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United States Department of Transportation United States Department of Transportation

HRT ADA Compliance Review - January 28, 2005

Location: Hampton, VA
Date of Final Report: January 28, 2005

The Transportation District Commission of Hampton Roads (Hampton Roads Transit)  Transmittal Letter

January 28, 2005

Mr. Michael S. Townes
Hampton Roads Transit
3400 Victoria Boulevard
Hampton, Virginia 23661

Dear Mr. Townes:

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 Hampton Roads Transit (HRT) from October 8-11, 2002.  Enclosed is the final report that incorporates HRT’s response by attachment.  Note that modifications have been made to the draft report, based on the additional information you provided in your response.  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 also will be posted on FTA’s official website here.

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

Please use the enclosed table as the format to report progress to FTA on the corrective actions 
HRT 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 in the enclosed table.  The first report will be due on April 15, 2005, and should include data through March 2005.  Following reports will be due by July 15, 2005, October 15, 2005, January 15, 2006, and each calendar quarter thereafter, until FTA releases HRT from this reporting requirement.

We recognize the progress that you have made in responding to the findings of the assessment as presented in your May 2, 2003 letter.  We acknowledge your request for a new Draft Report.  However, the findings included in the Draft Report represent the observations and analysis of FTA’s review team at the time of the site visit in October 2002.  Actions taken by HRT since then do not affect these findings.  We do encourage HRT to describe and document any changes to its ADA Complementary Paratransit service since that time.  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.

A.      ADA Complementary Paratransit Eligibility

2.  Finding:  Based on a review of randomly selected application files, in some cases, it appears that applicants were denied eligibility if they indicated that they could get to the bus stop nearest their home and from bus stops to frequent destinations.  These determinations do not appear to consider applicants’ abilities to travel throughout the entire service area but only from their homes and to certain destinations.  However, most eligibility determinations appear to be consistent with the regulatory definitions of ADA Complementary Paratransit eligibility.

Corrective Action Proposed by HRT:  “HRT requests that this be reconsidered. According to the Draft Report (pp. 23-24), this comment is based on a single applicant for whom eligibility was denied. Other reasons than those cited also enter into the determination for each individual.

“We believe that each applicant has a responsibility to provide information regarding their own functional abilities, about which they should be, the best judge. Our trained eligibility certification staff does their best to elicit information in a sensitive and thoughtful manner, but must rely on direct information from the applicant when making final decisions. Applicants that are denied eligibility have the right to provide subsequent information at the appeal hearing about any other locations or stops to which they believe travel cannot be completed, or any other relevant data to substantiate their request for eligibility. If the applicant’s circumstances change so that he/she is unable to use accessible fixed-route public transit for any trips, HRT would consider it, upon presentation.

“We appreciate the recognition that most eligibility determinations appear to be consistent with the regulatory definitions of ADA Complementary Paratransit eligibility. HRT’s goal remains to continue to improve the effectiveness and validity of our eligibility process.”

Additional Reporting:  In determining eligibility for ADA Complementary Paratransit service, HRT should consider all potential trips that an applicant could take - not just trips between home and frequent destinations.  During the site visit, HRT staff said that eligibility determination decisions “consider whether applicants are able to get to the bus stop nearest their home and if they are able to get to the nearest bus stop at their origin and at their frequent destinations a finding of ‘not eligible’ might be made[emphasis added].If an applicant can use fixed route for certain trips, but not others, HRT should grant conditional eligibility to the applicant.  Please revise the eligibility determination processes so that HRT does not deny eligibility solely on whether an applicant can travel to the bus stop nearest home and bus stops near frequent destinations.

3.  Finding:  The calendar period used to define periods of extremely hot weather (June 15 through September 15) appears to be overly restrictive.  A recent appeals panel determination appears to have extended this period by 45 days for one applicant.  It is not clear what temperature was considered “too hot” for applicants and what documentation HRT uses to indicate that this temperature is not exceeded regularly before June 15 or after September 15.

