**Autoridad Metropolitana de Autobuses (AMA)**

**Metropolitan Bus Authority (MBA)**

**San Juan, Puerto Rico**

**Review of Lift Reliability and Maintenance**

**for**

**Operation of Accessible Fixed Route Bus Service**

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**March 5-8, 2007**

***Summary of Observations***

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, DC**

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**Prepared by**

**Planners Collaborative Inc.**

**with**

**TranSystems Corp.**

**Final Report: October 15, 2007**

**CONTENTS**

[]{.mark}

[1 Purpose of the Review 1](#purpose-of-the-review)

[2 Background 3](#background)

[3 Overview of the Review 5](#overview-of-the-review)

[4 Observations of Lift and Ramp Reliability & Maintenance
9](#observations-of-lift-and-ramp-reliability-maintenance)

[4.1 Consumer Input 9](#consumer-input)

[4.2 AMA's Policies and Procedures Regarding Lifts
12](#__RefHeading___Toc178096536)

[4.3 Review Team Observations 18](#review-team-observations)

[5 Findings and Recommendations 35](#findings-and-recommendations)

[5.1 Findings 35](#findings)

[5.2 Recommendations 39](#recommendations)

**List of Tables**

[Table 4.1 -- Sample of AMA Complaints for 2006
12](#__RefHeading___Toc178096791)

[Table 4.2 -- AMA Fleet Roster -- February 2007
16](#__RefHeading___Toc178096792)

[Table 4.3 -- Summary of AMA Pull-out Observations, March 6, 2007
23](#__RefHeading___Toc178096793)

[Table 4.4 -- Operation of Lift/Ramp by Vehicle Type
24](#__RefHeading___Toc178096794)

[Table 4.5 -- Repair to Inoperable Lifts
25](#__RefHeading___Toc178096795)

[Table 4.6 -- Summary of Vehicles with Inoperable Lifts in Service
27](#__RefHeading___Toc178096796)

[Table 4.7 -- Vehicles in Service, February 1 to 5, 2007
27](#__RefHeading___Toc178096797)

[Table 4.8 -- AMA Inoperable Lifts on February 1, 2007
27](#__RefHeading___Toc178096798)

[Table 4.9 -- AMA Fleet Status -- February 2007
31](#__RefHeading___Toc178096799)

[Table 4.10 -- AMA Expenses & Funding History 2000-2006
34](#__RefHeading___Toc178096800)

**Attachments**

A AMA's Response Letter

B FTA's Notification Letter to AMA

C On-Site Review Schedule

D On-Site Review Forms

E Customer Comment Form

F OPPI Strategic Plan Agreement

G AMA Notices and Bulletins Regarding Accessible Fixed Route Service
Operating Policies and Procedures

H Sample AMA Maintenance Logs, Reports, and Forms

# Purpose of the Review

The U.S. Department of Transportation (DOT) regulations implementing the
Americans with Disabilities Act of 1990 (ADA) contain two primary
provisions to ensure that vehicles with accessibility features are
reliable and properly maintained. General equipment maintenance
requirements, which pertain to all types of entities and services, are
contained in 49 CFR § 37.161:

\(a\) Public and private entities providing transportation services
shall maintain in operative condition those features of facilities and
vehicles that are required to make the vehicles and facilities readily
accessible to and usable by individuals with disabilities. These
features include, but are not limited to, lifts and other means of
access to vehicles, securement devices, elevators, signage and systems
to facilitate communications with persons with impaired vision or
hearing.

*(b) Accessibility features shall be repaired promptly if they are
damaged or out of order. When an accessibility feature is out of order,
the entity shall take reasonable steps to accommodate individuals with
disabilities who would otherwise use the feature.*

> *(c) This section does not prohibit isolated or temporary
> interruptions in service or access due to maintenance or repairs.*

In addition to the general maintenance provisions described above that
apply to all transportation providers, 49 CFR § 37.163 requires public
entities to keep vehicle lifts[^1] (and ramps) in operative condition as
follows:

> *(a) This section applies only to public entities with respect to
> lifts in non-rail vehicles.*
>
> *(b) The entity shall establish a system of regular and frequent
> maintenance checks of lifts sufficient to determine if they are
> operative.*
>
> *(c) The entity shall ensure that vehicle operators report to the
> entity, by the most immediate means available, any failure of a lift
> to operate in service.*

*(d) Except as provided in paragraph (e) of this section, when a lift is
discovered to be inoperative, the entity shall take the vehicle out of
service before the beginning of the vehicle\'s next service day and
ensure that the lift is repaired before the vehicle returns to service.*

> *(e) If there is no spare vehicle available to take the place of a
> vehicle with an inoperable lift, such that taking the vehicle out of
> service will reduce the transportation service the entity is able to
> provide, the public entity may keep the vehicle in service with an
> inoperable lift for no more than five days (if the entity serves an
> area of 50,000 or less population) or three days (if the entity serves
> an area of over 50,000 population) from the day on which the lift is
> discovered to be inoperative.*
>
> *(f) In any case in which a vehicle is operating on a fixed route with
> an inoperative lift, and the headway to the next accessible vehicle on
> the route exceeds 30 minutes, the entity shall promptly provide
> alternative transportation to individuals with disabilities who are
> unable to use the vehicle because its lift does not work.*

The DOT ADA regulations also contain several requirements related to the
operation of accessibility features. Part 38 of the regulations requires
that accessible vehicles be equipped with mobility aid securement
systems and passenger restraint systems. Technical and functional
specifications for these securement and restraint systems are included
in Part 38. The regulations require that transit systems use the
securement system that is available on vehicles. § 37.165 requires that
agency personnel assist individuals with disabilities with the use of
lifts, ramps and securement systems (and that they leave their seat if
necessary to provide this assistance). §37.173 then requires that
transit agencies ensure that "personnel are trained to proficiency, as
appropriate to their duties, so that they operate vehicles and equipment
safely and properly assist and treat individuals with disabilities who
use the service in a respectful and courteous way, with appropriate
attention to the differences among individuals with disabilities."

The Federal Transit Administration (FTA) is responsible for ensuring
compliance with the ADA and the DOT implementing regulations (49 CFR
Parts 27, 37, and 38). As part of its compliance efforts, FTA, through
its Office of Civil Rights, conducts periodic reviews of fixed route
transit services operated by grantees.

[]{.mark}

This report includes the results of the review of lift reliability,
maintenance, and operation at the Metropolitan Bus Authority (MBA),
known in Spanish and hereafter referred to in this report as Autoridad
Metropolitana de Autobuses (AMA), based in San Juan, Puerto Rico. The
review was conducted from March 5-8, 2007. This report summarizes the
observations and findings of the on-site review of AMA's fixed route bus
service. A description of key features of the fixed route bus service is
first provided, followed by a description of the approach and
methodology used to carry out the review. Observations and findings
related to the ADA requirements are then described, and the major
findings of the review are summarized at the end of this report.
Recommendations of the review team for addressing issues identified also
are provided. AMA's response to the review findings and recommendations
is provided in Attachment A.

# Background

Autoridad Metropolitana de Autobuses (AMA) is a governmental
organization of the Commonwealth of Puerto Rico created by Act No. 5 of
May 11, 1959, as amended. AMA is one of several authorities under the
Puerto Rico Department of Transportation and Public Works (DTPW). The
AMA President and General Manager supervises the operations of AMA and
reports to the Secretary of the DTPW. Created to serve the San Juan
metropolitan area, AMA is the only public transportation authority in
the Commonwealth.

The AMA service area includes the municipalities of San Juan, Bayamón,
Carolina, Cataño, Guaynabo, Loíza, Toa Baja, and Trujillo Alto. The
entire San Juan metropolitan area has a population of 2.2 million,
according to the 2000 U.S. Census. AMA operates a network of 30
fixed-routes. One of these routes is a "Metrobus II" route, which
provides premium express service. AMA provides fixed route service seven
days a week from approximately 4:30 a.m. to 10 p.m. Service hours were
expanded in 2004, when the Tren Urbano rail service started. Buses
operate at average intervals of 20 to 25 minutes, with core routes
operating more frequently.

AMA operates the Metrobus II route under contract to the Puerto Rico
Highway and Transportation Authority (PHRTA), which is an authority
under DTPW. PHRTA also contracts with a private company to operate
another "Metrobus" route. Although not operated or controlled by AMA, to
the public, this contracted Metrobus route is indistinguishable from
other AMA routes.

AMA's active fleet includes 259 buses serving 195 daily runs. Four of
the buses are equipped with ramps; the rest are equipped with lifts.
Significantly, as will be discussed in Section 4, many of the lifts on
older vehicles in the fleet are not in working condition.

AMA operates all of its services, including fixed-route and paratransit
service, from a single maintenance and administration facility (the San
Francisco facility), located at 37 Avenido de Diego in Rio Piedras (San
Juan). AMA's paratransit service, "Llame y Viaje," operates a separate
fleet of 54 vehicles, 20 to 28 of which are used in service at a time.
AMA also has nine transit centers and two transfer terminals located
throughout its service area.

Major AMA capital improvements since 2001 include:

-   Modernization of the communication center, including installation of
    an automated vehicle location (AVL) system for both fixed route and
    paratransit service.

-   New vehicle purchases, including:

```{=html}
<!-- -->
```
-   30 new 2005, 35-foot buses for replacement (4) and expansion (26)

-   30 new 2004, 35-foot buses for replacement (20) and expansion (10)

-   4 new 2004, 35-foot hybrid buses (diesel/electric), as a pilot
    project to evaluate the technology's viability

```{=html}
<!-- -->
```
-   Construction of a battery room in the vehicle maintenance area to
    comply with environmental and safety requirements

Additionally, AMA is in the process of implementing the following major
projects:

-   Modernization of shop equipment and reorganization of the bus
    maintenance shop

-   Development of a Fleet Management Plan

-   Installation of security surveillance camera equipment at the
    central San Francisco facility, bus terminals, and on revenue
    service vehicles (request for proposals under development)

The adult fixed route bus fare is 75 cents. Reduced fares are offered to
senior citizens and persons with disabilities (35 cents) and students
(60 cents). Riders 75 years of age and older ride for free. No transfers
are issued; a separate fare must be paid for each boarding.

# Overview of the Review

The review focused on AMA's compliance with DOT's ADA regulatory
requirements related to the operation and maintenance of lifts as
required for accessible fixed route bus service. The specific regulatory
requirements that were the focus of the review are outlined in the first
section of this report.

FTA provided AMA with written notification of the review on January 29,
2007. A copy of the notification letter is provided in Attachment B.
This letter requested that AMA submit certain key service information
prior to the on-site visit, including:

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-   A current fixed route system map

-   A complete set of schedules for each fixed route

-   Identification of which routes are operated directly and which, if
    any, are operated by private contractor

-   Fixed route bus fleet inventory and division/garage information

-   A description of ramp/lift maintenance procedures

-   A copy of the current fixed route operators manual

-   Copies of notices, bulletins, and memoranda detailing ramp/lift
    operations and maintenance policies and procedures

-   Documentation of ramp/lift operations and lift operations monitoring
    procedures

-   A list of all complaints received by AMA regarding ramp/lift
    operations during the past year

    The letter also requested that an opening conference be scheduled on
    Monday, March 5, 2007, and an exit conference be scheduled on
    Thursday, March 8, 2007.

    Prior to the on-site visit, the review team conducted telephone
    interviews with several local riders and staff of agencies that
    serve people with disabilities. Those interviewed included riders
    who have disabilities who use the AMA system, as well as employees
    of disability organizations who assist individuals who use the
    service. Input on experiences in using the fixed route bus service
    was requested. All interviews were conducted in Spanish.

    []{.mark}

    Planners Collaborative Inc. of Boston, Massachusetts, and
    TranSystems of Medford, Massachusetts, conducted the review on
    behalf of FTA. Rosemary Gerty of TranSystems served as the team
    leader. Don Kidston and David Chia of Planners Collaborative, and
    Pilar Rodriguez of TranSystems assisted with the review. A schedule
    of the team's on-site review activities is provided in Attachment C.

