Location: Memphis, TN
Date of Final Review: May 13, 2009

Memphis Area Transit Authority (MATA) - Stop Announcement/Route Identification  Transmittal Letter

May 13, 2009

Mr. William Hudson, Jr.
President-General Manager
Memphis Area Transit Authority
1370 Levee Road
Memphis, TN 38108

Dear Mr. Hudson:

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) Route Identification and Stop Announcements compliance review conducted October 15 to 18, 2007 of the Memphis Area Transit Authority (MATA). Enclosed is the Final Report that incorporates MATA’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, and it will be posted on FTA’s website.

Also enclosed with this letter is an updated progress table listing FTA’s understanding of the corrective actions either planned or taken by MATA 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 additional documentation of results and outcomes
• Requested MATA to clarify corrective actions that are not fully specific

Please continue to use the enclosed table as the format to report progress to FTA on the corrective actions that MATA 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.

We note that MATA expects to have addressed 11 of the findings by the end of February 2009, and all but two of the findings are expected to be addressed by the end of July 2009. The first report will be due July 15, 2009 and should cover the period of January through May 2009. Additional reports will be due by October 15, 2009 and January 15, 2009 and each calendar quarter thereafter until FTA releases MATA from this reporting requirement.

We recognize the steps you have taken or will take to improve MATA’s route identification and stop announcements performance, as presented in your January 16, 2009, 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.

A. Stop Announcement and Route Identification Requirements

Finding. Although MATA has a policy of listing the route numbers serving a particular stop on the bus stop sign, not all signs are marked. In addition, MATA advises passengers to signal operators to stop, which may be difficult or impossible for individuals with vision impairments or other disabilities.

December 2008 Corrective Action Proposed by MATA: Eliminate website references to passengers signaling the operator to stop at a bus stop; eliminate website references to route numbers posted on bus stop signs. These policies are not included in any of MATA’s training materials.

Clarification of Finding: Please note that FTA was not recommending that route numbers be eliminated from bus stop signs. In fact, while not required by the ADA, including route numbers (that are sufficiently large as described in the ADA Accessibility Guidelines) on the stop signs is helpful to waiting passengers.

Clarification of Corrective Action: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken.

Finding. Although the MATA Operator Training Manual references the need to announce stops, it does not include instructions on making external route announcements.

December 2008 Corrective Action Proposed by MATA: Incorporate instructions in operator Training Manual. For making external route announcements, issue bulletins to operators.

Clarification of Corrective Action: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken. Please provide a copy of the materials provided to the drivers.

Finding. MATA buses do not have automated announcement systems. Buses are equipped with internal speakers, external speakers, and a microphone to help operators announce stops and routes. While DOT ADA regulations do not require automated announcement systems, they can be useful in assisting operators to meet the requirements under 49 CFR §37.167(b) that stops be announced.

December 2008 Corrective Action Proposed by MATA: Install automated stop annunciation system.

Additional Reporting: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken.

Finding. MATA currently uses on-board cameras to randomly review whether operators announce stops and make route identification announcements. Twenty-nine percent of the buses have on-board cameras; all buses have public address systems with microphones. Monitoring primarily through use of onboard cameras may not capture all instances of inadequate performance of required announcements.

December 2008 Corrective Action Proposed by MATA: (a) Increase use of supervisors for field checking of operator compliance. (b) Install cameras on all fixed route buses.

Clarification of Corrective Action: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken.

Finding. According to the monitoring log from the data from on-board cameras, 83 percent of operators were calling out stops between January and mid-October 2007.

December 2008 Corrective Action Proposed by MATA: Implement campaign to increase driver compliance in calling out stops.

Clarification of Corrective Action: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken. Please provide a copy of the materials provided to the drivers.

Finding. There were no observations included in the monitoring log citing a failure to make external route identification announcements without also failing to announce stops. Given the observations of consumers and the review team, this suggests that MATA is not carefully reviewing the video for external route identification announcements.

December 2008 Corrective Action Proposed by MATA: (a) Increase use of supervisors for field checking of operator compliance in making external route identification announcements. (b) Instruct persons reviewing video to separately log internal and external stop announcement violations.

