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.

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.

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

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

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

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

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

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

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

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

Reasonable Modification / Beyond the Curb Eligibility Form

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.

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%)

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

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

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)

Thank you