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CDTA ADA Compliance Review - January 31, 2007

Location: Albany, NY
Date of Final Report: January 31, 2007    

Capital District Transportation Authority Transmittal Letter

January 31, 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) Complementary Paratransit compliance review conducted at the Capital District Transportation Authority (CDTA) from June 13 to 16, 2005.  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 November 1, 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.

2.  ADA Complementary Paratransit Eligibility

11. Finding:  At the time of the review team’s visit, CDTA’s no-show suspension policy stated that “if you no-show three times in one month, you could lose your STAR riding privileges for a period of 30 days.”  According to the paratransit coordinator, CDTA has not been implementing this policy since early 2005.  CDTA was in the process of reviewing and possibly revising this policy.

Corrective Action Proposed by CDTA:  CDTA has been actively engaged in updating its STAR policies since the latter part of 2005, and will be implementing them in December of 2006. Part of the delay has been directly attributed to updates in Trapeze, and CDTA’s IVR system.

No show policy has been updated to reflect a percentage of rides within 30 days.  The policy to be enacted is such: If a customer has no showed 10% of their rides within thirty days (30), a written notice will be sent to him or her.  The notice will indicate that if they no-show another 10% of their trips within any thirty day period, the customer’s STAR service may be suspended for a period of 1 (one) week.  Subsequent suspensions may be for up to 30 (thirty) days

Prior to suspension, the customer will receive a written notice that service will be suspended beginning with a specified date.  The customer will also receive a copy of the appeals process (see below). STAR will continue to provide paratransit service until the appeal has been decided.  During this period, the customer will be required to pay a full fare for each no-show.

Additional Reporting:  Please confirm the date that CDTA’s new policies and procedures will come into effect.

Clarification of Corrective Action:  Is there a minimum number of no-shows and/or trips before CDTA sends a warning letter or suspension letter to a customer?  For example, would CDTA suspend a customer for being a no-show for one trip out of two (50%)?

5.1  Service Performance

7.  Finding:  For service on April 25, 2005, CDTA reported on-time and early drop-off performance at 83.4 percent.  The review team’s sample of trips from April 27, 2005, yielded an early/on-time drop-off performance rate of 82.1 percent.  The on-time performance for both dates falls below CDTA’s goal of 95 percent on-time performance for drop-offs.  Three drop-offs in the sample (7.7 percent of completed trips in the sample with appointment times) were made more than 15 minutes later than the scheduled drop-off time.  Drop-offs as little as 15 minutes late can cause people to miss appointments or otherwise negatively impact a persons ability to work, attend classes or participate in other time sensitive activities and could be considered significantly late.

Corrective Actions Proposed by CDTA:  On-time drop offs are considered within 10 minutes of the requested appt. time.

Clarification of Corrective Action:  Does CDTA consider a drop-off as on-time if it occurs 10 minutes after the requested appointment time?

8.   Finding:  Ten of the 39 drop-offs from the sample (25.6 percent) were more than 30 minutes before the scheduled time; one drop-off was more than one hour early.  Significantly early drop-offs can be an impediment to use of the service.

Corrective Actions Proposed by CDTA:  CDTA Reservation personnel have been trained to utilize the one-hour negotiation at the time of the trip request, keeping in mind travel time and appointment times. Once the scheduled time is confirmed however, it does not change for the customer.

Clarification of Corrective Action:  Do CDTA reservationists and schedulers consider and try to minimize very early drop-offs (e.g., more than 30 minutes) for trips with requested appointment times?

5.2  Transportation Operations

1.   Finding:     According to the dispatchers and operations manager, STAR often operates with fewer vehicle runs than scheduled.  This is usually because of the lack of available vehicles.  Sometimes this is because there are not enough drivers to cover the scheduled runs.

Corrective Actions Proposed by CDTA:  CDTA has been systematically replacing 1/5 of its paratransit fleet every year as a way to ensure that the average age of the fleet is not excessive. Additionally, with the use of taxis, CDTA is able to fully allocate every vehicle in operations that is available, knowing that the taxis will accommodate any additional capacity issues.

Clarification of Corrective Action:  While CDTA has an ongoing schedule for replacing its existing fleet, does it plan to expand the fleet?

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 Mr. 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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