1. Reasonable Modification
Impacts and Opportunities
CalACT Spring Conference
Thursday, April 25, 2019
Hej, hej
Why this session was selected for this CalACT conference
2015 FTA produced the legal language for Reasonable Modification.
While it was in development, there were genuine concerns about how Reasonable Modification, Origin to Destination, etc. would impact public transport
It has been almost four years since RM’s adoption and it seemed a good time to have a discussion on the impacts that it has had on fixed route and paratransit and also – one of the things that I personally think is very interesting – which are the opportunities for agencies and providing greater assistance to customers.

2. Access Services – Los Angeles, CA
Background
Created in 1994 by L.A. Metro Board to provide mandated ADA paratransit
Created as an independent transit agency
Contract paratransit and eligibility services
Meets ADA obligation for 45 member agencies – incl. Metro, LADOT, Foothill Transit
Services for persons who cannot use fixed-route independently for some or all transport needs
For background purposes, Access Services is the only ADA paratransit provider for Los Angeles County.
Access was created as an independent transit agency in 1994 for the purpose of providing ADA paratransit transportation.
Access is structured with a small central administrative staff and vehicle services, eligibility services, etc. are contracted out.
Access is a partner for all 45 fixed route providers in Los Angeles County, so each of Los Angeles County’s fixed route providers can concentrate on providing fixed route services and their ADA mandated services are provided through Access.
Lastly, Access’ customer base is made up of persons who would find it very challenging or impossible to ride the fixed route services of L.A. on their own.

3. What is Access’ Service Area?
Access is the single ADA complementary paratransit system for the 45 fixed route agencies of Los Angeles County.
Access’ service area covers almost all of the urbanized area of Los Angeles County

4. Access Services 4.4 million passengers 3.4 million trips
Fiscal Year 2018 Statistics
4.4 million passengers
3.4 million trips
157,560 eligible customers
92.1% on-time performance
20 minute window

5. Modified Paratransit Services
Reasonable Modification
Beyond the Curb (Origin to Destination)

6. Reasonable Modification
A reasonable modification for purposes of complementary ADA paratransit
is a modification to Access’ policies, practices, or procedures
that is requested by an eligible customer
to ensure that they are able to use the paratransit system

7. Beyond the Curb
Limited Change to Traditional Curb-to-Curb Service
Purpose: That some individuals could not utilize paratransit service but for this additional aid
Initial concerns from agencies and customers
Agencies indicated 1/3 of all trips transitioned to Origin to Destination
Customer telephone survey showed 35% to 73% of customers would utilize Beyond the Curb
Turning off vehicle concerns: climate control for passengers & service animals

8. Beyond the Curb Driver to not go farther than 60’
Elements
Driver to not go farther than 60’
Always maintain visual contact with vehicle
Cannot enter private property doorways
Cannot assist beyond ground level
Can assist and carry parcels that meet Access policy

9. When may Reasonable Modification Requests be Denied?
Granting the request would fundamentally alter the nature of Access’ service, programs, or procedures;
Granting the request would create a direct threat to the health or safety of others;
It is determined that the customer is able to fully use the services, programs, or activities for their intended purpose without the modification;
Granting the request would cause an unreasonable financial or administrative burden

10. Reasonable Modification / Beyond the Curb
Eligibility
All new Access applicants are evaluated for Beyond the Curb service
Current customers fill out RM/BTC form
Eligibility process determine regular or occasional need for RM/BTC
Customer can request Beyond the Curb at time of trip reservation (Next day service)
Customer can request Beyond the Curb service during trip – is accommodated as best as possible

11. Reasonable Modification / Beyond the Curb
Eligibility Form

12. Reasonable Modification / Beyond the Curb
Information to Contractors
This was a poster Access prepared for its Operator and Dispatch contractors to give a very high-level overview of the Beyond the Curb and Reasonable Modification program. Access has its County-wide service area split into 6 different regions, with service provided by 4 different contractors.
I include this, as one of the things that Access felt was very important was to ensure that Access and each contractor are speaking the same language.
It is just important that customers expectations are met similarly throughout the service.
A problem and a delight that we probably all have and maybe even more in paratransit or Demand-Response, is we have drivers who are compassionate for our customers who ride the service and the drivers get to know and they are willing to help with bags or escorting away from the vehicle, but with this new policy, it is important that customers receive similar levels of service from different drivers and in different regions. Similar to a McDonald’s Principle: There are thousands of McDonald’s employees around the world, but no matter where you are, you can expect a certain level of service from any franchisee in the system.

13. Reasonable Modification / Beyond the Curb
Statistics
Between July 2017 and February 2019
Average monthly trips: 280,000
Average monthly RM applications submitted: 45
Average monthly BTC requests at reservation: 2,200 (or 0.8%)

14. Reasonable Modification / Beyond the Curb
Statistics
Common RM Request Purposes:
Van Only
Sedan Only
Gated Communities
Driveway Drop-offs
No Share Ride
Service Area Extension

15. Develop Policies for Frequent Requests
Gated Communities
Rule: Not enter gated communities
Modification allowed when
Manned security post, or
Provided Gate Code that opens gate (not a phone number)
Code is issued to Access
Permission to use Code given by Property Management or HOA
Code & facilities checked by Access Safety Inspectors
Hold for statistics

16. Reasonable Modification – Service Opportunities
Reasonable Modification purpose:
individuals could not utilize paratransit service but for this additional aid
Ability to introduce exceptions to rules without eliminating principal rules
Provides opportunity for trial exceptions
Removing certain rules which constitute barriers (1 hour wait time between trips)

17. Thank you