[]{.mark}

The following individuals participated in the opening conference held at
9 a.m. on Monday, March 5:

  ---------------------- ------------------------------------------------
  Evan Gonzalez          President, AMA

  Nydia Falcon Garcia    Vice President of Operations (Maintenance), AMA

  Angel L. Hernandez     Vice President of Service Programs and
                         Development, AMA

  Lourdes Suarez         Director of External Programs, AMA

  Rafael D. Valentin     Special Assistant to the President for Llame y
                         Viaje (Paratransit), AMA

  Rosemary Gerty         TranSystems (Review Team Leader)

  Don Kidston            Planners Collaborative

  David Chia             Planners Collaborative

  Pilar Rodriguez        TranSystems
  ---------------------- ------------------------------------------------

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Jonathan Klein of the FTA Office of Civil Rights in Washington, DC, and
Frank Billue, the Regional Civil Rights Officer for the FTA Region IV
Office in Atlanta, participated via conference call.

Mr. Klein thanked AMA for its cooperation with the review. He described
the purpose of the review as identifying whether people with
disabilities were receiving accessible fixed route services to which
they are entitled in accordance with the DOT ADA regulations. He also
noted that it was an objective of the review to offer assistance to AMA
in meeting the ADA requirements and that the review team was available
for that purpose. Mr. Klein outlined the process that would be followed
for the review, noting that preliminary findings would be presented by
the review team at the exit conference on Thursday, March 8. He
explained that the review team and FTA would then prepare a draft
report, which would be transmitted to AMA for review. Any errors
identified by AMA would be corrected and AMA's response letter to the
draft report and findings would then be incorporated into a final
report. Mr. Klein noted that the final report with any corrections and
AMA's initial comments would become a public document in accordance with
the Freedom of Information Act. After issuance of the final report, AMA
would be requested to provide quarterly progress reports on advancement
of corrective actions for those findings that identify potential for
improvement in delivering the ADA required service and those that
identify non-compliance with DOT ADA regulations. Progress reports will
continue until FTA has been satisfied that all findings have been
adequately addressed, and releases AMA from the requirement for
additional reporting.

Ms. Gerty distributed a copy of a review schedule that had been
forwarded to AMA the prior week. She reviewed the planned on-site
activities and meetings. She noted that the review would focus on the
working condition, maintenance, and use of the bus ramps/lifts and
wheelchair securement systems. She explained that observations would be
made during the morning pull-out and that vehicle inspection and
maintenance records and operator training materials would be reviewed.
She also explained that approximately 10 operators would be interviewed
and AMA's service monitoring efforts, including the handling of
complaints regarding accessible fixed route service, would be reviewed.
She noted that in-service observations and "ride-alongs" with consumers
also were planned.

Following the opening conference, the review team met with senior AMA
managers to discuss policies, maintenance and operating procedures,
fleet resources, and other issues related to data that AMA had forwarded
in advance. Internal complaint records that related to accessible fixed
route service also were reviewed and operator interviews (conducted in
Spanish) were initiated. The team toured the AMA facility, including the
communication center. The team began its review of maintenance records
related to lifts and ramps. The team also began inspecting vehicles to
determine whether they met ADA vehicle requirements. The vehicles
inspected were representative of the different makes and models in the
AMA fixed route fleet.

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On Tuesday, March 6, the review team observed the morning pull-out
process, whereby bus operators take their assigned buses from the bus
yard into passenger service. The team specifically observed the cycling
of lifts and ramps and made random checks of the wheelchair securement
systems. Following pull-out, team members met with garage maintenance
staff to review recent vehicle inspection and maintenance records. Bus
operators were also interviewed throughout the day, as they reported for
duty or as they completed their work shifts. The team also began
interviews with the repair shop and parts department staff.

On Wednesday, March 7, Mr. Kidston, Ms. Gerty, and Ms. Rodriguez
accompanied riders who use lifts and ramps to board AMA's fixed route
service, and observed them attempting to use the service. They completed
three trips during the morning and afternoon, noting the performance of
the operators and equipment. Simultaneously, the team also reviewed
AMA's maintenance and complaint records, training curriculum, and
dispatch logs, and conducted operator interviews.

The team members spent Thursday morning, March 8, analyzing the
information and preparing for the exit conference. The exit conference
took place at 2 p.m. that afternoon. The following individuals
participated in the exit conference:

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  ---------------------- ------------------------------------------------
  Evan Gonzalez          President, AMA

  Nydia Falcon Garcia    Vice President of Operations (Maintenance), AMA

  Angel L. Hernandez     Vice President of Service Programs and
                         Development, AMA

  Lourdes Suarez         Director of External Programs, AMA

  Rafael D. Valentin     Special Assistant to the President for Llame y
                         Viaje (Paratransit), AMA

  Rosemary Gerty         TranSystems

  Don Kidston            Planners Collaborative

  David Chia             Planners Collaborative

  Pilar Rodriguez        TranSystems
  ---------------------- ------------------------------------------------

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Jonathan Klein and David Knight of the FTA Office of Civil Rights in
Washington, DC, and Frank Billue, the Regional Civil Rights Officer for
the FTA Region IV Office in Atlanta, participated via conference call.

[]{.mark}

Prior to the exit conference, the Review Team had briefed FTA on its
overall findings. Mr. Klein thanked AMA for its cooperation throughout
the review and stressed that while the review was intended, in part, to
provide technical assistance to AMA, FTA expected AMA to make
significant progress toward correcting the deficiencies cited during the
review. He urged AMA to begin to take corrective actions right away and
not to wait for the written report to be issued. Mr. Billue offered any
assistance that his office could provide to assist AMA. Mr. Gonzalez
indicated that AMA would work with FTA on those items where
recommendations for improvement were made, notwithstanding constrained
finances in Puerto Rico in all areas of the transit system operation and
noting that the system had been running more than \$10 million in the
red.

The review team then presented its observations and preliminary findings
and recommendations for discussion with AMA officials. Ms. Rodriguez
summarized the results of the customer interviews, complaint review,
ride-alongs with passengers, and operator interviews. Ms. Gerty
described the training curriculum for operators. Mr. Chia reviewed the
results of the pull-out observations and fleet availability. Ms. Gerty
then described the overall maintenance program, as well as observations
related to the communication center procedures for reporting in-service
ramp/lift failures. Mr. Kidston then reviewed the transit agency
resources (including vehicles, finances, and budgeting practices), along
with the results of an analysis of the parts inventory system and its
relationship to the lift/ramp maintenance program.

# Observations of Lift and Ramp Reliability & Maintenance 

To assess AMA's current performance with respect to accessible fixed
route reliability, maintenance, and operation, the review team performed
the following activities:

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-   Gathered consumer input by various means, including telephone
    interviews in Spanish with individuals who use wheelchairs who are
    regular riders of the AMA bus system and with personnel from various
    agencies whose clients are regular riders

-   Reviewed policies and procedures regarding lift operations, service
    monitoring, and equipment inspection

-   Observed bus operations

-   Interviewed bus operators (in Spanish) to gauge their understanding
    of ramp and wheelchair securement use policies and procedures

-   Observed vehicle pull-out and inspection

-   Reviewed maintenance procedures and performance

-   Reviewed recent bus procurements, current fleet accessibility, and
    bus stop accessibility

-   Reviewed availability of resources for lift/ramp operation.

Team member observations made during each of these review activities are
detailed below. Copies of the forms used to collect information on-site
are included in Attachment D.

## Consumer Input

The review team gathered input from AMA fixed route service customers to
assist in identifying any problems with the use of lifts and ramps from
the perspective of the consumer. Three methods were used for gathering
consumer input: review of complaints on file with FTA, interviews with
consumers and consumer representatives, and review of AMA's complaint
files.

### FTA Complaint {#fta-complaint .unnumbered}

There was one formal ADA complaint related to AMA's fixed route and
paratransit service on file with FTA's Office of Civil Rights at the
time of the on-site review. The complaint included an ongoing dialogue
with FTA on various areas of concern that spanned several years. In a
letter dated February 16, 2007, FTA closed that complaint, noting the
following:

> *"The specific issues in your complaint, including AMA's failure to
> properly maintain lifts and driver sensitivity, will be addressed from
> a broader perspective by this compliance review, with the intent of
> resolving any issues of non-compliance identified. You also raised
> concerns about AMA's paratransit service, Llame y Viaje; however
> recent conversations with you indicate that you are not a current
> rider of Llame y Viaje. We will focus on your fixed route bus concerns
> at this time. If you have additional Llame y Viaje concerns, please
> contact us again. As part of this review, if we make findings of
> deficiencies, FTA will monitor activities until we determine that the
> deficiencies noted are corrected. When the compliance review report is
> final, we will provide a copy to you. For the reasons discussed above,
> we will not pursue additional investigation of your specific complaint
> at this time."*

### Customer Interviews {#customer-interviews .unnumbered}

The review team conducted four telephone interviews with individuals who
ride or have attempted to ride AMA's fixed route buses. All interviews
were conducted in Spanish. One of the interviews was with the
spokesperson for a local disability organization. The reviewers also
unsuccessfully attempted to contact several other organizations in an
effort to identify people who need to use lifts/ramps when riding AMA
buses. Among those organizations were the Center for Independent Living
in San Juan (in Spanish, "Movimiento para el Alcance de Vida
Independiente") and the Puerto Rico chapter of the Paralyzed Veterans of
America; however, the publicized phone numbers for both organizations
were disconnected or went unanswered. Furthermore, the team could not
identify representatives in Puerto Rico for some major disability rights
groups, such as Americans Disabled for Accessible Public Transportation
and the National Organization on Disability. The team did, however,
contact the Puerto Rico offices of the Protection and Advocacy Agency
(known locally as "OPPI," which stands for *Oficina del Procurador Para
Impedidos*). OPPI receives and processes complaints from AMA users;
however, its mission appears to be more focused on legislative issues
and less on consumer advocacy.

There was a consensus among the interviewees that, for persons with
disabilities, using either the fixed route or paratransit service is
challenging, and the service is unreliable and often unsafe. The
problems encountered when using the AMA fixed route system that were
described by the interviewees fall into two main categories.

The first group of problems encountered by people using wheelchairs or
scooters concerns the lack of stop accessibility. According to
interviewees, AMA bus stops are often inaccessible because access from
the streets to the sidewalks is blocked by parked cars or the sidewalks
are too narrow for lifts/ramps to properly deploy. As a result, when
alighting from the bus, passengers are often left in the street because
the lift cannot be deployed on the sidewalk.

The second group of cited problems concerns lift reliability. Three
interviewees estimated that more than 50 percent of the lifts do not
work. The other interviewee noted that neither she nor her disabled
family members rely on AMA's fixed route system anymore because it is
almost impossible to access the stops near their house. However, she
also said that on the few occasions when she used the fixed route bus
system in the past year, she has had an acceptable experience with the
reliability of the lifts and the operators.

Two of the interviewees had particularly serious complaints about
operators' lack of courtesy and apparent unwillingness to transport
people with disabilities. They noted that operators are often
disrespectful and hurtful in the way they address customers with
disabilities, even telling such customers that they "do not belong in
the fixed route system" and should call the ADA paratransit service
(Llame y Viaje) for a ride. The interviewees felt that the operators
often just make up excuses to avoid transporting them. According to the
interviewees, the most common excuses are:

-   "The lift is broken"

-   "I don't have the key to operate the lift"

-   "The supervisor did not activate the lift"

Additionally, one interviewee uses a walker and cannot use the steps to
board the bus. When she asks operators to deploy the lift or ramp for
her, she said they will often refuse to do so, stating that the lift is
only for people who use wheelchairs.

### Customer Comments and Complaints Received by AMA {#customer-comments-and-complaints-received-by-ama .unnumbered}

Customers can file complaints concerning accessibility of AMA's fixed
route service not only at AMA but also through the Protection and
Advocacy Office (known locally as OPPI) and several other government
agencies and departments. One of the customers interviewed mentioned
that he would rather file a complaint at OPPI because the process at AMA
is "confrontational and disadvantageous for the customer." A copy of the
AMA comment form is included in Attachment E.

The review team attempted to review the internal complaint records
related to the provision of accessible fixed route service in 2006.
However, the team encountered problems locating and validating the
records because of the decentralized process used by AMA to handle
customer complaints. There is no one central office where complaints are
collected and processed. Complaints may be filed through various
departments by phone, in person, or even by sending text messages or
e-mails to staff. As a result, although according to AMA most complaints
are filed with the Programming and Services Department, the
communication center, the Legal Department, or the Office of the
President/General Manager, many complaints may go unrecorded and
undocumented.

