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MARTA ADA Compliance Review - December 3, 2012

Location: Atlanta, GA  
Date of Final Report: December 3, 2012

Metropolitan Atlanta Rapid Transit Authority (MARTA) Transmittal Letter

December 3, 2012

Dear Dr. Scott:

This letter concerns the Federal Transit Administration's (FTA) ADA Complementary paratransit service review of the Metropolitan Atlanta Rapid Transit Authority (MARTA), which was performed from February 9-12, 2009. FTA would like to thank you and your staff for the cooperation provided during the review. As we received no response from MARTA to our request for corrections or substantive updates to the draft report, th is report is now final. A copy of the Final Report is enclosed, and will be posted on FTA's website on our ADA page.

At this time, we ask MARTA to provide a written response by January 4, 2013 listing its proposed corrective actions (and implementation dates) to address the specific findings in the Final Report.

In addition to the findings described in the report, FTA has also identified several issues concerning MARTA's public information - particularly the PDF version of the MARTA Mobility Guide on MARTA's website - that require attention. Because these policy revisions were implemented and/or identified after the site visit, they are not included in the Final Repot1 and will be addressed outside of the compliance review process; however, many of these additional issues are relevant to the findings contained in this report. Whether MART A elects to address and report on these issues separately or in concert with the findings contained in this repot1 is a matter for MARTA to determine. These additional issues are as follows:

  • The MARTA Mobility Guide (page 15), states that the duration of a paratransit trip ';may be twice as long as a fixed route trip." This is inconsistent with the standard in place at the time of the review, which was the fixed route travel time for the same trip plus 30 minutes to account for walking, transfers, and waiting time as part of a fixed route trip. The standard in place at the time of the site visit was consistent with the DOT ADA regulations and FTA technical assistance; the standard in the subsequent Guide is not. A revised standard for on-board travel time is needed, as is a plan for monitoring the on-board time that Mobility riders experience.
  • The Guide suggests on page 23 that customers with vision impairments are required to confirm reservations to obtain driver assistance. FTA requests clarification of this policy.
  • Due to the removal of the term "common wheelchair" from the DOT ADA regulations ( 49 CFR 37 .3), the Guide (Pages 26- 27) and other public information should be revised to delete references to this term. Effective October 19, 20 I I, the term "wheelchair" was revised to mean "a mobility aid belonging to any class of three- or more-wheeled devices, usable indoors, designed or modified for and used by individuals with mobility impaim1ents, whether operated manually or powered." FT A directs MARTA to revise public information accordingly and submit the revised information to FTA.
  • The Guide states on page 31 that MARTA looks for a pattern and practice of missed trips by the patron; however, it does not describe how MARTA determines that a pattern or practice of missing scheduled trips exists for any of the suspension periods. The Guide also omits imp011ant information concerning a stay of the suspension pending the outcome of an appeal. Most importantly, however, the suspension policy must be revised to provide for reasonable time periods for suspension of service, as the suspension periods in the Guide are excessive. These revisions are required in addition to those detailed in Finding 9.8.6 in the Final Report.
  • At the time of the review, MARTA's unwritten transfer policies appeared to be vague and potentially subject to change based on a particular dispatcher's discretion. FTA requests a current copy of MARTA's transfer policies for Mobility customers transferring between MARTA vehicles within MARTA Mobility's service area.

Please provide MARTA's corrective action plan and responses by January 4, 2013 electronically to Susan Clark, Equal Opportunity Specialist, via email at sue.cfark@dot.gov with a copy to Carlos Gonzalez, FTA Region 4 Civil Rights Officer, at carlos.gonzafez3@dot.gov. lf you have any questions, please contact Susan Clark at (202) 493-0511 or at her e-mail address above. Thank you.


Sincerely,

John R. Day
ADA Team Leader
FTA Office of Civil Rights

Enclosures
cc: Sharon C. Crenchaw, Director, MARTA Mobility
Yvette G. Taylor - Regional Administrator, FTA Region 4
Carlos Gonzalez, Regional Civil Rights Officer, FTA Region 4
Frederick L. Daniels, Jr., Chairman, MARTA Board of Directors (copy enclosed)
Office of the Board of Directors
MARTA
2424 Piedmont Road, NE
Atlanta, GA 30324

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