Corrective Action Proposed by HRT:  “The ‘excess temperature’ determination for each individual is based on the information that they provide to us during the interview, and varies by individual.  The basic three-month ‘window’ was determined based on historical experience in our local area, and in order to provide parameters that work within the confines of the available reservations/scheduling software.  If or when an individual requests ‘hot weather’ paratransit outside these dates, and if the forecast is in agreement, we do our best to accommodate them, and have done so on a regular basis.  However, it is the applicant’s responsibility to provide us with valid information.”

Additional Reporting:  For riders who do need paratransit outside of the three-month window, how does HRT document this need so that call-takers know when to accept their trip request?  HRT should develop specific guidelines for its staff to determine when a rider is eligible for a requested trip.  In addition, HRT should go beyond doing “our best to accommodate them.”  If a rider is eligible for a requested trip, HRT should provide that trip.

4.  Finding:  HRT’s practice of considering the 21-day determination process to start after both the interview has been held and professional verification has been received appears to be inconsistent with the regulatory requirements for timely processing of eligibility determinations.  Section 37.125(c) of the regulations states that the processing time begins upon receipt of a complete application.  Because HRT has chosen to have applicants mail in applications prior to in-person interviews, the 21-day processing time begins upon receipt of the completed application form.  The time required to schedule and hold an interview is not within the control of the applicant.  Similarly, the application form only asks individuals to provide the names of professionals who can be contacted if necessary.  The time required by HRT to request and receive information from professionals also is not within the control of the applicant.

Corrective Action Proposed by HRT:  “Our community advisors fully concurred with the recommendation to move to a functional assessment in order to better determine eligibility.  The reason that the paper ‘form’ consists of only two pages of requested information was specifically requested by the Advisory Committees to minimize the up-front burden on the applicant, and it is clearly designed to elicit only minimal information to track and schedule the applications.  The ‘short form’ obviously does not seek enough information for an adequate or responsive determination of an individual’s eligibility.  Both the Unified Plan and the form cover page clearly state that the interview is an essential part of the process, and that an application is not considered complete until the interview and related assessments have been conducted.  In effect, the two-page form, with one page of preliminary information, and one page to authorize additional professional verification is merely an initial request to begin the interview and assessment process; it in no way constitutes a completed application, and we know of no applicant who has perceived it as such.  Mailing in the form is simply a convenience for the prospective applicant.  As noted in the Revised Draft Report, the use of professional verification is seldom required, and only carefully sought, but such responses, when needed, are certainly not under the control of HRT.

“It is, further, disingenuous to suggest that ‘the time required to schedule and hold an interview is not within the control of the applicant,’ since Mr. Thatcher made a point of suggesting to our staff that they were perhaps being too lenient in allowing the applicants themselves to determine the scheduling of the interview.

“If the consultants have constructive suggestions for improving the clarity of the initial form, we would of course consider them, in consultation with the local advisory process.  We will also consider having the prospective applicant delay providing any substantive information until they physically arrive for the interview process, although we are concerned that this may further delay the scheduling for some individuals.”

Additional Reporting:  The HRT application does state, “your application is not considered complete until you have the in-person interview.”  We recognized that Section 37.125 of the regulations grants HRT the authority to establish its eligibility process.  However, as Appendix D to Section 37.125 states, “the process may not impose unreasonable administrative burdens on applications.”  In the case of HRT, the time required to process and evaluate applications is dependent on scheduling the interview and possibly HRT’s receiving a professional verification.  HRT should describe the steps that it will take so the interview and professional verification both take place in a timely manner.  For example, HRT could aim to schedule the in-person interview and contact the designated medical professional within one week of receiving the paper form.

5.  Finding:  Based on the sample of application files reviewed by the assessment team, 97 percent of determination decisions made between July and September 2002 appear to have taken longer than 21 days.  Only eight percent of all determinations were made in less than 30 days.  Thirty-eight percent of determinations during this period took longer than 60 days.  The switch to the new eligibility determination process appears to be contributing to very long delays in completing determinations.