Procedurally, complaint records are generally filed and organized
according to bus operator. Service complaints are associated with an
operator and the case is documented in the operator's file, rather than
in a central file. Typically, each complaint is first handled by the
Programming and Services Department. If the customer wants a hearing,
one is arranged by the department and all parties involved (customer,
operator, an AMA representative, and a union representative) are called
in. The customer can opt out of the hearing; however, it appears that
this right is not understood by some customers. Additionally, many
customers believe that they must go to a hearing by themselves. In cases
where the customer opts out of a hearing, AMA will do an internal
investigation and take steps toward resolving the issue, but there is no
record of the actions taken. If a hearing is held, the department
attempts to resolve the issue and records all actions taken in the
operator's file.

If the issue is not resolved at the Programming and Services Department
or if the customer wants to bring a lawyer, the issue is referred to the
Legal Department. If the problem is still not resolved at this level, it
is forwarded out of the agency, to the Department of Labor.

The Legal Department maintains the operators' files, which include the
customer complaints. The review team obtained a list of all complaint
hearings scheduled in 2006 from the Programming and Services Department.
This list included all complaints filed against operators, not only by
customers but also by supervisors and other AMA employees.

In 2006, there were 76 scheduled hearings in the Programming and
Services Department for customer-related complaints. Of the 76
complaints with hearings, the review team selected a sample of 20
complaints to determine their status and whether the complaints were
related to lift/ramp and ADA issues. Files for four of the complaints
could not be found. Of the remaining 16 complaints in the sample, seven
were unrelated to lifts, ADA requirements, paratransit service, or
operator conduct involving a disabled passenger. Table 4.1 identifies
the issues cited in the nine accessibility-related complaints. Some
complaints identified more than one issue, and as a result the total of
complaints for each issue exceeds nine.

[]{#__RefHeading___Toc178096791 .anchor}Table 4.1 -- Sample of AMA
Complaints for 2006

  ------------------------------------------------------ ----------------
  **Type of Complaint**                                  **Number of
                                                         Complaints**

  Poor bus operator conduct                              6

  Inoperable lift                                        3

  Elderly passengers were not provided appropriate       2
  assistance                                             

  Operator did not secure passenger wheelchair           1

  Complaint about paratransit service                    1
  ------------------------------------------------------ ----------------

There was a record of AMA follow-up for six of the nine complaints. In
some cases, AMA responded by issuing a memorandum to all operators
regarding policies and procedures. In other cases memos were issued to
the responsible individual and apologies sent to the customer involved.

Overall, the analysis for this review points to the great difficulty in
tracking complaints using AMA's current process.

On February 8, 2007, AMA signed a letter indicating its intent to work
with OPPI on a strategic plan to improve services for individuals with
disabilities. A February 8, 2007 letter stating AMA's intent to
participate with OPPI in development of a plan to comply with supporting
the rights of people with disabilities ("Implantacion del Plan
Estrategico de la AMA Para Cumplir con la Ley 238 DEL 31 de Agosto de
2005 'Carta de Derechos de las Personas con Impedimentos'") is included
in Attachment F.

## [[]{#__RefHeading___Toc178096536 .anchor}AMA's Policies and Procedures Regarding Lifts](#__RefHeading___Toc173134587)

Following is a description of policies and procedures adopted by AMA
regarding accessibility of the fixed route system and the provision of
accessible fixed route bus service. Copies of relevant AMA policies and
procedures are included in Attachment G.

### Operator Training {#operator-training .unnumbered}

AMA requires bus operators to complete a 25-day classroom and hands-on
training program. Although not specified in the associated "Academia
2001" curriculum outline, AMA reports that on day 5, trainees begin to
work with wheelchair securement and lift/ramp boarding and alighting
procedures. On day 15, there is a half-day presentation by OPPI
describing passengers with disabilities and their needs. On the other
hand, AMA noted that there have been virtually no new hires in the past
five years; therefore, the curriculum may be out of date and detailed
information about what exactly what topics were covered in recent
trainings could not be provided.

No formal bus operator retraining is offered. Any retraining that occurs
is the result of a complaint or incident.

Several driver bulletins are included in Attachment G. Two driver
bulletins, dated February 3, 2006 and March 29, 2006, state that drivers
are required to allow passengers to board using lifts or ramps upon
request, whether or not they use a wheelchair or scooter.

### Bus Operations {#bus-operations .unnumbered}

[]{.mark}

Operators are assigned a vehicle when they report to the desk (pull-out)
dispatcher each day.

AMA operators are supposed to inspect their assigned vehicle before
entering into passenger service. Most AMA operators do not include
cycling of lifts as part of the inspection. Accordingly, there is no
consistent cycling of lifts on a daily basis.

Further, there is no written documentation of the operator's inspection.
If the operator identifies a problem, he or she makes an oral report to
the supervisor. If the needed repair is minor, requiring only a few
minutes labor and no significant expense, the operator will take the bus
to the shop and, upon completion of the repair, continue to use the bus
in service. If the required repair appears to be major, the supervisor
will take the bus to the shop and the operator will be assigned to
another bus. Only such major repairs are regularly tracked in AMA's
maintenance system records.

Additionally, lift failures that are discovered for buses assigned to
service are to be reported to the communication center, either by the
operator or transportation supervisor. A sample copy of the log is
included in Attachment H. As noted earlier, however, operators do not
typically look for problems with lifts/ramps prior to pull-out.

If a lift/ramp problem is identified in service, the operator is
required to follow the procedures outlined in an April 24, 2003 memo
(see Attachment G). The procedures include notifying the communication
center that the lift has failed, advising the customer of the outcome of
the communication center contact, and providing alternative
transportation if the next accessible bus is more than 30 minutes away.
This policy is consistent with the DOT ADA regulatory requirements at 49
CFR § 37.163.

[]{.mark}

The communication center records the operator's report on a log sheet
(called "Control de Reparacion de Rampa de Impedidos") and dispatches a
mechanic to meet the vehicle. The mechanic either repairs the reported
defect or returns the bus to the shop. Notably, the first record for
inoperable lifts identified while in service is the dispatch log
maintained by the communication center.

Normally, at the end of the day the operator returns the bus to the
revenue collection area and reports out to the desk dispatcher. If,
however, the operator identifies a problem upon returning the bus at the
end of the run, the vehicle is brought to the shop. Buses with defective
wheelchair lifts are brought to the doors outside the wheelchair
maintenance bays in the garage. As with inoperable lifts identified at
pull-out, the first written record of an inoperable lift identified at
pull-in is created when a work order is issued for a major repair.

AMA has standby operators at the outlying terminals and transfer
locations to provide immediate assistance when lift boarding issues
arise and the next accessible bus is estimated to be more than 30
minutes away. Although having such procedures for backup service is good
practice, AMA's records indicate little use of the service. The lack of
use is significant because it conflicts with the documented lift-failure
rate of 50 percent and the fact that buses with inoperable lifts are
often kept in service (discussed below). The discrepancy suggests that
either operators are not reporting lift failures while in service or
passengers who need to board using a lift are not attempting to access
AMA's fixed route service.

### Service Monitoring and Enforcement of Policies and Procedures {#service-monitoring-and-enforcement-of-policies-and-procedures .unnumbered}

AMA does not have a formal service monitoring program for the
enforcement of policies related to the provision of accessible fixed
route services. Traffic checkers ride buses to observe and record travel
times and the number of passengers using the bus, but do not
specifically look for performance related to accessibility concerns.
Similarly, although AMA Road Supervisors monitor operator performance,
with four supervisors assigned on weekdays and two on weekends, AMA does
not use "secret" or "mystery" riders to monitor service. Secret or
mystery riders are people unknown to the operator who ride buses and
observe and record performance of the operator and vehicle components.
Many transit providers have found them indispensable to ensuring
operator compliance with DOT ADA regulatory requirements, including
proper provision of lift and ramp service.

### Maintenance and Inventory Control {#maintenance-and-inventory-control .unnumbered}

Maintenance performance is tracked using written forms and paper copies
of maintenance records. Records are maintained for each vehicle and are
kept in paper form in file cabinets. Fleet management software was being
installed at the time of the review. Upon installation of the electronic
system, AMA plans to conduct preventive maintenance inspections (PMIs)
for each bus based on mileage intervals, as described below.

Currently, AMA procedures call for scheduled preventive maintenance
inspections every 35 to 45 days or every 400 hours of service. Item #105
"wheelchair y mecanismo de 'interlock'" is shown on the "yellow"
preventive maintenance checklist ("Reporte de Mantenimiento Preventivo
(Inspeccion)"), which is included in Attachment H. In June 2006, a
revised preventive maintenance schedule was proposed, which includes
"Type A" inspections every 6,000 miles, "Type B" inspections at 12,000
miles, "Type C" inspections every 18,000 miles, and "Type D" inspections
every 24,000 miles. Among other items, the Type A inspections will
include the following lift-related elements:

-   Operation of wheelchair lifts/ramps

-   Sensors, switches, and linkages

-   Electrical connections

-   Large hydraulic tanks

-   Cleanliness of lifts/ramps

AMA staff members have also proposed a more detailed form
("Mantenimiento de Rampas"), which is included in Attachment H.
Additionally, the new proposed inspection handbook ("Procedimento Para
el Mantenimiento Preventivo de Vehiculos de 30, 25 y 40 Pies") also
includes a statement indicating the need for information about the ADA
requirements related to preventive maintenance.

[]{.mark}

When bus maintenance staff members need parts, they must get them from
AMA's warehouse. Significantly, if lift/ramp parts are not available,
repair work is suspended, and the bus is returned to the active fleet of
buses available for service. As is described further in Section 4.3.6,
it had been AMA's practice for the warehouse to notify maintenance staff
by e-mail, on a daily basis, when special order parts are received. When
the parts become available, buses awaiting parts are supposed to be
scheduled for maintenance at a rate of two per day until the associated
repairs are completed. At the time of the review, however, this practice
had not occurred for a couple of months, apparently because of a
significant breakdown in communication between the Maintenance
Department (alternatively referred to as the Operations Department) and
warehouse concerning special order parts. As a result, no repairs for
buses awaiting parts had been made over the same period. The breakdown
is particularly perplexing because the warehouse and maintenance
facilities are next door to each other, in the same building.

The current system for inventory control relies largely on manual
procedures and paper records. The Parts Department maintains an
inventory of in-stock spare parts for vehicles. Stocks of parts from the
bus parts lists are maintained in the inventory, with the exception of
parts for the 2004-2005 Orion buses. The inventory is kept on computer,
but it is based on the paper records.

Parts are stored in bins or shelf areas in the warehouse. The warehouse
manager makes regular visual inspections of the parts inventory to
determine whether minimum quantities of each part are available, and
additional parts are ordered as needed when the manager observes that
stocks are depleted. Parts are also ordered when parts requested for
vehicle maintenance are out-of-stock. Notably, the recent breakdown in
repairs requiring special order parts, described above, was not due to
failure to acquire needed parts. In recent months, the needed parts have
been received, but the repairs have not been made.

The warehouse initiates all requisitions, which are forwarded to the
Purchasing Department. The requisitions are circulated to the Director
of External Affairs and the Chief of the Budget Office for confirmation
of the availability of Federal and local funds, respectively. Upon
receiving funding approval, the Purchasing Department issues a purchase
order for each needed part. The process to issue the purchase order
typically takes one to three days, which is in addition to seven to ten
days needed to receive the part once the requisition has been issued.

As is also discussed in Section 4.3.6, AMA is in the process of
installing a new Inventory Control System. The system will maintain a
tally of parts in-stock, tracked according to base line inventory, parts
drawn from stores, and additional parts received. For each part, minimum
and maximum units in inventory are being developed based upon rate of
use and the lead time for restocking the part. Automatic reordering when
minimums are reached should minimize parts shortages, and adhering to
maximums when reordering should minimize the amount of money needed to
maintain an adequate parts inventory. At the time of the on-site review,
the new inventory control system was scheduled for installation between
March and December 2007.

### Fleet Roster {#fleet-roster .unnumbered}

AMA has a fleet of 315 buses; however, as will be described later in
this report, 56 of those buses are old and unavailable for passenger
service and, at the time of the review, 9 others were off-site for
warranty work and therefore also unavailable (see Table 4.2). This
leaves 250 buses to serve 195 weekday runs, yielding a spare ratio of
0.28, exclusive of buses being serviced under warranty. Furthermore, of
the 250 buses available for service, 24 are 12 years old and an
additional 61 are 10 years old.

