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KCATA ADA Compliance Review - July 30, 2007

Location: Kansas City, MO  
Date of Final Review: July 30, 2007

Kansas City Area Transportation Authority  Transmittal Letter

July 30, 2007

Mr. Mark E. Huffer
General Manager
Kansas City Area Transit Authority
1200 East 8th Street
Kansas City, MO 64108

Dear Mr. Huffer:

Thank you for your response to the Federal Transit Administration’s (FTA) letter and preliminary report of findings for the Americans with Disabilities Act (ADA) fixed route and stop announcement and route identification compliance review conducted at the Kansas City Area Transit Authority (KCATA) from January 16 to 19, 2007. Enclosed is the Final Report that incorporates KCATA’s official response by attachment. As of the date of this letter, the final report became a public document and subject to dissemination under the Freedom of Information Act.

Enclosed with this letter is a progress table listing FTA’s understanding of the corrective actions either planned or taken by KCATA 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.

  • Based on our understanding of each of KCATA’s responses to the findings, we have:
  • Identified whether the response adequately addresses the finding
  • Requested any needed documentation of results and outcomes
  • Requested, when appropriate, that KCATA clarify specific corrective actions in response to the finding

Please use the enclosed table as the format to report progress to FTA on the corrective actions that KCATA 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 October 15, 2007, and should include data for the months of July through September 2007 and any actions completed prior to that date that have not already been addressed. 

Additional reports addressing the remaining open findings will be due by January 15, 2008, April 15, 2008, and each calendar quarter thereafter until FTA releases KCATA from this reporting requirement. FTA will attempt to respond to each quarterly report that it receives from KCATA, but please note that the quarterly reports are due from KCATA regardless of whether FTA has responded to the previous report.

We recognize the progress that you have made in responding to the findings of the review as presented in your June 13, 2007 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. Stop Announcement and Route Identification Requirements

Finding: In Subsection D of the Disability Awareness Section of its Metro Operator Training Manual and Resource Guide, KCATA requires its operators to announce transfer points and destination points on fixed routes. Operators are required to “announce stops upon the request of a person with a disability. The ADA requires that stops be announced sufficiently to permit individuals with visual impairments or other disabilities (observable or hidden) to be oriented to their location.”

Corrective Action Proposed by KCATA: Subsection D of the Disability Awareness Section of the Metro Operator Training Manual and Resource Guide (MOTM&RG) has been revised, and reads as follows:
11) …...The ADA requires that stops be announced at sufficient intervals to permit individuals with visual impairments or other disabilities (observable or hidden) to be oriented to their location (underscore added for emphasis). See attachment.

Reinforcement through continued training is ongoing.

Clarification of Corrective Action: Does KCATA have any plans to incorporate the stop lists provided to operators into the operators training, instruction and monitoring?

Operator announcement of the stops on lists developed to comply with the requirements of the DOT ADA regulations, rather than reliance upon operator judgment, should result in better compliance with the regulations. Operator use of the stop lists will ensure consistency between the stops announced automatically and those announced by operators and facilitate monitoring of operator performance. The consistency of announcements will make it easier for regular customers who depend on the stop announcements to orient themselves on the route. 

Finding: KCATA does not require operators to identify their route to customers waiting at stops shared by more than one route. In Subsection D of the Disability Awareness Section of its Metro Operator Training Manual and Resource Guide, KCATA requests operators to announce, outside their bus, their route number at transfer points and bus stops serviced by other routes.

Corrective Actions Proposed by KCATA: Subsection D of the Disability Awareness Section of the MOTM&RG has been revised, and reads as follows:
12) Operators shall announce outside their bus, their route number at transfer points and bus stops serviced by other routes.

(Underscore, bold and word change added for emphasis).

Clarification of Corrective Action: If the operator fails to stop and curb the bus and open the door when making route announcements, many waiting customers may not hear the announcement. Does KCATA include curbing and stopping the bus and opening the door in its training for making route announcements? 

It is suggested that operators be instructed to announce the route destination as well as the route number to make it easier for the customer to identify the route and to identify the direction of travel of the bus.

Finding: KCATA issues a list of stops to be announced, with changes as they occur, to operators in a ring-bound handbook. Road Supervisors, who are responsible for field location of bus stops, are responsible for reporting changes to schedulers, who maintain the stop lists. According to KCATA managers, road supervisors do not always report stop changes. This can result in inaccurate stop lists.

Corrective Actions Proposed by KCATA: Road Supervisors are not principally responsible for the field location of bus stops. Instead, any changes (additions or removals) are most likely to occur as a result of a service planning decision with the concurrence of the KCATA Manager of Road Supervisors. The Manager of road Supervisors directs the activities of the Union job position, which is responsible for the installation of all such bus stops. Going forward, all changes will be coordinated between the Manager of Road Supervisors and the Manger of the Scheduling Unit, so that accuracy can be ensured.

Clarification of Corrective Action: Will the coordination of stop changes (additions, deletions or relocations) be recorded in a work order type system, or similar system to document the date and source of the initial request, concurrence of both managers in the stop change and date of completion of the stop change? A simple tracking procedure could be helpful in avoiding miscommunication.

2. Stop Announcements

Finding: Of 58 observations of route segments, no stop announcements were made on 11 (19 percent) of the routes.