Corrective Action Proposed by HRT:  “We agree that the new process is taking longer than we had hoped, but it is also necessary to ensure fair and objective determinations for all applicants.  Despite our efforts, we have had difficulty recruiting and retaining a full complement of eligibility staff, and we conduct periodic retrainings to improve their skills.  The new process is fully intended to evolve and improve over time in response to new assessment techniques, and the ability of the computer software to better maintain and utilize detailed confidential information.  Additionally, increased eligibility certification staff time is being budgeted for.

“We also request that the chart on page 26 be amended. The heading of the second data column is unclear, due to the two ‘interview’ references. Further, the presentation, if it is to be useful should more accurately reflect time passed from the actual interview, not the initial short form.”

Additional Reporting:  Please provide statistics on HRT’s application processing times for 2004.  In addition, please provide a timetable and action plan outline.

6.  Finding:  While the regulations do not require determinations to be made in 21 days or less, they do require that presumptive eligibility be granted if decisions take longer than 21 days.  HRT appears to continue service for riders seeking recertification if determinations are delayed, but there was no evidence that new riders are made aware that they can use the service if determinations take longer than 21 days.  The cover letter to the application form does not indicate this and there was no evidence that applicants are contacted if their applications have not been processed within 21 days.

Corrective Action Proposed by HRT:  “HRT made a decision to continue to allow interim eligibility to existing riders while implementing the new process, and we are gradually eliminating the backlog.  The necessity and availability of ‘presumptive eligibility’ is cited in the Unified Plan and will be communicated to applicants during their interview.  HRT has informed applicants of their ability to schedule trips (presumptive eligibility) when the certification process has exceeded the 21-day period from the interview date.  HRT will formalize presumptive eligibility on future application forms and at the interview.”

Additional Reporting:  Please provide a timetable for the changes.  In addition, please provide a copy of the new application form.

7.  Finding:  The current practice of granting “feeder service only” eligibility to riders without more detailed information about the specific abilities of riders to get to and from bus stops appears to require that HRT needs to offer feeder service on both ends of all trips requested by these riders.  In addition, because information about the ability of riders to wait for a bus at a stop is not part of the final determination, HRT is planning to make feeder transfers only at selected bus stops that are equipped with amenities such as benches, shelter and phones.  It appears likely that the combination of needing to provide “double feeder” service for all trips to riders determined “feeder service only” eligible and the need to make transfers at only designated locations with certain amenities will result in excessively long trip times. Consequently, the policy of only offering feeder service to certain riders could result in a substantial number of significantly long trips and could discourage use of the service.

Corrective Action Proposed by HRT:  “The distance that an individual can independently traverse is elicited as part of the interview process.  As noted in the Revised Draft Report, this category has been set up prospectively so that individuals who should be able to use feeder service will have received full appropriate notice once our operations and software are fully able to schedule such trips.  Until such time, individuals in this category receive full eligibility and service barring any other eligibility limitations.  We fully expect, as do other systems exploring this approach, that the details of how feeder service will be implemented will continue to be refined with improvements in technology and communications equipment.  Because of this, the description of “double feeder” service is highly speculative, reflects a lack of awareness of local operating conditions, and should be reconsidered by FTA.  While the consultant remarks regarding double feeder service is appreciated, it is also a good example of opinion being substituted for true regulatory analysis.  HRT will consult with other transit systems as well as FTA representatives when feeder service is initiated to ensure full compliance with regulatory requirements.”

Additional Reporting:  Please provide a timetable for implementation of “feeder service only” eligibility.

8.  Finding:  It appears that the majority of late cancellations are for agency trips (often with reservations made by the agency rather than by the individual).  For the month of August 2002, 89 percent of the late cancellations were attributable to trips requested for customers attending five agencies.