[]{#__RefHeading___Toc178096792 .anchor}Table 4.2 -- AMA Fleet Roster --
February 2007

  ------------- ---------------- ---------------- ------------ ------------
  **Year**      **Make**         **Model**        **Ramps      **Total
                                                  /Lifts**     Vehicles**

  2005          New Flyer        Delf-35          Ramps        4

  2005          Orion            Orion V          Lifts        30

  2004          Orion            Orion V          Lifts        30

  2002          Nova             6.2 VN           Lifts        10

  2000          Nova             8.2 VN           Lifts        70

  1999          Nova             T802 VN          Lifts        29

  1998          Nova             T802 VN          Lifts        18

  1997          Nova             T802 VN          Lifts        79

  1995          Flxible          400964D50        Lifts\*      45

  **Totals**                                                   315

  Note: none of                                                
  the 1995                                                     
  lifts are                                                    
  operable.                                                    
  ------------- ---------------- ---------------- ------------ ------------

In addition to the fixed route fleet, AMA maintains retired paratransit
vehicles for use as needed, to respond to in-service failures of the
lifts on fixed route buses.

### Bus Stop Accessibility {#bus-stop-accessibility .unnumbered}

Section 810 of Appendix A to 49 CFR Part 37 requires that new bus stop
boarding and alighting areas have a firm stable surface 96\" deep (from
the road edge) and 60\" wide (along the road edge). Section 810 also
requires that such areas be connected to streets, sidewalks, or
pedestrian paths by an accessible route. New bus shelters must have a
clear floor area of 30\" by 48\" and must also be connected to an
accessible route.

AMA identifies bus stops to customers on the street with signs, many of
which include information about which routes serve the specific stop and
schedule frequency. Shelters and benches are available at some, but not
all stops.

Passengers are expected to signal operators to stop by waving at them;
if they do not wave, the operators will not stop. As noted later in this
report, AMA has significant issues with vehicles parking or waiting
illegally in the bus stop areas. According to AMA, law enforcement does
not appear to place a high priority on keeping bus stops clear of
vehicles. Consequently, parked vehicles often block access to fixed
route bus stops, making it difficult for passengers to use the stops and
for operators to spot passengers waiting for the bus.

### Budget and Financial Resources {#budget-and-financial-resources .unnumbered}

As stated above in Section 2, AMA is a division of DTPW and the AMA
President and General Manager reports to the DTPW Secretary.
Approximately 15 to 20 vice presidents, directors, and assistants report
to the president. Senior staff who have significant impact on lift
operations include: the Vice President of Programming and Development
(transportation), Vice President of Operations (passenger vehicle
maintenance), Vice President of General Services (purchasing and
warehouse), Assistant for Special Major Capital Projects (management
information systems), Vice President for Administration (budget &
financial control), and Director of the Office of External Resources
(Federal funding).

The AMA budget process is based on a fiscal year ending June 30, and is
scheduled in coordination with the commonwealth budgeting process. In
July or August of each year, the commonwealth issues budget instructions
to all agencies for the next year's budget. AMA develops the agency
budget during the period from September through November. The AMA
process overlaps with presentation of agency budgets for review by the
commonwealth, which occurs between September and February. The
commonwealth finalizes its proposed budget in February and the governor
presents the budget to the legislature. Between February and June, the
legislature reviews the budget, which it typically approves in June.

The annual AMA budget is for both capital and operating expenses. Funds
for vehicle parts are included in the Preventive Maintenance (PM)
element of the capital budget. Other costs included in the PM element
are labor, supplies (parts), and equipment (machinery) needed to perform
preventive maintenance.

The Chief of the AMA Budget Office is responsible for preparing the
annual budget. Major initiatives in the capital budget are developed by,
or with input from, the President and General Manager's Office. The
budget chief also obtains input from a number of senior managers.

The PM component of the annual AMA capital budget is developed by the
External Resources Department, based on the budget for the previous year
and a straight line projection from expenditures for recent years. The
PM component is further adjusted to reflect changes in fleet or other
equipment. During the on-site review, AMA proposed that the Purchasing
Department develop future PM budgets using information from the new
Inventory Control System.

The equipment component of the annual capital budget is developed by the
Purchasing Department, which receives a baseline budget from the Budget
Office. Funding to complete projects initiated in the prior year is
provided first. Next, funding for new projects is prioritized and added
to the proposed budget, based on remaining available funds.

Funding for service comes from four principal sources:

-   Agency revenues

-   Local funds

-   Commonwealth funds

-   Federal funds

Agency revenues are derived from passenger fares, contract services and
leases, concessions, and advertising. The sources of commonwealth funds
are general revenues appropriated annually by the legislature and
4-cents out of an 8-cents-per-gallon tax on diesel and propane sales.
Federal funds consist of formula grant funds for capital investments,
including preventive maintenance of vehicles and planning.

In January 2006, AMA increased base fixed route bus fares from 25 cents
to 75 cents. AMA estimated that the fare increase will result in an
overall annual increase in fare revenues from approximately \$6 million
to \$12 million.

## Review Team Observations

In addition to interviewing riders and examining AMA's policies and
procedures, the review team conducted firsthand observations of service,
reviewed AMA's internal records, and conducted further interviews, as
follows:

