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RTA ADA Compliance Review - March 1, 2012

Location: Riverside, CA 
Date of Final Report: March 1, 2012   

Riverside Transit Agency (RTA) Transmittal Letter

March 1, 2012

Dear Mr. Rubio:

Thank you for your response to the Federal Transit Administration's (FTA) Americans with Disabilities Act of 1990 (ADA) Complementary Para transit Service Review of the Riverside Transit Authority (RTA), which was performed from February 2-5, 2004. FT A would like to thank you and your staff for the cooperation provided during the review. At that time, you were informed that FT A would issue a draft report of the findings, on which RT A would have an opportunity to provide comment, following which a final report would be released. RTA's comments were to be included in the attachments to the final report.

Upon receiving RTA's comments to the draft report on July 27, 2011, and our subsequent phone call with your agency in mid-November to discuss the revised Compliance Review process, this report is now considered a Final Report. A copy so marked is enclosed for your records. 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.

FTA recognizes that is has been over eight years since our on-site review and changes have likely occurred in RTA's transit program. This report reflects the observations of our review team at the time of the on-site review, and information submitted by RTA in response to the findings made at that time; it is not intended to address RTA's current state of overall compliance with DOT ADA regulations, which may be affected by factors beyond the scope of this review. We appreciate the cooperation and assistance that you and your staff have provided us during the review. A corrective action plan addressing the findings from this review will be developed in consultation with RTA, and FT A will work diligently with RTA to ensure compliance with DOT ADA regulations.

Contained within this letter is a summary of the findings of non-compliance made in the report. FTA recognizes your July 27, 2011 correspondence responded to the findings made in the report. Now that PTA's compliance review of RTA is finalized, FTA will work collaboratively with RTA in reviewing the adequacy of your responses and determining which, if any, open findings require additional reporting.

OPEN FINDINGS:

A. Service Criteria

  1. The DOT ADA regulations at 49 C.P.R. § 37.13 I requires that entities shall provide complementary paratransit service to origins and destinations within corridors with a width of 3/4-mile on each side of each fixed route. The corridor shall also include an area with a 3/4-mile radius at the ends of each fixed route. RTA does not provide ADA complementary paratransit service within 3/4-mile of fixed route services that it operates in San Bernardino County.
  2. The DOT ADA regulations are 49 C.P.R. § 37.12 I requires that public entities operating a fixed-route system provide paratransit service to individuals with disabilities that is comparable to the level of service provided to individuals without disabilities who use the fixed route system. It appears that RTA may not provide service during the same days and hours as fixed route service. Some fixed route services operate between 3:51 AM and 10:19 PM on weekdays and from 5:30AM and 9:53PM on Saturday and Sunday. The scope of one of the operating contracts limits service hours to 5:00AM to 10:00 PM Monday through Friday, 6:00AM to 7:30PM on Saturday and 6:30AM to 9:30PM on Sunday.
  3. Fares for trips made between two points near an intercity fixed route could require two transfers using Dial-A-Ride services resulting in a maximum fare of $9.00 per on-way trip. This would exceed the twice the fixed route fare of $1.50 for the same trip. The DOT ADA regulations at 49 C.P.R. § 37.131(c) require that the fare for ADA complementary paratransit service be no more than two times the base fare for a comparable fixed route trip.
  4. Although RTA is responsible for providing ADA complementary paratransit service for fixed route service it operates in Corona and Riverside, the MOUs provide no mechanism for monitoring the services provided by the Cities or implementing corrective action if the service fails to meet the requirements of the ADA.

B. ADA Complementary Paratransit Eligibility Determinations

  1. To request an appeal, RTA instructs individuals to write a brief letter making the request and indicating why they feel the decision was unsatisfactory or incorrect. DOT ADA regulations at 49 C.P.R. § I 25(g)(2) state that while RTA may require that the individual appealing make the request in writing, RTA can request but not require the appellant to provide documentation of the basis for the appeal. RTA must allow the individual (and/or a representative) an opportunity to be heard based on either an oral or written request.

D. Reservations and Scheduling

  1. Confirmation of the outcome of call-backs to riders to inform them of changes in pickup times did not appear to be recorded on the hold/call-back lists. One of the recurring complaints of customers was that they did not receive notification of schedule changes. Changing pickup times without notifying customers can result in missed or late trips based upon the time negotiated with the customer.

E. Service Performance

  1. Trips complying with RTA's goal for trip length could be excessively long compared to fixed route trips between the same origin and destination. For example, if an ADA complementary paratransit trip were three hours long and the fixed route trip from the same origin to the same destination were 1-1/2 hours, the trip would comply with RTA's goal. However, such an ADA complementary paratransit trip would not provide a comparable level of service to fixed route, as is required under DOT ADA regulation 49 C.P.R. § 37.121, and would be considered an excessively long trip.

G. City Services

  1. The DOT ADA regulations at 49 C.P.R.§ 37.131(b)(2) permit transit providers to negotiate pickup times with riders, but cannot require an ADA eligible individual to schedule a trip to begin more than one hour before or after their desired pickup time. The current reservations and scheduling system does not retain the pickup times requested by riders. Other than first-hand observation of the service, there is no way to ensure that negotiated ride times are within an hour of the requested times as required by the ADA regulations.

Please provide your response within 30 days of the date of this letter. Should you have any questions about the enclosed report or this letter, please contact Aaron Meyers of my staff at (202) 366-2055 or via at aaron.meyers@dot.gov, with a copy to Monica McCallum, Regional Operations Division Chief, at monica.mccallum@dot.gov.

Sincerely,

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

Enclosure
cc: Linda Ford, Acting Director, FTA Office of Civil Rights
Leslie T. Rogers, Regional Administrator, FTA Region 9
Monica McCallum, Regional Operations Division Chief
Chris MacNeith, Regional Civil Rights Officer, Region 9
Derrin Jordan, Regional Civil Rights Officer, Region 9
David Chia, Planners Collaborative

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