Corrective Action Proposed by HRT:  “While HRT does not assume responsibility for the behavior of human service or medical agencies, the issue is being addressed through consultation with contracting agencies and the No Show - Late Cancellation Policy.  It is partly for this reason (significant number of no shows and late cancels) that special provisions were designated in the policy for subscription and ‘contracted’ services, and we will continue to monitor problem areas.  However, we fully understand that we must try to balance the rights of individual customers with the paternalistic and often self-focused ‘mission’ of some agencies.  We also deplore the negative impact of late cancels on other eligible passengers.  In general, agency representatives who participate on our Advisory Committee have been very constructive in trying to help educate their peers and colleagues about the need to be considerate of other passengers.  Operational and reporting format changes are being investigated in an effort to separate non-ADA contract trips from paratransit trips.”

Additional Reporting:  Please provide a timetable for changes.

9.  Finding:  HRT’s policy of considering only three no-shows in a 90-day period to be excessive and an abuse of the service may unreasonably limit service to ADA eligible customers and does not appear to be consistent with the intent of the regulations.  Appendix D of 49 CFR Part 37 indicates that suspensions of eligibility for no-shows are intended to prevent a “pattern or practice of ‘no-shows’…   A pattern or practice involves intentional, repeated or regular actions, not isolated, accidental or singular incidents.”  Given that a rider who forgets that he or she has booked a trip could be assessed two no-shows for a single round-trip, three no-shows could be exceeded by forgetting to cancel only two round-trips.  For a rider who travels regularly (say, 10 one-way trips a week), three missed trips in a 90-day period would be only two percent of the total trips made by that person.  Missing only two out of every 100 trips scheduled does not seem to be a reasonable standard for defining a “pattern or practice” or abuse of the service.

Corrective Action Proposed by HRT:  “This policy was the subject of extensive and thoughtful discussion by the Advisory Committees, and the adopted policy strongly reflects many of their concerns and recommendations.  When HRT developed the policy, the incidences of no-shows and late cancellations had gotten completely out of control due to previous lack of enforcement and had a serious detrimental effect both on system performance and actual capacity.  The annual cost for incomplete trips were in excess of $250,000 per year.  The Advisors and Commission members understood the negative impact on system capacity and service quality, and were fully supportive of requiring passengers to understand their obligations to their fellow riders.

“Of course, we are well aware that ‘a rider who forgets that he or she has booked a trip could be assessed two no-shows for a single round-trip’, and have reminded Handi-Ride staff, as well as riders, that we will not unilaterally cancel any return trip for a scheduled customer who misses an outbound ride.  To do otherwise would have been contrary to other FTA guidance, as well as presumptuous on our part.  The policy and practice also indicates that recorded no-shows or late cancels will and have been erased when beyond the customer’s control or for other demonstrable cause.  Of course, the appeals process exists as an additional safeguard and as a rule, considers new information when rendering appeal-hearing determinations.

“The Revised Draft Report indicates that no-shows and late cancellation rates have increased since initiation of the new policy.  We disagree; the quality of the data may have improved, as we believe has customer responsibility.  In addition and consistent with consultant comment, agency trips (non-ADA paratransit trips) account for a large percentage of recorded no-shows and late cancels.  More analysis must be conducted to analyze ADA mandated trips apart from those not covered by DOT legal requirements.  Following that analysis, a truer picture can be achieved and potential action taken if warranted and agreed to by the Commission.”

Additional Reporting:  While FTA understands that passenger no-shows impose a cost on service, HRT’s current policy appears unduly severe for frequent riders.  One way of addressing frequent riders in HRT’s policy is to consider trip frequency as part of the policy.  And while a rider may appeal a service suspension and HRT staff may be cautious in applying the policy, this does not make the policy reasonable.

Please identify what actions HRT plans to take to further review its policy of suspending service for three no-shows in a 90-day period.  Additionally, you reference a possible analysis of “ADA mandated trips apart from those not covered by DOT legal requirements.”  Please share the results of such an analysis.  Has a pattern for ADA mandated trips emerged?