-   Conducted "ride-alongs" with consumers who use wheelchairs

-   Interviewed bus operators

-   Observed pull-out and vehicle accessibility equipment

-   Reviewed maintenance records and dispatch logs

-   Reviewed fleet availability records and related resource
    considerations

-   Inspected one of each type of fixed route bus purchased by AMA for
    compliance with ADA vehicle design (Part 38) standards

```{=html}
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-   Reviewed resources and budget

The remainder of this section of the report summarizes these
observations.

### In-Service "Ride-Alongs" {#in-service-ride-alongs .unnumbered}

As part of the review, team members arranged to meet with two local
customers who use the lifts or ramps to access the AMA bus system. Three
rides were observed on Wednesday, March 7. One rider used a walker and
the other used a power wheelchair, which was of a size and weight that
fit the DOT regulation's definition of a "common wheelchair." The
reviewers recorded whether the boarding and alighting processes were
successful, if the lifts / ramps were operable, and whether the
operators properly secured the rider's wheelchair.

The ride-alongs resulted in the following observations:

-   Out of six boarding attempts, only three resulted in completed
    trips. The other three buses did not have working lifts, according
    to the operators.

-   Operators with buses that reportedly had non-functioning lifts did
    stop and advise the passenger. However, only one operator appeared
    to radio the communication center to report that he was unable to
    transport the passenger using a wheelchair because the lift was
    broken.

-   One operator said that he had to check the lift because he wasn't
    sure that it worked (it did).

-   In two of the three trips, the wait time for an accessible bus was
    longer than 30 minutes (the wait time was 35 minutes for each).

-   The operators seem to be knowledgeable in operating the lift.
    However, two operators did not properly secure the wheelchair, using
    only one or two straps to secure the wheelchair and failing to offer
    use of the shoulder belt.

-   Operators were generally respectful, although one did make a comment
    stating that the passenger should be using paratransit service.

-   Lack of accessibility to the stops and areas around stops was
    observed to be a barrier to accessing AMA buses (see summary comment
    below).

-   Curb ramps are often either non-existent near the bus stops or
    blocked by parked vehicles.

Overall, the review team observed that the infrastructure in San Juan is
not readily accessible for persons using wheelchairs and scooters as
well as for persons who have difficulty walking up steps (discussed
further in Section 4.3.8). Particularly in the congested downtown
business areas, sidewalks may be obstructed by posts, planters, or other
barriers, and curb ramps are often blocked by parked or waiting
vehicles. Additionally, at some crosswalks and intersections, there are
no curb ramps at all. As a result of cars parked at bus stops, the
operator may not be able to pull the bus up to the curb, forcing both
ambulatory and non-ambulatory passengers to board or alight in the
street, rather than on the sidewalk. As a result, persons using
wheelchairs or scooters may not be able to access the bus because they
cannot get to the street due to absence of curb ramps. Additionally,
boarding with wheelchairs or scooters from the street is problematic
because deployment of lifts and ramps at street level can result in
excessive slopes, which violates Federal law and is dangerous for
customers and operators. Even where the bus can reach the curb, persons
using wheelchairs or scooters may still be prevented from accessing the
bus because of inaccessible sidewalks and curb ramps, which make the
stop inaccessible.

During a ride-along, a review team member noted a blocked bus stop that
prevented a rider who uses a wheelchair from accessing the sidewalk from
the bus, and forced the rider to travel in the street, in vehicular
traffic, a half block before being able to use a curb ramp to access the
sidewalk. This situation will become a bigger issue as more low-floor
buses with ramps are introduced into the system. Low-floor buses are
designed to deploy ramps onto the sidewalk. If deployed onto the street,
the ramp may be too steep to negotiate or there may not be enough room
to maneuver between the ramp and an obstruction for boarding or
alighting from the bus.

### Bus Operator Interviews {#bus-operator-interviews .unnumbered}

During the on-site review, the team interviewed 10 bus operators at the
garage, either before or after their shifts. The interviews were
conducted in Spanish. A copy of the form used in the interviews is
presented in both English and Spanish in Attachment D. Before the
interviews, reviewers observed an apparent misunderstanding among AMA
staff regarding who could use the lifts, resulting in operators
routinely denying requests to use lifts from people who were not using
wheelchairs or scooters. Accordingly, an extra question regarding
eligibility to use the lift was added to the questionnaire. At the
beginning of each interview, the interviewer explained the purpose of
the review and told the operators that any identifying information
collected during the interviews would be kept confidential.

Bus operators were randomly selected and included a mix of operators
with varying years of service. It should be noted that AMA has not hired
new bus operators during the last five years. Accordingly, the least
experienced operator interviewed has been at AMA for seven years, and
several interviewed operators had more than 30 years of experience with
AMA. Two women and eight men were interviewed. Additionally, AMA has no
part-time operators. As a result, all operators interviewed work full
time and almost always operate a lift-equipped bus.

Three of the 10 operators indicated that they transport someone with a
disability at least once a day. Five operators indicated that they do so
at least once a week, one said once every two months on average, and one
said that he hardly ever has passengers with disabilities on board.

All of the operators who have worked for AMA for more than 20 years said
that they did not receive training regarding disability issues at the
time of their hiring. All of the operators with 15 years of experience
or less indicated they received training in serving passengers with
disabilities as part of the "Academia" (a training course for new
operators). All of the operators who received training thought it was
appropriate.

Six of the ten interviewed operators said they have not received any
refresher training. Two of the remaining four operators indicated that
refresher courses are provided when new buses arrive and that they are
instructed how to operate the lift at that time. It does not appear,
however, that there is any refresher training in other areas related to
disability issues, such as passenger assistance or use of securements.
Additionally, there are apparently no refresher trainings offered apart
from those that occur when new buses arrive.

The majority of the operators (eight) said that they check the lift
everyday. One operator indicated that she checks the lift every two or
three days, and the other said that he only checks the lift when he
needs to pick up a passenger with a disability.

All but one of the operators said that if the lift does not work, they
report it to a supervisor or communication center. Notably, all of the
operators agreed that in the event of a broken lift discovered at
pull-out, they continue with pull-out unless the lift is stuck while
deployed. One operator indicated that he does not report the broken
lift, stating "no action is taken even when they report it, thus it does
not really matter" (translated).

All operators except one, who did not want to answer the question,
agreed that it will take a very long time (expressed in months, years,
or never) for all the lifts to be repaired. All operators agreed that at
some point, they have left the garage with a broken lift.

All operators said that if the lift is deployed and gets stuck while in
service, they call dispatch or a supervisor to arrange for a mechanic to
be sent and another vehicle to transfer the passengers. If the lift
breaks and the bus can continue in service (i.e., where the lift is in
the stored position), some operators said that they report it
immediately to the communication center and some said they just continue
without taking any action.

Many operators appeared unaware of required procedures when operating a
bus with a broken lift. Some operators indicated that when they see a
person with a disability waiting for the bus and the lift is broken,
they call the communication center and stop to inform the passenger that
the lift is broken. Some, however, said they either call the
communication center or inform the passenger, but not both. One operator
said that he would tell the passenger to call AMA to arrange for a ride
on his or her own.

All operators acknowledged that the lift should be deployed on the
sidewalk but recognized that it is not always possible to do so and that
having parked cars obstructing the bus stops is a major issue preventing
them from deploying lifts properly.

All operators said that the assistance that they provide to customers
who use wheelchairs or scooters consists of operating the lift and
securing the customer. One operator mentioned that he would also help
with fare payment.

Most operators correctly responded that if there is no designated space
for a wheelchair or scooter available, they cannot allow the person
onboard. However, one operator noted that if there was no room, he would
"ask the customer to press the brake and hold on tight, and drive
slowly." Another operator said that if the person could be transferred
to a regular seat, he would help the customer to use a regular seat and
continue on.

There appeared to be some misunderstanding regarding who is entitled to
use the lift. Seven operators said that only people using wheelchairs or
scooters could use the lift. Two operators indicated that AMA had asked
them to allow all people with disabilities (e.g., people using walkers,
canes, or who cannot use the stairs) to use the lift; however these two
operators considered it unsafe to do so because the lifts do not operate
smoothly and they therefore prefer not to board standees. Only one
operator correctly responded that all people with disabilities may use
the lift when needed.

All operators understood the procedures associated with priority
seating. All indicated that they ask passengers using those seats to
move and to allow a person with a disability to use the seats, if
needed.

In addition to responses to the questions, some operators provided
comments, which are summarized below.

-   Two operators indicated that a major problem preventing them from
    deploying the lifts is that the keys to the control box (required in
    some buses) are missing. One operator suggested that AMA make more
    keys and provide all operators with a key as part of the "uniform"
    that must be carried.

-   Various operators commented on lift maintenance. Two indicated that
    maintenance was better in the past and that AMA should make an
    effort to catch up repairing broken lifts. Three other operators
    indicated that the lifts are dirty, especially the securement
    straps, which makes some customers, and even operators, unwilling to
    use them.

-   Two operators said that the scooters are usually too heavy and they
    tend to break the lifts.

-   Three operators said that most of the lifts do not work.

-   One operator noted that if the customer does not want to be secured,
    the operator cannot let the customer onboard

The interviews indicated that, in general, operators are not familiar
with ADA requirements and AMA operating procedures. Inconsistencies in
bus operator understanding of the procedures were evident with respect
to passenger assistance, reporting procedures, and lift use eligibility.
On the other hand, operators seemed familiar with procedures for
priority seating. In addition, it appears that operators perceive lift
reliability as a problem for AMA management and do not feel involved in
either the problem or the solution. One operator said that "if the lift
does not work, it's not my problem, it's AMA's."

### Pull-out and Condition of Accessibility Equipment {#pull-out-and-condition-of-accessibility-equipment .unnumbered}

The review team observed the morning pull-out on Tuesday, March 6 at the
AMA facility. The purpose of the observation was to assess the working
condition of lifts/ramps and other accessibility equipment, to observe
procedures used by bus operators for cycling and inspecting equipment,
and to determine whether bus operators are familiar with the operation
of accessible equipment.

[]{.mark}

The review team observed and AMA officials confirmed that cycling of
lifts is not a part of AMA operators' daily practice. In fact, operators
did not perform regular pre-trip vehicle inspections and did not have
any checklist to complete and submit.

The practices and vehicle features that review team members looked for
during the morning pull-out included:

-   Operation of lift/ramp

-   Display of international symbol of accessibility (ISA) on vehicle
    exterior

-   Working exterior destination signs

-   Working securements (the equipment to secure the wheelchair in
    place) for passengers who use wheelchairs

-   Working restraints (lap and shoulder belts to secure the passenger)
    for passengers who use wheelchairs

-   Clean securements and restraints

Review team members used a standard form to record results of the
observations and inspections. A copy of this "Record of Lift
Cycling/Working Condition of Lifts and Access Features" form is included
in Attachment D.

[]{.mark}

Table 4.3 provides a summary of the pull-out observations. Note that in
some cases, not all items were observed and/or tested on every bus. The
total of the "Yes" and "No" columns therefore does not always sum to the
total number of buses observed.

[]{#__RefHeading___Toc178096793 .anchor}Table 4.3 -- Summary of AMA
Pull-out Observations, March 6, 2007

  ----------------------------------------- --------- -------- ----------------
  **Observation**                           **Yes**   **No**   **Total
                                                               Observations**

  Lift/Ramp Works                           28        28       56

  Securements Work                          24        1        25

  Restraints Work                           23        0        23

  Securements and Restraints Clean          14        8        22

  Operator Familiar with Equipment          29        0        29

  International Symbol of Accessibility     24        16       40
  Displayed                                                    

  Destination Signs Work                    34        0        34
  ----------------------------------------- --------- -------- ----------------

As shown in Table 4.3, the lifts/ramps operated properly on only 50
percent of the buses observed at pull-out (28 of the 56 vehicles
observed). For three of the non-operating lifts, the operator was able
to deploy the lift, but then could not stow the lift. As expected, none
of the five Flxible buses had operating lifts. The operators of these
vehicles did not try to cycle the lifts knowing that they did not work.
For six other vehicles with non-operating lifts, the operator also did
not try to cycle the lifts, but simply stated that they did not work.
Notably, all vehicles that did not have operating lifts or ramps were
put into revenue service that morning. On a positive note, all operators
observed cycling lifts appeared to know how to operate them.

The securements for riders who use wheelchairs worked for all but one of
the 25 vehicles tested by team members. The restraint systems worked for
all 23 vehicles for which team members made the observations. The
destination signs worked properly for all 34 vehicles for which team
members made observations.

Two other areas in which AMA vehicles had a relatively high proportion
of poor performance were the cleanliness of restraints and securements
and display of required signage. Eight of 22 vehicles were observed to
have restraints and/or securements that were not clean. Sixteen of the
40 buses observed did not display an ISA on the exterior of the vehicles
near the accessible door.

Table 4.4 shows the operation of lifts/ramps for each type of vehicle
observed by the review team. As mentioned above, none of the Flxible
buses had an operating lift. By contrast, both RTS 30-foot buses that
were observed had operating lifts. Of AMA's existing fleet, only New
Flyer buses are equipped with ramps. The one New Flyer observed had an
operating ramp.

[]{#__RefHeading___Toc178096794 .anchor}Table 4.4 -- Operation of
Lift/Ramp by Vehicle Type

  ------------------------ --------------- --------------- ----------------
  **Vehicle Type**         **Yes**         **No**          **Total
                                                           Observations**

  Flxible buses            0               5               5

  RTS 40-foot buses        12              13              25

  RTS 30-foot buses        2               0               2

  Orion V buses            13              10              23

  New Flyer ramp buses     1               0               1
  ------------------------ --------------- --------------- ----------------

### Maintenance Records and Dispatch Logs {#maintenance-records-and-dispatch-logs .unnumbered}

The DOT ADA regulations at 49 CFR § 37.163(a) require that transit
agencies keep accessibility features of transit services, particularly
lifts and by implication ramps, in "operative condition." Additionally,
section 49 CFR § 37.163(d) requires transit agencies to take vehicles
with inoperative lifts (and implicitly inoperable ramps as well) out of
service when discovered to be inoperative and to repair lifts/ramps
before returning vehicles to service. DOT Regulations at 49 CFR §
37.163(e) state that when there is no spare vehicle to replace a vehicle
that has an inoperative lift, "the public entity may keep the vehicle in
service with an inoperable lift for no more than . . . three days (if
the entity services an area of over 50,000 population) from the day on
which the lift is discovered to be inoperative."

The assessment team reviewed AMA inspection and maintenance records for
lifts and ramps. The purpose of the records review was to identify
inoperable lifts and to track lift repairs from identification to
completion.

