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USDOT ADA Service Requirements
Ann Beauvais, RAE Consultants, Inc. Dan Wagner, Precision Compliance, Inc. AzTA/ADOT Annual Transit Conference April 2016
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USDOT ADA Requirements Session Focus
Discuss ADA requirements Present good practices Answer your questions
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USDOT ADA Requirements Common Deficiencies
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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
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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
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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
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USDOT ADA Requirements ADA Complaint Procedures
Options Develop separate procedures Incorporate into Title VI notice and complaint procedures Address in general complaint procedures
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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”
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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)
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USDOT ADA Requirements Examples
Here and There Transit Central West Virginia Transit Authority
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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
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USDOT ADA Requirements Service Provisions
Common Wheelchair
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USDOT ADA Requirements Service Provisions
Service animals Driver assistance Lift/ramp deployment Lifts/ramps for standees Lift/ramp failures Alternative service (fixed route)
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USDOT ADA Requirements Vehicle Accessibility
Fixed route Demand response ADA paratransit
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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
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USDOT ADA Requirements Route Deviation
Open to general public Promote to general public Provide information on how to request Discuss any surcharges
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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USDOT ADA Requirements Questions / Discussion
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USDOT ADA Service Requirements
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