10.  Finding:  HRT’s policy regarding suspensions does not appear to be a “reasonable sanction” for abuses of the service.  DOT ADA regulations allow service to be suspended for a pattern or practice of no-shows for a “reasonable period of time.”  The current HRT policy could result in a suspension of eligibility for one year, a revocation of eligibility, and a requirement to reapply for eligibility for a rider who no-shows or late cancels 12 times over a one-year period.

Corrective Action Proposed by HRT:  “This should be reconsidered. As noted above, the sanctions were carefully thought out because previous passenger behavior was out of control and was impacting available scheduling for other riders.  HRT reviewed no-show and late cancellation policies from around the country and adopted a program that is more lenient than many of those studied.  Results show that the new policy has indeed helped in our local area, especially with community perception and behavioral modification.

“More importantly, however, it should be noted that only 2 customers have been sanctioned beyond the second level out of more than 300 notices of suspension.  HRT and the Advisory Committee believe that this is evidence of the value and effectiveness of the new policy.”

Additional Reporting:  For a rider who takes 10 one-way trips per week, 12 no-shows or late cancels over a one-year period would represent a no-show/late cancel rate of less than three percent.  The potential suspension of one year seems unduly severe for such a rider.  As suggested in Finding A.9, one way of addressing frequent riders in HRT’s policy is to consider trip frequency as part of the policy.  The fact that HRT has been lenient in enforcing this policy is not “evidence of the value and effectiveness of the new policy” and does not make the policy reasonable.

Please identify what actions HRT plans to take to further review its policy of suspending eligibility for 12 no-shows or late cancels in a year.

11.  Finding:  The mandatory use of the current “Request for Appeal” form does not appear to be consistent with Section 37.125(g)(2) of the DOT ADA regulations.  This section of the regulations indicates that the appeals process must provide an opportunity for appellants to be heard (in person) and to present information and arguments.  Requiring applicants to complete a detailed form and answer complex questions before being heard appears to be inconsistent with the regulations.  The requirement to complete this form may discourage individuals from pursuing an appeal.

Corrective Action Proposed by HRT:  “HRT respectfully requests that this finding be reconsidered.  The form clearly states, ‘Lack of information submitted by you on this form will not prevent your Appeal from being scheduled and/or heard.’  The form is structured so that both the Appellant and the Panel have as consistent an approach as possible, and that the Appellant is fully informed of the kind of information that may be needed on their own behalf.  In reality, no one has ever been denied an Appeal request due to lack of information, and there have been numerous requests received with significantly less than complete responses.  As with other elements of the HRT program, this approach was based on review of other exemplary ADA paratransit programs around the country and HRT has received no complaints regarding its format.”

Additional Reporting:  While the Appeals Form states, “Lack of information submitted by you on this form will not prevent your Appeal from being scheduled and/or heard,” the form also states at the top of page 1, “Note: Use of this form is mandatory.”  HRT’s policy should make it clear that an individual may file an appeal without using this form.  HRT may provide the form to appellants and indicate that the information requested would be helpful for both the appellant and HRT, but optional.

Please develop a revised Appeals Form that clearly states that an appellant may choose to use or not use the form to file an appeal.

B.      Other Service Access Issues

1.  Finding:  The requirement to call both paratransit providers and the need to use a fixed route bus to transfer between paratransit systems on either side of the Bay appears to place an undue burden upon the customer.  At minimum, it might discourage riders from requesting such a trip.  At worst, it might be virtually impossible for some passengers to make the double transfer required to complete the trip.  It also is likely that the travel time for such a trip would exceed the travel time standard established by HRT.

Corrective Action Proposed by HRT:  “HRT will develop and implement a coordinated call system for paratransit trips across the Bay by June 1, 2003.  The travel time to make a cross-bay trip for a fixed-route customer is comparable to a paratransit trip.  Cross-bay paratransit trips currently average 3 per month.”

Additional Reporting:  Please update and indicate how this was accomplished.