As previously discussed, lifts and ramps are not consistently inspected
by AMA operators at pull-out. When they are inspected and found
inoperable, there is no record made by the operator or pull-out
personnel of this finding.

AMA typically identifies inoperable lifts in one of three ways, which
are roughly correlated to the circumstances under which the failures are
discovered. If an inoperable lift is identified during pre-trip
inspection, a work order may be issued, particularly if major repair
work is required. The work order is the first record of such a lift
failure. Inoperable lifts are also noted in the communication center
logs when operators report them to dispatchers, as typically occurs when
the failures are identified while in service. If a lift is found to be
inoperable during PM inspections, it is so identified on the PM
inspection form, which is kept in the vehicle's file.

In addition to these typical methods of identifying inoperable lifts,
AMA recently conducted two surveys of bus lifts. The surveys evaluated
the 259 buses in AMA's active fleet. One survey was conducted throughout
the month of October 2006. The other survey was conducted on January 31,
2007. The results of the surveys are summarized in Table 4.5.

[]{#__RefHeading___Toc178096795 .anchor}Table 4.5 -- Repair to
Inoperable Lifts

  ------------ ----------------------------------- -------------- ----------- ------------
                                                   **Failure      **Other**   **Totals**
                                                   Reported in                
                                                   PMI or                     
                                                   Survey**                   

  Vehicles                                                                    

               Total                               315                        

               Out of Service                      56                         

               Active Fleet                        259                        

  Reports of                                                                  
  Inoperable                                                                  
  Lifts                                                                       

               October 2006 Survey                 93                         

               January 31 Survey                   66                         

               February 2007 Communication Center  16                         
               Logs                                                           

               PMIs / Maintenance Files            33                         

               Total Number of Reported Inoperable 163                        
               Lifts                                                          

  Work Orders                                                                 
  Issued                                                                      

               Issued                              43             9           52

               Awaiting Parts                      35             22          57

               Net                                 85                         

  Repaired                                         39             5           44
  ------------ ----------------------------------- -------------- ----------- ------------

The data concerning inoperable lifts in the table below is derived from
four data sources: the October 2006 AMA survey, the January 31, 2007 AMA
survey, a summary of dispatch logs for the month of February 2007
(compiled by the AMA communication center), and preventative maintenance
inspection (PMI) records[^2]. From these four sources, the total number
of buses identified during the period as having inoperable lifts was
163, representing 63 percent of the active fleet.

A list of work orders for lift repairs for the period from September 20,
2006 through February 22, 2007 was used to identify bus files for
review. For each identified lift, the list of work orders includes the
vehicle number, a description of the repair, the date that the work
order (job order) was issued, and the recorded date of repair. The
repair file for each of the work orders was reviewed and the work order
information was confirmed. For each lift problem that was identified in
a PMI preceding the repair, the date of the PMI was recorded as the date
the failed lift was reported and the means of identification was
recorded as "PMI."

[]{.mark}

The review team evaluated 62 work orders issued for lift repairs during
the period from September 20, 2006 to February 22, 2007. Ten of those
repairs were multiple work orders for the same bus, resulting in 62 work
orders for 52 buses. Based on the review of the work orders, the need
for 36 repairs for lifts on 33 buses appeared to have been identified
during PMIs. The method used by AMA to identify the need for repair for
the remainder of the lifts with work orders is unclear. The work orders
that could not be linked to PMIs or one of the surveys are identified in
Table 4.5 under the column "other." A file review indicated that repairs
were completed for 51 of the 62 lifts on 44 buses. Parts were not
available for the 11 remaining lifts, which were not repaired.

Of the 163 buses identified as having inoperable lifts, work orders were
issued for 43 (26 percent). Typically, a work order is not issued if a
part needed for repair is not available. Of the 120 buses for which no
work order was issued, AMA identified 35 as awaiting parts as of
February 2007. This leaves 85 (52 percent) of the 163 buses identified
with inoperable lifts which are neither awaiting parts nor have any
record of repair. Often, work orders are not issued if the repair is
minor, such as replacement of a fuse, and the reviewers were unable to
find documentation of such repairs.

### Vehicle Lift Availability {#vehicle-lift-availability .unnumbered}

The DOT regulations require that a bus operator remove from service a
bus whose lift or ramp does not operate before the next service day (49
CFR § 37.163(d)). The regulations allow an exception "if there is no
spare vehicle available to take the place of a vehicle with an
inoperable lift, such that taking the vehicle out of service will reduce
the transportation service the entity is able to provide" (49 CFR §
37.163(e)). For bus operators that serve an area of greater than 50,000
in population, a bus with an inoperable lift may be used for up to three
days after the lift is discovered to be inoperable.

[]{.mark}

The review team conducted an analysis of AMA operations to determine
whether AMA was complying with these regulations. The baseline for this
analysis was a fleet-wide survey of all AMA vehicles on Wednesday,
January 31, 2007. AMA collected data on whether the buses in service on
that day had operating lifts. According to the survey, 66 buses in
service on that day did not have properly operating lifts. The survey
did not include 24 Flxible buses with inoperable lifts that are
regularly used in service.

[]{.mark}

The review team inspected the daily pull-out records for February 1 to
5, 2007. These records identify the route assignments for all buses used
in service. Of these 66 vehicles identified with inoperable lifts, 21
were in use for four days over this five-day period and 17 vehicles were
in use for all five days. This results in a total of 38 vehicles that
were in use for more than three days after AMA had determined that they
had an inoperable lift. AMA has no records that any of these lifts were
repaired during these five days. Even without considering the Flxible
buses, this is clearly a violation of 49 CFR § 37.163. Table 4.6
summarizes the use of these 66 vehicles over the sample five-day period.

[]{.mark}

[]{#__RefHeading___Toc178096796 .anchor}Table 4.6 -- Summary of Vehicles
with Inoperable Lifts in Service

+-----------------------------------------+----------------------------+
| Total buses with inoperable lifts       | 66                         |
+-----------------------------------------+----------------------------+
| Days in Service, February 1 to 5, 2007  |                            |
+-----------------------------------------+----------------------------+
| > **5 days**                            | **17**                     |
+-----------------------------------------+----------------------------+
| > **4 days**                            | **21**                     |
+-----------------------------------------+----------------------------+
| > 3 days                                | 13                         |
+-----------------------------------------+----------------------------+
| > 2 days                                | 7                          |
+-----------------------------------------+----------------------------+
| > 1 day                                 | 7                          |
+-----------------------------------------+----------------------------+
| > Not used                              | 1                          |
+-----------------------------------------+----------------------------+
| Note: Does not include 1995 Flxible     |                            |
| buses, all of which have inoperable     |                            |
| lifts but are still used in service, in |                            |
| violation of 49 CFR § 37.163.           |                            |
+-----------------------------------------+----------------------------+

[]{.mark}

Table 4.7 shows the proportion of the vehicles with operable lifts for
each of the five sample days. It is interesting to note that AMA used
buses with inoperable lifts on Saturday and Sunday, February 3 and 4,
2007. The required number of vehicles on the weekend days is much lower
than on weekdays. It appeared that AMA had a sufficient number of
vehicles with operable lifts so that it could have deployed fully
accessible fleets on those two days. However, AMA still had 36 percent
of its buses in service with inoperable lifts on each weekend day.

[]{#__RefHeading___Toc178096797 .anchor}

Table 4.7 -- Vehicles in Service, February 1 to 5, 2007

  ------------------------------ -------- -------- -------- -------- --------
                                 **Feb    **Feb    **Feb    **Feb    **Feb
                                 1**      2**      3**      4**      5**

  Total Pull-out                 160      166      103      81       163

  Lift/Ramp Operable (as of      106      112      66       52       108
  1/31)                                                              

  Lift/Ramp Inoperable (as of    54       54       37       29       55
  1/31)                                                              

  \% Inoperable                  33.4     32.5     35.9     35.8     33.7

  Note: does not include 1995                                        
  Flxible buses, all with                                            
  inoperable lifts used in                                           
  service in violation of 49 CFR                                     
  § 37.163.                                                          
  ------------------------------ -------- -------- -------- -------- --------

### Inoperable Lifts and Parts Availability  {#inoperable-lifts-and-parts-availability .unnumbered}

The review team also reviewed the availability of buses with operable
lifts. The results of that review are summarized in Table 4.8.

[]{#__RefHeading___Toc178096798 .anchor}Flxible, the manufacturer of the
1995 buses, has gone out of business, and according to AMA as a result
parts are not readily available to repair the lifts on these buses. As a
result of lack of spares and continued usage of the vehicles, the lifts
on these buses are currently inoperable. However, as of the time of the
on-site review, the Flxible buses are still being used in regular
service (14 were assigned to service on February 1, 2007). These buses
and lifts are further addressed in the discussion on resources below.

An additional 56 lifts on other buses are inoperable and awaiting parts.
Of these buses, 27 were assigned to service on February 1, 2007. A
number of factors appear to have contributed to these part shortages, as
is discussed below.

Table 4.8 -- AMA Inoperable Lifts on February 1, 2007

  ---------- ---------- ------------- --------------- ---------- ------------ ----------- --------------
  **Year**   **Make**   **Available   **Permanently   **Lifts    **Total      **Buses in  **Inoperable
                        Buses**       Inoperable      Awaiting   Inoperable   Service**   Lifts in
                                      Lifts**         Parts**    Lifts**                  Service**

  2005       New Flyer  3                             0          0            3           0

  2005       Orion      29                            9          9            24          8

  2004       Orion      23                            4          4            18          3

  2002       Nova       10                            0          0            8           0

  2000       Nova       70                            23         23           35          4

  1999       Nova       15                            3          3            9           2

  1998       Nova       15                            5          5            10          3

  1997       Nova       61                            12         12           36          7

  1995       Flxible    24            24              0          24           14          **14**

                                                                                          

  Total                 250           24              56         80           157         41

  \% of                                                          32%                      26%
  Buses                                                                                   
  ---------- ---------- ------------- --------------- ---------- ------------ ----------- --------------

First, no spare parts for lifts were purchased at the time the 2004 and
2005 Orion buses were purchased. It had been AMA's practice to only
order parts for these lifts when the Maintenance Department makes an
initial request for a part. At the time of the review, there were 13
Orion buses awaiting parts, including sensors for the lifts. AMA's
Purchasing Department revised this practice during the review and
ordered spare parts (as identified on the parts list) for the Orion
lifts on March 7, 2007, with scheduled delivery on March 14. The
Purchasing Department also indicated that parts lists, including parts
for lifts and ramps, would be obtained for future bus purchases and
parts would be ordered as part of the bus procurement, with delivery at
the time the buses are delivered.

Further, as is discussed in Section 4.2.4, there currently is no
procedure in place to automatically notify the Operations (maintenance)
Department when out-of-stock parts are received. According to AMA
personnel, the practice had been for the warehouse to send e-mails to
maintenance when parts are received. Maintenance personnel indicated,
however, that they had received no notifications in months. Some parts
were received, but buses with inoperable lifts were not being repaired
because of the apparent breakdown in communication between the warehouse
and the maintenance staff.

The present system for parts maintenance relies on visual inspection to
identify the needs for reordering parts Although visual inspection is
helpful in identifying potential parts shortages, because of its
dependence on personal observation, it is subject to human error. As an
example, there was no follow-up on a purchase order (#40695) for lift
pumps that was cancelled in July 2005. Ten pumps were purchased on March
15, 2005, six were used by December 2005, and the last one was used on
January 26, 2007. A new requisition was initiated for the pumps, which
are reconditioned in Puerto Rico, on February 9, and they were in stock
by March 7. As a result of the failure of the manual tracking system,
the item was out-of-stock for over a month. Installation of the
Inventory Control System should reduce the number of parts shortages
resulting from human error.

AMA also attributed recent parts shortages to AMA financial problems.
During 2006, parts requisitions were held and not approved because of
the unavailability of sufficient local match to fund purchases.
Additionally, because of a failure to pay bills, some suppliers were
reportedly holding shipments, requiring cash on delivery (COD), or
declining orders outright, collectively resulting in further parts
shortages and delays. AMA managers indicated that delays of up to three
months were not uncommon around September 2006. As an example, a
requisition (#32811) was issued on October 6, 2006, and the purchase
order was delayed over four months, until February 14, 2007 because of a
lack of funds. A requisition for lift pumps (#40695) was initiated in
July 2005 but the purchase order was canceled. AMA received supplemental
funds in the form of a \$47 million loan from the Commonwealth of Puerto
Rico in February 2007 and has paid all debts to suppliers, including
debts from as far back as 2003. The loan and associated payment of
suppliers appears to have addressed this parts problem in so far as it
results from financial problems.

### Vehicle Inspections {#vehicle-inspections .unnumbered}

As part of its review, the review team looked at seven representative
buses from the AMA fixed route fleet to determine whether their designs
meet the requirements of Subpart B of 49 CFR Part 38, the Americans with
Disabilities Act Accessibility Specifications for Transportation
Vehicles. This portion of the ADA regulations applies to all new, used
or remanufactured buses. Vehicles purchased by public as well as private
entities operating services covered by the ADA, regardless of whether or
not they receive Federal funding, must comply with these specifications.

A member of the review team inspected the accessibility features of AMA
buses, including one each of the five designs represented in the AMA
fleet. These included:

-   Flxible 40\' with front-door lift

-   RTS 40\' with rear-door lift

-   RTS 30\' with rear-door lift

-   Orion V 40\' with rear-door lift

-   New Flyer 35\' with ramp

The components addressed in the bus inspections included:

-   Lift or ramp

-   Securement area

-   Other vehicle features (e.g., doors, steps, floors, handrails,
    communication devices)

The review team member used a Bus and Van Specification Checklist to
record the observations for each bus (see Attachment D). Following are
the key results of these inspections.

**Flxible 40\' with front-door lift**

The review team inspected AMA vehicle #95-096, which had the following
