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CENTRO ADA Compliance Review - March 5, 2008

Location: Syracuse, NY
Date of Final Report: March 5, 2008     

Central New York Regional Transportation Authority (CENTRO) Transmittal Letter

March 5, 2008
Re: Report for ADA Compliance Review of Complementary Paratransit Service

Dear Mr. Kobliski:

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 from April 23 to 26, 2007, of Central New York Regional Transportation Authority’s (CNYRTA) ADA complementary paratransit service.  Enclosed is the Final Report that incorporates CNYRTA’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.  It will also be posted on our website shortly.

Enclosed with this letter is a progress table listing FTA’s understanding of the corrective actions either planned or taken by CNYRTA 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 CNYRTA to clarify specific corrective actions based on CNYRTA’s response to the report findings

Please use the enclosed table as the format to report progress to FTA on the corrective actions that CNYRTA has completed or intends to implement as a result of our findings.  Please note that the findings in the table and in this letter have been identified according to the format used for the Summary of Findings, on page 20 of the Report.  In your response, please identify each response using the same format (e.g., A.1, etc.) for consistency.

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, 2008, and should include data for the months of January through March 2008, and any actions completed prior to that date that have not already been addressed.  Additional reports will be due by July 15, 2008, October 15, 2008, and each calendar quarter thereafter until FTA releases CNYRTA 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 4, 2008, 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.

B.  ADA Complementary Paratransit Eligibility

14.   Finding:  Participation by the Oneida County general manager in the six-person committee that hears formal ADA complementary paratransit eligibility appeals in Oneida County appears to violate the DOT ADA regulatory requirement that there be separation of functions between those hearing appeals and those making the initial eligibility decision.  The regulations require that, to the extent practicable, the person hearing the appeal not be a supervisor of the original decision maker.

Corrective Actions Proposed by CNYRTA:  All requests for appeals now go to the Vice President for Operations.

Clarification of Corrective Action:  Please confirm that the Vice President for Operations does not oversee any of the individuals who currently review applications for CAB service.  Also, please clarify whether the Vice President is now the exclusive reviewing official for appeals or is merely replacing the general manager on the committee.

D.  Trip Reservations and Scheduling

8.   Finding: During interviews with Centro operators, they cited instances of receiving unclear or incorrect information about riders, such as customers’ inability to board certain vehicles or being accompanied by a PCA.  They also cited occasional problems of incorrect locations or addresses printed on manifests.

Corrective Actions Proposed by CNYRTA:  We will further survey our operators to determine information they would like to have on the revised manifest.

Clarification of Corrective Action:  Please report on progress in the next quarterly progress report.  Please indicate whether all operations will eventually use the same manifests.  Additionally, the proposed corrective action appears to primarily address operator concerns regarding the comprehensiveness of manifest information.  Please also report on how the proposed and implemented changes will ensure that all the information is accurate.

12. Finding:  In Oneida County, trip information on canceled trips is not being retained.  A record of the cancellation can be helpful, should the change in trip status be questioned after the fact.  For example, the information can be helpful in documenting late cancellations or disputed cancellations.

Corrective Actions Proposed by CNYRTA:  None provided.

Additional Reporting:  Please provide a response to this finding, a planned completion date, and a contact name and telephone number.

E.  Service Performance

14. Finding: Contractors do not notify the Onondaga dispatcher when they receive trip cancellations from customers.  As a result, CAB, Centro, and CNYTRA personnel are unaware of the change in trip status.

Corrective Actions Proposed by CNYRTA:  None provided.

Additional Reporting:  Please provide a response to this finding, planned completion date, and provide a contact name and telephone number.

15. Finding:  Operators sometimes change the sequence of stops on their routes without notifying the dispatcher.

Corrective Actions Proposed by CNYRTA:  None provided.

Additional Reporting:  Please provide a response to this finding, a planned completion date, and a contact name and telephone number.

We recognize the efforts that CNYRTA 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. David Knight, ADA Team Leader, at (202) 366‑0805 or at his e-mail address: david.knight@dot.gov.

It would also be helpful to us if you would provide an electronic copy of all correspondence to this office to the FTA Region II Civil Rights Officer at: john.prince@dot.gov.

Sincerely,

Cheryl Hershey
Acting Director
FTA Office of Civil Rights

Enclosures

cc: Brigid Hynes-Cherin, FTA Region II Administrator
John Prince, FTA Region II Civil Rights Officer
Larry Penner, FTA Region II Director of Operations & Program Management

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