C.      Telephone Capacity & Trip Reservations

2.  Finding:  Drivers noted that they sometimes receive incorrect information on their manifests – either a wrong address or changes in mobility aids are not noted.

Corrective Action Proposed by HRT:  “This finding should be reconsidered and changed to a general comment.  The lack of specificity makes it impossible for staff to respond in a substantive manner.  The same comment could be made anywhere in the country.  HRT is willing to adopt best practices from other transit systems where drivers never make similar comments.  The introduction of Trapeze greatly improved manifest reliability.  However, with no-show and late cancellation numbers averaging 4.5 percent of all trips booked, ‘incorrect information’ will continue to pose challenges for management and drivers alike.  Steps have been taken to address driver concern over manifest accuracy through increased communication. Drivers are encouraged to provide feedback on manifest accuracy travel times, traffic obstruction, etc. on a daily basis so that system modifications can be made to increase accuracy. Regular formal and informal discussions with drivers take place to receive feedback and address areas of concern. Efforts will continue in the future.”

Additional Reporting:  Please describe any formal feedback process developed by HRT for drivers to provide information about inaccuracies on their manifests.

3.  Finding:  An initial review of the data provided by the BCMS monitor system used by HRT for Handi-Ride suggests that customers have good access to the reservations and dispatch lines.  Access to the cancellation lines appears to have improved; however, complaints continue about cancellations not being entered when they are left on the answering machine.

Corrective Action Proposed by HRT:  “Again the lack of specificity makes it impossible to respond in a substantive manner.  We are aware of occasional complaints, and if validated, the customer is not charged with a no-show or late cancel.  We are also aware of circumstances where there has been no evidence of such calls ever having been left.  Efforts will continue to monitor, document and maintain recorded cancellation lines to achieve 100% consistency and accuracy.”

Additional Reporting:  Please describe the specific actions that HRT will take to ensure the entering of cancellations requested via the answering machine.

6.  Finding:  Carriers do not have prepared scripts for call takers and call takers are not consistent in confirming the trip details at the end of a call.

Corrective Action Proposed by HRT:  “This appears to be a consultant opinion of desirability, rather than an ADA compliance issue.  Call taker training emphasizes the relationship between appointment and travel times, disability awareness, customer service, and utilization of the computerized reservation system.  HRT will prepare a list of key transportation questions that will be used to ensure that each call taker is providing a consistent reservation approach.”

Additional Reporting:  The intent of the finding was to note that call takers were observed to be inconsistent in confirming trip details back to customers, which could contribute to errors or misunderstandings.  In addition, please indicate the adopted approach and timetable for implementation.

F.      On-Time Performance

1.  Finding:  Handi-Ride collects pickup and drop-off times for 100 percent of its trips.  Minibus submits monthly reports that provide the percent of late pickups of trips.  The cab companies submit trip tickets that list the negotiated and actual pickup times.  HRT does not regularly review or analyze the cab companies’ data to determine their on-time performance.

Corrective Action Proposed by HRT:  “HRT Handi-Ride has made significant improvements in management oversight of internal operations and performance as well as that of all existing contractors.  Mini-Bus, Inc., HRT’s largest contract, submits a comprehensive monthly report to facilitate review.  A procedure will be established to regularly monitor the operating performance of taxi contractors in order to measure actual on-time performance against established service goals.  HRT will meet with taxi contractor representatives within 30 days to establish a monthly report to review performance data in an effort to address operating deficiencies.  Comparisons will be made against established goals and objectives.”

Additional Reporting:  Please describe the monthly reporting process.  In addition, please provide sample completed reports from the taxi contractors.

2.  Finding:  During August 2002, 81 percent of Handi-Ride’s pickups were within its +/–15‑minute window - significantly lower than the HRT’s goal of 95 percent.  If one is concerned primarily with late pickups, then Handi-Ride was early or on time for 93 percent of trips, closer to its 95 percent standard.