compliance issue:

-   Lift did not operate (49 CFR § 38.23)

> This vehicle is one of AMA's 45 model year 1995 Flxible buses.
> According to AMA staff, none of the Flxibles have an operating lift.

**RTS 40\' with rear-door lift**

The review team inspected AMA vehicles #20026 and #99013. Vehicle #99013
had the following compliance issue:

-   Lift did not operate (49 CFR § 38.23)

The review team completed the inspection with vehicle #20026, which had
an operating lift. Vehicle #20026 had the following compliance issues:

-   No sign designating a set of forward-facing seats as priority seats
    for persons with disabilities (49 CFR § 38.27(a))

-   "Stop request" control for the rear securement area did not work (49
    CFR § 38.37(a))

**RTS 30\' with rear-door lift**

The review team inspected AMA vehicle #2002-01, which had the following
compliance issue:

-   Seats designated as priority seats for persons with disabilities
    were side facing, not forward facing (49 CFR § 38.27(a))

**Orion V 40\' with rear-door lift**

The review team inspected AMA vehicles #2005-03 and #2005-14. Vehicle
#2005-03 had the following compliance issue:

-   Lift did not operate (49 CFR § 38.23)

The review team completed the inspection with vehicle #2005-14, which
had the following compliance issue:

-   "Stop request" control for the rear securement area did not work (49
    CFR § 38.37(a))

**New Flyer 35\' low-floor with ramp**

The review team inspected vehicle #2005-32. This sample vehicle complied
with all required specifications.

### Resources {#resources .unnumbered}

As described earlier, AMA has a fleet of 315 buses. At the time of the
on-site review, 56 of those 315 buses were old and unavailable for
passenger service and 9 others were off-site for warranty work and
unavailable. This leaves 250 buses to serve 195 weekday runs or a spare
ratio of .28, exclusive of buses being serviced under warranty. Of the
buses available for service, 24 are 12 years old and an additional 61
are 10 years old (see Table 4.9).

To address older buses in the fleet, AMA has proposed the acquisition of
new buses in the upcoming years. Twenty lift-equipped Orion buses have
been ordered for delivery in 2007 and purchase of 10 additional New
Flyer hybrid low-floor buses is planned. These procurements will permit
some older buses to be replaced. An additional purchase of 32 low-floor
buses is planned for 2008.

[]{#__RefHeading___Toc178096799 .anchor}Table 4.9 -- AMA Fleet Status --
February 2007

  ------------ ---------- ----------- ------------ ----------- -------------- --------------- ----------
  **Year**     **Make**   **Model**   **Total      **Out of    **Warranty**   **Available**   **Runs**
                                      Vehicles**   Service**                                  

  2005         New Flyer  Delf-35     4            0           1              3               

  2005         Orion      Orion V     30           0           1              29              

  2004         Orion      Orion V     30           0           7              23              

  2002         Nova       6.2 VN      10           0           0              10              

  2000         Nova       8.2 VN      70           0           0              70              

  1999         Nova       T802 VN     29           14          0              15              

  1998         Nova       T802 VN     18           3           0              15              

  1997         Nova       T802 VN     79           18          0              61              

  1995         Flxible    400964D50   45           21          0              24              

                                                                                              

  **Totals**                          **315**      **56**      **9**          **250**         **195**
  ------------ ---------- ----------- ------------ ----------- -------------- --------------- ----------

When the planned bus acquisitions are added to the current fleet, it
appears that AMA will have an adequate number of buses for daily service
and spares.

As noted previously, the lifts on the 1995 Flxible buses are inoperable
and can't be repaired. As mentioned above, the manufacturer is no longer
in business and according to AMA spare parts are not readily available
for these lifts. AMA is considering a lift replacement program for the
Flxble buses at a cost of \$15,000 to \$18,000 per lift. AMA is
evaluating the proposed program in light of the remaining functional and
economic life of the vehicles and the schedule for vehicle replacement.
Supplier installation is being considered for later model buses to
maintain a warranty, with lower cost in-house installation for older
buses with more limited functional life.

Ramps, which are available on low-floor buses, have been observed to be
significantly more reliable than lifts. The mechanics of a flip-out ramp
are simpler and less prone to failure than hydraulic lifts. Also, absent
damage to the frame or blockage, ramps can be easily deployed manually.

Considerations in purchasing low-floor buses should include the need for
operation on uneven pavement and the condition of bus stops,
particularly any challenges to deployment of the ramp on the sidewalk.
As discussed in Section 4.3.1, to maintain traversable slopes, ramps
should be deployed on raised sidewalks at accessible bus stops. This
requires that bus stops be accessible, be raised to a 6--7 inch curb
reveal, that stops be clear of obstructions, such as illegally parked
vehicles, and that operators curb the buses. Recognizing that design and
construction of bus stops are outside of AMA's authority, in order for
low-floor buses with ramps to be effectively utilized, bus stops should
be reviewed and modified as needed. Moreover, bus stops should be kept
clear of vehicles, and operators should be required to curb the bus.

Effective management information systems (MIS) such as fleet management
and inventory control systems require adequate technical capacity in the
form of MIS managers and technicians to support these systems. AMA
managers indicated that MIS capacity to operate these systems is good.

Based upon a review of the National Transit Database (NTD) statistics,
the typical ratio of buses to mechanics and technicians, for mid-size
bus systems, is about 2.35:1. A review of AMA's roster of maintenance
staff indicates a total of 166 maintenance personnel with 9 dedicated to
paratransit vehicles and 21 supervisors and administrative staff.
Accordingly, 136 mechanics and technicians are assigned to maintain the
fixed route bus fleet. This results in 2.32 buses per mechanic for the
full 315 bus fleet and 1.90 buses per mechanic/technician for the active
259 bus fleet. The total bus maintenance and technician staffing levels
appear to be consistent with that of comparably sized bus systems.

### Budget Process {#budget-process .unnumbered}

The AMA budget process does not appear to provide all department heads
with an effective opportunity to identify capital and operating funds
needed to effectively achieve department objectives. Providing an
opportunity for such input may have avoided significant oversights,
including the failure to order lift parts for the 2004-5 Orion buses.
Systematic input from department heads early in the budget process can
be an effective tool for identifying needs and setting priorities. Many
transit service providers also use a committee of senior managers to set
priorities and balance departmental needs against each other and
available funding.

A summary of the AMA expenses and funding levels for the years 2000
through 2006 is presented in Table 4.8. During this six-year period,
AMA's operating expenses increased approximately 15 percent for 4 of the
6 years. In 2004, operating expenses declined 13 percent, and in 2006
they increased by 1 percent. Approximately \$13 million of the overall
increase in expenses over the six-year period is associated with
provision of contract services and was off-set by contract payments for
the services.

Maintenance expenses, which are closely related to lift performance,
have fluctuated during this period between \$10.6 million and \$18.1
million, ending at \$14.8 million in 2006. Annual increases have been as
much as 33 percent in 2002 and annual declines as much as 24 percent in
2004. Expenses for vehicle materials and supplies have varied from \$3.1
million to \$8.5 million during this period, with \$3.7 million in
expenditures during 2006.

Although overall AMA expenditures have increased substantially over this
period, widely fluctuating expenditures for bus maintenance and
materials, may be contributing to availability of lift parts and the
large number of buses with inoperable lifts.

With respect to funding services, AMA officials reported that the
commonwealth does not always provide sufficient funds to match Federal
grant programs. This has resulted in foregone Federal assistance and
funding shortfalls that have impacted parts supplies, as discussed
above.

AMA managers also cited declining gas taxes as a limit to funding for
services. As can be seen in Table 4.10, gas tax revenues have declined
from \$23.4 million in 2000 to \$15.9 million in 2006.

As mentioned above, to address funding limits AMA increased base fares
from 25 cents to 75 cents in January 2006. AMA estimated that the fare
increase will result in an overall annual increase in fare revenues to
\$12 million from approximately \$6 million. The 2006 revenues of \$8.9
million indicate an increase of \$2.3 million in fare revenue for the
first six months of the fare increase. A simple linear projection
results in an estimate of \$4.6 million in increased fare revenues over
the base of \$6.6 million for 2005 for a total of \$11.2 million for a
full year.

[]{#__RefHeading___Toc178096800 .anchor}Table 4.10 -- AMA Expenses &
Funding History 2000-2006

  ------------ -------------- ---------------- ---------- ---------- ---------- ---------- ---------- ---------- ---------- ---------- ---------- ---------- ---------- ---------- ----------
                              **Year**         **2000**   **2001**              **2002**              **2003**              **2004**              **2005**              **2006**   

  **Budget**                                   **Amt**    **Amt**    **%        **Amt**    **%        **Amt**    **%        **Amt**    **%        **Amt**    **%        **Amt**    **%
                                                                     Change**              Change**              Change**              Change**              Change**              Change**

               Operating                                                                                                                                                           
               Expenses                                                                                                                                                            

                              Operations       23.5       26.9       14%        27.3       1%         28.2       3%         28.2       0%         32.8       16%        35.4       8%

                              Vehicle          10.6       12.1       14%        16.1       33%        18.1       12%        13.8       **-24%**   16.7       21%        14.8       **-11%**
                              Maintenance                                                                                                                                          

                              Facilities       1.6        1.8        13%        2.6        44%        2.6        0%         2.5        -4%        3.4        36%        2.7        -21%
                              Maintenance                                                                                                                                          

                              General          9.5        11.0       16%        13.1       19%        19.0       45%        14.4       -24%       15.4       7%         16.1       5%
                              Administration                                                                                                                                       

                                                                                                                                                                                   

                              Total            45.2       51.8       15%        59.1       14%        67.9       15%        58.9       **-13%**   68.3       16%        69.0       **1%**

                                                                                                                                                                                   

               Other Expenses                  1.9        2.2        16%        2.9        32%        8.1        179%       8.8        9%         10.2       16%        13.1       28%
               (Int, Dep)                                                                                                                                                          

                                                                                                                                                                                   

               Total                           47.1       54.0       15%        62.1       15%        76.0       22%        67.7       **-11%**   78.5       16%        82.1       5%

                                                                                                                                                                                   

  Funding                                                                                                                                                                          

               AMA                                                                                                                                                                 

                              Passenger        7.2        8.1        13%        7.9        -2%        7.6        **-4%**    7.1        **-7%**    6.6        **-7%**    8.9        35%
                              Revenues                                                                                                                                             

                              Contract         12.9       17.3       34%        16.0       -8%        18.6       16%        19.0       2%         24.6       30%        25.9       5%
                              Services                                                                                                                                             

                              Rent,            1.4        1.3        -7%        1.4        9%         1.6        14%        1.8        13%        1.6        -12%       1.6        0%
                              Concessions, Ads                                                                                                                                     

                              Interest, Other  0.7        0.3        -48%       0.2        -44%       0.1        -33%       0.3        104%       0.1        -43%       0.2        32%

                              Total            22.1       27.0       22%        25.5       -6%        27.9       10%        28.1       1%         32.9       17%        36.5       11%

                                                                                                                                                                                   

               Commonwealth                                                                                                                                                        

                              Fuel Tax         23.4       21.5       -8%        19.0       -11%       15.6       **-18%**   14.8       **-5%**    16.8       14%        15.9       -5%
                              (Diesel, Prop.)                                                                                                                                      

                              Grants           0.0        0.0        -74%       0.0        0%         0.0        -840%      0.0        -100%      0.1        N/A        0.0        -72%

                              Total            23.4       21.5       -8%        19.0       -11%       15.6       -18%       14.8       -5%        16.9       15%        15.9       -6%

                                                                                                                                                                                   

               Federal                         2.9        5.2        78%        9.3        77%        18.3       98%        14.0       **-24%**   22.5       60%        21.6       **-4%**

                                                                                                                                                                                   

               Total                           48.6       53.8       11%        53.7       0%         61.8       15%        57.0       **-8%**    72.2       26%        74.1       3%

  Amount in \$                                                                                                                                                                     
  millions; %                                                                                                                                                                      
  change from                                                                                                                                                                      
  prior year.                                                                                                                                                                      
  ------------ -------------- ---------------- ---------- ---------- ---------- ---------- ---------- ---------- ---------- ---------- ---------- ---------- ---------- ---------- ----------

# Findings and Recommendations

This section presents the review team findings and recommendations,
based on the information collected and on-site observations. For each
numbered finding, there may be one or more corresponding
recommendations.

## Findings

General findings are provided first, followed by detailed findings under
various sections of the review.

### Operation of Buses with Inoperable Lifts {#operation-of-buses-with-inoperable-lifts .unnumbered}

1.  AMA operates buses with inoperable lifts in passenger service.
