficiencies identified in the draft report, and we anticipate your continued endeavors to take further corrective actions as noted in this letter. We appreciate the cooperation and assistance that you and your staff have provided us during this review. If you have any questions about this matter, please contact me or Jonathan Klein, Equal Opportunity Specialist, at (202) 366-0809 or at his e-mail address: jonathan.klein@dot.gov.

It would also be very helpful to us if you would provide a copy of all correspondence to this office to the FTA Region II Civil Rights Officer at the following address:

Mr. John Prince
Civil Rights Officer, Region II
Federal Transit Administration 
One Bowling Green, Room 429
New York, NY 10004


Sincerely,

Michael A. Winter
Director, Office of Civil Rights

Enclosures

cc: David Stackrow, CDTA Chairman
Brigid Hynes-Cherin, FTA Region II Administrator
John Prince, FTA Region II Civil Rights Officer
Larry Penner, FTA Region II Director of Operations and Program Management

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