Corrective Action Proposed by HRT:  “HRT’s focus admittedly has been in the area of minimizing late pickups and not on early arrivals.  Efforts will be made operationally (Trapeze and driver standard operating procedures) to minimize early pickups.  The on-time performance for HRT fixed route transit (penalized for late arrivals) averages 90%.  HRT will meet with its contractors within 30 days to establish on time performance and operational guidelines that emphasize arrival within +/-15-minute in order to be considered ‘on time.’  Efforts will be made to monitor and minimize early arrivals.”

Additional Reporting:  Please describe the guidelines developed by HRT for on-time performance of the contractors.  In addition, please provide reports on recent on-time performance.

3.  Finding:  For the month of August 2002, about 94 percent of Minibus pickups were early or on time.  Minibus did not report the number of pickups that took place before the beginning of the pickup window.

Corrective Action Proposed by HRT:  “The 94% on time performance of Mini-Bus includes early arrivals.  See number F.2 above.”

Additional Reporting:  Please refer to F.2 above.

4.  Finding:  Based on a sample of trips from August 2002 analyzed by the review team, none of four carriers (Handi-Ride, Minibus, Beach Taxi, and Carson Transportation) met HRT’s goal of 95 percent on-time pickups.  If one is concerned primarily with avoiding late pickups, then the on-time performance of three of the carriers exceeded 90 percent, while Beach Taxi was on time or early for only about 82 percent of its pickups.

Corrective Action Proposed by HRT:  “HRT will continue to improve the monitoring of internal Handi-Ride operations and performance, and that of all the contractors.  See number F.3 and F.4 above.”

Additional Reporting:  Please refer to F.2. above.

6.  Finding:  Based on the review team’s analysis, Handi-Ride has a high proportion of early pickups. Nearly 45 percent of the sampled trips had pickups that took place before the beginning of the pickup window.  Nine percent of the sampled trips had pickups more than 15 minutes before the beginning of the pickup window.

Corrective Action Proposed by HRT:  “See number F.2, F.3, and F.4 above.”

Additional Reporting:  Please refer to F.2 above. In addition, please provide reports on recent early pickups.

7.  Finding:  In the review team’s sample of Handi-Ride trips, all drop-offs were on time.  However, there is some concern with the high proportion of early drop-offs: for 45 percent of the sample trips with appointment times, Handi-Ride dropped off the rider more than 30 minutes before the appointment time.

Corrective Action Proposed by HRT:  “HRT acknowledges occasional early drop offs and attributes this in part to the impact of no shows and late cancels on daily driver schedules.  Even with dispatchers juggling trips to maximize efficiency, there are times when the drop is made before the scheduled appointment time.  Customers have for the most part been positive when early arrival times occur.  Great care is taken however to ensure that customers do not arrive at an appointment location before the office opens for business.  While early arrivals sometime result in customer concern, avoidance of late arrivals has been the primary focus.  Staff will meet within 30 days to review early arrival circumstances in an effort to minimize.  The service parameters for the Trapeze scheduling software will also be reviewed as part of this effort.”

Additional Reporting:  Please refer to F.2 above. In addition, please provide reports on recent early drop-offs.

H.      Resources

2.  Finding:  It appears that there may be minor driver shortages for both carriers.

Corrective Action Proposed by HRT:  “HRT acknowledges driver shortages in both paratransit and fixed route operations that have been attributed to the local economy.  Efforts to improve recruitment will continue.”

Additional Reporting:  Please identify specific practices to attract and retain drivers.  Please provide a timetable for any actions.

We recognize the efforts HRT has already made to correct the deficiencies identified in the draft report, and we anticipate HRT’s 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 assessment.  If you have any questions about this matter, please contact me or David Knight, Equal Opportunity Specialist, at (202) 366-0805 or at his electronic mail address:


Michael A. Winter
Director, Office of Civil Rights

Final Report
Progress Table

cc:   Susan Borinsky, FTA Region III Administrator
Deborah Haines, FTA Region III Civil Rights Officer
Planners Collaborative Inc.

Last updated: Friday, September 11, 2015
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