Clarification of Corrective Action: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken.

Finding. MATA does not have a pre-trip inspection form. MATA relies on its operators to fill out a “Trouble Report Job Assignment Card” when they find that the PA system is not working.

December 2008 Corrective Action Proposed by MATA: Implement a mandatory Pre-Trip Inspection Form for operators.

Clarification of Corrective Action: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken. Please provide a copy of the materials provided to the drivers.

B. Stop Announcements

Finding. Of the 38 route segments observed by the review team: 29 percent (11 operators) made more than two-thirds of the required announcements; 32 percent (12 operators) made from one-third to two-thirds of the required announcements; 24 percent (9 operators) made fewer than one-third of the required announcements; and 16 percent (6 operators) made no announcements.

December 2008 Corrective Action Proposed by MATA: Implement campaign to increase driver compliance in making stop announcements.
Clarification of Corrective Action: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken. Please provide a copy of the materials provided to the drivers.

Finding. Collectively, the MATA operators made 227 stop announcements. Review team members determined that 162 of the announcements (73 percent) were loud and clear enough for most passengers to hear and understand.

December 2008 Corrective Action Proposed by MATA: Implement campaign to increase driver compliance in making loud and clear stop announcements.

Clarification of Corrective Action: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken. Please provide a copy of the materials provided to the drivers.

Finding. MATA operators made 165 of 333 of the MATA-required announcements (49.5 percent) based on the time points and transfer points noted on MATA’s public timetables.

December 2008 Corrective Action Proposed by MATA: (a) Implement campaign to increase driver compliance in calling out time points and transfer points. (b) Create and provide drivers with route-specific lists of stops, transfer points, major intersections, and major destinations for operators to announce.

Clarification of Corrective Action: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken. Please provide a copy of the materials provided to the drivers, including the list of stops to be called for every bus route.

Finding. On routes with long intervals between transfer points, MATA operators typically did not announce intersections or destinations with sufficient frequency to orient passengers.

December 2008 Corrective Action Proposed by MATA: Include in the route-specific list, major intersections and major destinations sufficient to orient passengers where there are long intervals between transfer points 

Additional Reporting: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken. Please provide a copy of the materials provided to the drivers, including the list of stops to be called for every bus route.

Finding. When making stop announcements, MATA operators often made the announcements at or after the bus passed the stop.

December 2008 Corrective Action Proposed by MATA: Implement campaign to insure that operators make stop announcements sufficiently in advance of arriving at the stop for a rider to be able to alight at the desired stop.

Clarification of Corrective Action: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken. Please provide a copy of the materials provided to the drivers.

C. Route Identification

Finding. The review team observed only two route identification announcements in 47 observations, a rate of 4 percent.

December 2008 Corrective Action Proposed by MATA: Implement campaign to increase driver compliance in route identification announcements.

Clarification of Corrective Action: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken. Please provide a copy of the materials provided to the drivers.

Finding. At North End Terminal, the downtown terminal for 25 of MATA’s 35 bus routes, there is limited information for a passenger who wants to transfer between bus routes. There are no signs that indicate which bus routes stop at either of the two bus lanes. There are no audio announcements for buses arriving or departing the terminal. The only source of information identifying the lane to use is a MATA-staffed information booth inside the facility.

December 2008 Corrective Action Proposed by MATA: Implement signage designating routes that stop at east side bays and west side bays at North End Terminal; implement external signage at American Way Transit Center.

Clarification of Corrective Action: Please provide an update in the next quarterly report regarding the status of this effort, including a description of the specific steps being taken.

We recognize the efforts that MATA 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 Sue Clark for this review, at (202) 493-0511 or via e-mail at susan.a.clark@dot.gov.

It would also be helpful if you would provide electronic copies of all correspondence to this office by e-mail to Mr. Frank Billue, FTA Region IV Civil Rights Officer, at frank.billue@dot.gov.

Sincerely,

Cheryl L. Hershey
Director
Office of Civil Rights

Enclosures

cc: Yvette G. Taylor, FTA Region IV Administrator
Frank Billue, FTA Region IV Civil Rights Officer
Dudley Whyte, FTA Region IV Director of Operations & Program Management