1. USDOT ADA Service Requirements
Ann Beauvais, RAE Consultants, Inc.
Dan Wagner, Precision Compliance, Inc.
AzTA/ADOT Annual Transit Conference
April 2016

2. USDOT ADA Requirements Session Focus
Discuss ADA requirements
Present good practices
Answer your questions

3. USDOT ADA Requirements Common Deficiencies

4. USDOT ADA Requirements Common Deficiencies
#1: Asset Management
Preventive Maintenance Program / Procedures
Vehicles
Facilities
ADA Equipment
#2: ADA Service Provision
General Policies and Procedures
Route Deviation Information
Complementary Paratransit Requirements

5. USDOT ADA Requirements Common Deficiencies
#3: Financial Management
Reimbursement Support Documentation Lacking
Incorrect Time Allocation to Transit
Fare Collection Procedures
#4: Procurement
FTA Clauses
SAM.gov Search
Policies and Procedures
Fuel, Oil and Maintenance Contracts

6. USDOT ADA Requirements ADA Complaint Procedures
Are required effective July 13, 2015
Incorporate due process standards
Provide for prompt and equitable resolution
Must advertise
Must respond promptly

7. USDOT ADA Requirements ADA Complaint Procedures
Options
Develop separate procedures
Incorporate into Title VI notice and complaint procedures
Address in general complaint procedures

8. USDOT ADA Requirements Reasonable Modification
Effective as of July 13, 2015
May rely on existing process or develop a new process
Provide information that is accessible to the public
May require advance notice but flexibility for on-the-spot requests is needed
May not require persons to use term “reasonable modification”

9. USDOT ADA Requirements Public Information
Let the public know that your service is accessible
Promote the accessibility of fixed-route service
Post all documents on website in “readable” formats (native pdf, HTML)

10. USDOT ADA Requirements Examples
Here and There Transit
Central West Virginia Transit Authority

11. USDOT ADA Requirements Service Provisions
Stop announcements (fixed route)
Vehicle ID mechanisms (fixed route)
Priority seating
Wheelchair securement
Transfers from a wheelchair to a seat
Seatbelts
Weight/size restrictions

12. USDOT ADA Requirements Service Provisions
Common Wheelchair

13. USDOT ADA Requirements Service Provisions
Service animals
Driver assistance
Lift/ramp deployment
Lifts/ramps for standees
Lift/ramp failures
Alternative service (fixed route)

14. USDOT ADA Requirements Vehicle Accessibility
Fixed route
Demand response
ADA paratransit

15. USDOT ADA Requirements Equivalent Service
Response time
Fares
Geographic service area
Hours and days of service
Restrictions on trip priorities based on trip purpose
Availability of information and reservation capability
Constraints on capacity or service availability

16. USDOT ADA Requirements Route Deviation
Open to general public
Promote to general public
Provide information on how to request
Discuss any surcharges

17. USDOT ADA Requirements Commuter Bus Service
Commuter bus service means fixed route bus service, characterized by service predominantly in one direction during peak periods, limited stops, use of multi-ride tickets, and routes of extended length, usually between the central business district and outlying suburbs. Commuter bus service may also include other service, characterized by a limited route structure, limited stops, and a coordinated relationship to another mode of transportation.

18. USDOT ADA Requirements Commuter Bus Service
Other Characteristics
No attempt to comprehensively cover a service area
Limited route structure
Limited origins and destinations
Interface with another mode of transportation
Limited purposes of travel

19. USDOT ADA Requirements Complementary Paratransit
Eligibility
Strictly limited
Decision with 21 days
Decision letter contents
Appeal decision within 30 days
Not dependent on location of residence

20. USDOT ADA Requirements Complementary Paratransit
Visitors Policy
Documentation that certified in home location
Documentation of disability if not apparent
Proof of residency
Eligible for 21 days of service over a year’s period

21. USDOT ADA Requirements Complementary Paratransit
Service Characteristics
Origin-to-destination service
Same days and hours as fixed-route service
¾ mile of routes and core service area
No priorities based on trip purpose
Personal care attendants and companions

22. USDOT ADA Requirements Complementary Paratransit
Fares
Eligible riders pay no more than twice the fixed-route fare
PCAs pay no fare
Companions pay ADA paratransit fare

23. USDOT ADA Requirements Complementary Paratransit
Reservations
Scheduled day before up to 14 days in advance
No requirement for same-day trips
Accepted during office hours
Accepted all days prior
Answering machines OK
No restrictions on number of reservations
No waiting lists

24. USDOT ADA Requirements Complementary Paratransit
No practice or pattern of capacity constraints
Reservations
Denials
Missed trips
Excessively long trips
Tracked separately if service open to others

25. USDOT ADA Requirements Complementary Paratransit
No-show Policy
Is allowed, not required
May not assess financial penalties
Count only no-shows under the rider’s control
May count late cancellations within two hours or less as no-shows
Must take into account frequency of travel
Must provide for appeal of suspensions
Ensure lengths of suspensions are “reasonable”
Can provide for progressive discipline

26. USDOT ADA Requirements Questions / Discussion

27. USDOT ADA Service Requirements