Corrective Actions Proposed by KCATA: KCATA intends to expand its current secret rider program for stop announcements monitoring purposes. 
Further, KCATA will continue to troubleshoot and correct GPS interruptions, odometer discrepancies, etc., and inoperable bus speaker systems. In fact, the entire fleet has been inspected for inoperable bus speaker systems. Repair and replacement has already occurred. 

Lastly, an Operator Vehicle Report has been made available to bus operators for the purpose of reporting any such announcement issues/problems. See attachment.

Additional Reporting: Please provide a copy of reports for the most recent month, for stop announcements observed by secret riders; operator reported announcement and display sign problems; and automated system inspection results. The reports should include the number of observations as well as the results of the observations/inspections. 

Please also provide information on discipline of operators that is related to failure to perform stop announcements. Specifically, please report on the number of operators disciplined for failure to announce stops and the type(s) of discipline that each received.

8. Finding: Two of twelve operators interviewed said that they report a malfunctioning public address system when identified; the other ten operators said that they do not.

Corrective Actions Proposed by KCATA: KCATA will instruct (through training and information) its operators to report malfunctioning PA systems. 
Bus operators will be instructed to report any findings on either a “bad order” card or an “operator vehicle report card” (see previously referenced attachment).

Clarification of Corrective Action: Does KCATA propose a program to monitor operator reporting of inoperable Automated Announcement Systems, beyond reliance upon operators to respond to training and instruction, particularly in view of the low level of operator reporting identified in interviews? 

9. Finding: There appears to be a large number of vehicles with automated stop announcement systems that are either not turned on or are not reported and recorded as needing repair. The automated stop announcement equipment was not working on 14 (24 percent) of the 58 buses observed. Assuming the same failure rate for all KCATA vehicles, approximately 53 of the approximately 220 buses used in daily service will have inoperable automated announcement systems. As reported in Section 3.5, an average of 10.6 automated stop announcement systems are repaired per week or 2 or 3 repairs per day. The discrepancy between 53 inoperable systems and two to three daily repairs indicates that many systems are either operational and not turned on properly, or inoperable and not reported and recorded as in need of repair.

Corrective Actions Proposed by KCATA: All vehicles are equipped with the Automated Announcement System. Inoperable speaker systems have been replaced.
KCATA will continue to inspect and repair/replace the audio hardware.

Additional Reporting: Please provide a report for the most recent month in the reporting period identifying the number of Automated Announcement Systems inspected, the number of inoperable systems identified, and the number of systems repaired. See 2.1.

11. Finding: About half of the operators were not aware that the buses had a public address system that could be used for voice announcements.

Corrective Actions Proposed by KCATA: KCATA initiated a Bus Operator Refresher Training Program in June 06. Bus Operators are required to attend the eight-hour training course on a biennial basis. The course curriculum has been adjusted, so that the use of the on board PA system is covered. 

Further, KCATA will arrange for informal, yet focused, training on this matter in the bus operator waiting area.

Additional Reporting: Please provide copies of any training materials that address operator use of the Automated Announcement System and manual use of the PA component of the system.

3. Route Identification

1. Finding: The review team observed only one route announcement in 68 observations.

Corrective Actions Proposed by KCATA: KCATA will revise its operator training (New Hire and Refresher) to ensure that operators understand the requirement to make route announcements at any shared stops. 

Relevant informational bulletins have already been directed to KCATA’s bus operator workforce.
Again, the relevant work rules have been revised and field supervisors have been trained

Additional Reporting: Please provide a copy of reports for the most recent month for route announcements observed by secret riders, and any other reports on monitoring of stop announcements. The reports should include the number of observations as well as the results of the observations. 

Please also provide information on discipline of operators that is related to failure to perform route announcements. Specifically, please report on the number of operators disciplined for failure to announce routes and the type(s) of discipline that each received.

4. Finding: A number of operators were observed stopping only in response to a signal from waiting customers.

Corrective Actions Proposed by KCATA: Rule 6.1 in the KCATA Manual of Instruction, Operating Rules and Discipline Code states,
“Operators will not pass up passengers.” For those confirmed infractions of the work rule, three step progressive discipline is imposed – one-day suspension, three-day suspension, and discharge. 
Secret riders and field supervisors have been directed to more closely monitor for this operational infraction. 

Secret riders will observe specifically whether a bus comes to a complete stop at shared stop locations for the purpose of providing the external route ID announcement.

Additional Reporting: Please include observations of operators stopping for waiting passengers at shared stops, with secret rider reports for the most recent month as requested in 3.1.

In addition to the information on discipline of operators that is related to failure to perform route announcements (see Finding 3.1), please provide information on disciplinary actions related to failure to stop.

We recognize the efforts that KCATA 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 VII Civil Rights Officer at the following address:

Mr. Thomas C. Harris
Civil Rights Officer, Region VII
Federal Transit Administration 
901 Locust Street, Room 404
Kansas City, MO 64106


Sincerely,

David Knight
ADA Team Leader

Enclosures

cc: 
Mokhtee Ahmad, FTA Region VII Administrator
Cindy Terwilliger, FTA Region VII Supervisory Senior Operations Manager
Thomas Harris, FTA Region VII Civil Rights Officer
Don Kidston, Planners Collaborative, Inc.

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