    Observations of the pull-out process and the working condition of
    lifts and ramps at the AMA facility found that on March 6, 2007,
    only 28 of the 56 buses inspected (50 percent) had an operating lift
    or ramp. None of the five Flxible buses observed during pull-out had
    an operating lift. Both of the RTS 30-foot buses had operating
    lifts. The one New Flyer bus observed had an operating ramp. All 28
    vehicles that were observed during pull-out to have a non-operating
    lift continued into service.

2.  During interviews with operators, several mentioned that they do not
    have the keys required to operate the lifts. As a result, some buses
    with otherwise-operable lifts can not be used.

3.  AMA appears to place buses with inoperable lifts in service when
    there are buses with operable lifts available. AMA assigned buses
    with inoperable lifts to passenger service on Saturday and Sunday,
    February 3 and 4, 2007---36 percent of the buses in revenue service
    on each day had inoperable lifts. It appeared that AMA had a
    sufficient number of vehicles with operable lifts so that it could
    have deployed fully accessible fleets on those two days.

4.  Preventive Maintenance and lift and ramp maintenance is performed
    during peak service hours Tuesday through Saturday on the 6 a.m. to
    3 p.m. shift. As a result, usable buses with operational lifts may
    be withheld from service, requiring the use of buses with inoperable
    lifts during these hours. AMA managers indicated that they are
    considering revisions to the work schedule.

### Operation of Inoperable Lifts for More than Three Days {#operation-of-inoperable-lifts-for-more-than-three-days .unnumbered}

1.  AMA operates buses with inoperable lifts in service for more than
    three days. Thirty-eight vehicles (representing 23 percent of
    typical weekday pull-out) with inoperable lifts on February 1, 2007,
    were assigned to service on more than three days during the period
    February 1 to 5, 2007, according to AMA daily pull-out records.
    Twenty-four 1995 Flxible buses are regularly used in service even
    though their lifts are inoperable. Fourteen of the Flxible buses
    were assigned to service on February 1, 2007. Fifty-six buses
    awaiting parts for inoperable lifts are available for daily service.
    Twenty-seven of theses buses were assigned to service on February 1,
    2007.

### Routine Maintenance Checks {#routine-maintenance-checks .unnumbered}

1.  AMA employees do not perform regular daily maintenance checks of
    lifts to determine their operability. AMA operators do not cycle
    their vehicles' lifts prior to pull out. Operators do not have
    regular pre-trip inspections, and they do not have any checklist or
    inspection form to document vehicle defects for maintenance and
    repair.

### Reporting Lift Failures {#reporting-lift-failures .unnumbered}

1.  Operators do not immediately report lift failures. Since operators
    do not consistently perform pre-trip inspections, they are not
    always able to identify and report inoperable lifts before entering
    service.

2.  Operators reported 28 inoperable lifts to the AMA Control Center
    during February, 2007. AMA reported 66 buses with inoperable lifts
    used in service on February 1. It appears that operators are not
    reporting all inoperable lifts to the Control Center.

### Maintenance of Lifts & Other Accessibility Features {#maintenance-of-lifts-other-accessibility-features .unnumbered}

1.  AMA fails to maintain lift systems on its fixed route buses in good
    repair. Based on information collected during the period from
    October 2006 through February 2007 from four reporting sources, the
    total number of buses identified as having inoperable lifts during
    one of the inspections was 163, representing 63 percent of the
    active fleet of 259 buses.

2.  Eight (36 percent) of the 22 securement and restraint systems
    observed at pull-out were not clean.

3.  Sixteen (40 percent) of 40 vehicles observed at pull-out did not
    have a proper ISA displayed on the exterior of the bus near the
    accessible entrance.

4.  The 40-foot Flxible buses do not have operating lifts.

5.  An inspection of two sample 40-foot Orion V buses found one bus with
    a lift that did not operate. The other 40-foot Orion V bus met all
    but one ADAAG requirements: a "stop request" control that did not
    work (49 CFR § 38.37(a)).

6.  An inspection of two sample 40-foot RTS buses found one bus with a
    lift that did not operate. The other 40-foot RTS bus did not meet
    two ADAAG requirements: no sign designating priority seating for
    persons with disabilities, and a "stop request" control that did not
    work.

7.  The 35-foot New Flyer buses with low floors and ramps appear to meet
    all ADAAG vehicle specifications. The 30-foot RTS buses appear to
    meet all ADAAG specifications except for the sign designating the
    wheelchair securement locations. The sign was placed over
    side-facing seats rather than forward-facing seats.

8.  The first written record of an inoperable lift identified at
    pull-out or pull-in, is created when a work order is issued for
    repair. The dispatch log maintained by the communication center
    provides a record of inoperable lifts reported while a bus is in
    revenue service.

9.  Maintenance performance is tracked using written forms and paper
    copies of maintenance records, making it more difficult to manage
    and track lift maintenance than if an automated system were used.
    AMA was installing fleet management software at the time of the
    review.

10. There was a consensus among consumers interviewed that bus stops are
    not accessible. Sidewalks are inaccessible, curb ramps are limited,
    and other vehicles park in bus stops making it difficult or
    impossible to deploy lifts/ramps on the sidewalk level. The on-site
    review team's observations while riding the fixed route system
    confirmed their accounts.

11. If properly maintained, the current fleet size and planned bus
    acquisitions appear to provide AMA with an adequate number of buses
    for daily service and spares.

12. Purchase of 30 low-floor buses is planned for 2008. Use of low-floor
    buses with ramps, which are mechanically simpler than lifts, should
    significantly improve reliability of bus access.

13. The lifts on the 1995 Flxible buses are inoperable and cannot be
    repaired. The vehicle manufacturer is no longer in business and
    according to AMA spare parts are not available for these lifts. AMA
    is considering a lift replacement program at a cost of \$15,000 to
    \$18,000 per lift. If the inoperable lifts are not replaced or
    repaired, the Flxible buses must be permanently removed from
    service.

### Prompt Repair of Lifts {#prompt-repair-of-lifts .unnumbered}

1.  AMA fails to repair inoperable lifts promptly. Of the 163 buses
    identified as having inoperable lifts from four reporting sources
    spanning the period October 2006 through February 2007, work orders
    for repairs were issued for 43 (26 percent). Additionally, there was
    no record of repair for 85 of the 163 buses identified with
    inoperable lifts (52 percent), which also were not identified as
    awaiting parts.

2.  As of February 2007, 35 (29 percent) of the 120 buses for which no
    work orders were issued were awaiting parts.

3.  At the time of the review, there were thirteen 2004-5 Orion buses
    with inoperable lifts because parts were out-of-stock. Parts from
    the recommended parts list were not purchased at the time of the bus
    purchase. Parts were being ordered on an as-needed basis, resulting
    in increased numbers of inoperable lifts.

4.  At the time of the review there was no procedure in place to
    automatically notify the Operations (maintenance) Department when
    out-of-stock parts were received. As a result, buses with inoperable
    lifts were not being repaired because the maintenance staff was
    still awaiting parts that, in fact, had been received and were in
    stock.

5.  The budget process does not include the identification of needs by
    major department heads. Such input into the process can be very
    helpful in identifying resource needs before shortages result in
    service problems.

6.  According to AMA managers, during 2006, parts requisitions were held
    because of insufficient funds. Additionally, because of failure to
    pay bills, some suppliers held shipments, required cash on delivery,
    or declined orders. AMA has addressed the requisition problem with
    supplemental funds received in February 2007.

7.  AMA officials reported that the Commonwealth does not always provide
    sufficient funds to match Federal grant programs. This absence of
    local matching funds has resulted in foregone Federal assistance and
    funding shortfalls that have impacted parts supplies, and, in turn,
    accessible services.

### Accommodation of Customers with Disabilities {#accommodation-of-customers-with-disabilities .unnumbered}

1.  AMA does not have a centralized program to monitor service,
    including service for people with disabilities who need lifts to
    board buses.

2.  AMA does not have a centralized customer complaint process.
    Complaints may be filed through various departments by phone, in
    person, or by text messaging or e-mailing AMA staff. According to
    AMA, most complaints are filed with the Programming and Services
    Department, the communication center, the Legal Department, or the
    Office of the President/General Manager; however, many complaints
    may not be counted or addressed in an organized way. Complaints are
    filed by operator or employee, not in a central file.

3.  AMA does not use secret riders or other methods of monitoring
    customer service, particularly as it concerns vehicle access. Such
    programs can be effective in identifying and tracking service
    delivery problems, from the perspective of the customer.

4.  Operators do not appear to understand that people with disabilities
    who do not use scooters or wheelchairs must be allowed to use the
    lift when, as a result of their disability, it is required to access
    the vehicle. Nine of 10 operators interviewed said that allowing
    other mobility aids on lifts was not required or that they would not
    allow it, based on safety concerns. One rider interviewee who uses a
    walker and cannot use the steps to board the bus said that operators
    often refuse to deploy the lift in response to her request, stating
    that the lift is only for people who use wheelchairs. In 2006, AMA
    issued two driver bulletins reminding operators that the lift or
    ramp may be used by passengers upon request, but widespread
    misunderstanding among operators appears to persist.

5.  An April 24, 2003 memo describes the procedures for operators to
    follow if the lift fails while vehicles are in revenue service. The
    procedures require that the operator notify the communication center
    that the lift has failed and advise the customer of the outcome of
    the contact with the communication center. Additionally, alternative
    transportation must be provided if the next accessible bus is more
    than 30 minutes away.

6.  AMA reports that it has a procedure for using back-up operators and
    vehicles located throughout the service area in the event of a lift
    failure that cannot be resolved within 30 minutes. There is,
    however, little documented use of this service.

## Recommendations

### Operation of Buses with Inoperable Lifts {#operation-of-buses-with-inoperable-lifts-1 .unnumbered}

1.  AMA should develop and implement a program to improve lift
    reliability with a goal of having operating lifts or ramps on all
    buses used in passenger service. AMA should not place buses into
    service that have non-operating lifts.

2.  AMA should issue "lift keys" to each operator to ensure that a key
    is always available to operate the lift. Operators should be
    required to have a key with them at all times when in revenue
    service.

3.  AMA should not schedule buses with inoperable lifts for service when
    buses with operable lifts are available. AMA should immediately
    change its practices in this regard for weekend service.

4.  AMA should continue to seek feasible revised work schedules that
    will move preventive maintenance away from peak hours and increase
    the availability of buses with operating lifts. Performing
    preventive maintenance after buses are returned to the maintenance
    facility for the day should reduce the number of buses with
    inoperable lifts that are used in revenue service.

### Operation of Inoperable Lifts for More than Three Days {#operation-of-inoperable-lifts-for-more-than-three-days-1 .unnumbered}

1.  AMA should immediately discontinue use of buses with inoperable
    lifts, including all of the 1995 Flxble buses. In no case should
    buses be used in revenue service for more than three days without
    operable lifts, as required by 49 CFR § 37.163 (e).

### Regular Maintenance Checks {#regular-maintenance-checks .unnumbered}

[]{.mark}

1.  AMA should develop a pre-trip vehicle inspection process for
    operators to inspect, record, and report the condition of the
    vehicle, before the operator uses the vehicle in passenger service.
    The inspection should include lifts, ramps, wheelchair securements,
    stop request controls, public address system, variable message
    signs, passenger information signs, and other accessibility
    features.

### Reporting Lift Failures {#reporting-lift-failures-1 .unnumbered}

1.  Operators should report lift failures to yard supervisors before
    pull-out. Operators should submit all completed vehicle inspection
    forms to a central record keeper as part of an integrated procedure
    for reporting and tracking all lift failures.

2.  AMA should enforce the internal procedure for operators to follow
    when lifts fail while vehicles are in revenue service. Bus operators
    should contact the communication center and then advise riders of
    the exact arrangements being made to assist them. AMA should
    consider monitoring operator reporting through road supervisor
    inspection. Operator failure to follow the in-service lift failure
    procedure should trigger remedial personnel action.

### Maintenance of Lifts & Other Accessibility Features {#maintenance-of-lifts-other-accessibility-features-1 .unnumbered}

[]{.mark}

1.  Periodic preventive maintenance procedures should include inspection
    and repair of all accessibility features, including lifts, ramps,
    wheelchair securements, stop request controls, public address
    systems, variable message signs, and door and seating signs.

2.  AMA is strongly encouraged to develop an integrated system for
    reporting and tracking inoperable lifts and other failures of
    vehicle accessibility features. The tracking system should collect
    information from initial problem reports by operators, pre-trip
    inspections, communication center reports, supervisor reports, and
    customer comments. The tracking system should include up-to-date
    information from the initial identification of the problem through
    completion of the repair. The tracking system should be compatible
    with AMA's fleet management software, which was being installed at
    the time of the on-site review.

3.  To strengthen its efforts to make bus stops accessible, it is
    suggested that AMA work with appropriate local jurisdictions to
    enforce the no-parking requirements at bus stops. It is also
    suggested that AMA work with the responsible local government
    offices to improve bus stop accessibility, including installation
    and maintenance of adjacent curb ramps.

4.  AMA is encouraged to continue with the purchase of low-floor buses
    in conjunction with accessibility improvements to bus stops and
    training of operators in proper ramp deployment techniques.

5.  AMA should remove the 1995 Flxible buses with inoperable lifts from
    service until the lifts are either replaced or repaired, or retire
    the buses.

### Prompt Repair of Lifts  {#prompt-repair-of-lifts-1 .unnumbered}

1.  The program to improve lift reliability in recommendation 5.1.1
    should address the schedule for lift repair to ensure that it is
    sufficiently prompt to avoid the use of buses with inoperable lifts
    in passenger service.

2.  AMA is encouraged to expeditiously order all out-of-stock lift
    parts, and to maintain minimum inventories sufficient to avoid parts
    being out-of-stock. AMA is encouraged to continue installation of
    fleet management software, with particular attention to inventory
    control for lift/ramp parts.

3.  AMA should continue with its revised practice of purchasing parts on
    manufacturers' recommended lists, including parts for lifts and
    ramps, as it procures new buses.

4.  AMA should immediately institute a procedure for the warehouse to
    inform the Maintenance Department when out-of-stock parts are
    received.

5.  AMA should consider revising its internal budgeting process to more
    formally include the needs of departments as identified by
    department heads early in the process.

6.  AMA officials should, during the commonwealth's budgeting process,
    find a way to effectively communicate the importance of local funds
    from the commonwealth to obtaining matching Federal grants.

### Accommodation of Customers with Disabilities {#accommodation-of-customers-with-disabilities-1 .unnumbered}

1.  AMA should develop a customer-friendly complaint/comment process
    that captures all complaints and ensures a timely response to
    complaints. Centralized files should be maintained that document the
    filing and resolution of complaints. Complaint tracking can be a
    valuable management tool in identifying, tracking, and addressing
    service issues, and it should be utilized as such.

2.  AMA should consider using secret riders or other methods to provide
    independent customer-based oversight of its service. Such monitoring
    can be used to provide ongoing performance measures for lifts,
    ramps, and other accessibility features, as well as general measures
    of customer service quality.

3.  AMA should emphasize and enforce operating procedures related to
    providing accessible service (including proper operation of lifts,
    ramps, and wheelchair securements) and employ progressive discipline
    practices when necessary to ensure operator compliance.

Attachment A

**AMA's Response Letter**

**\[See other file for Attachment A\]**

Attachment B

**FTA's Notification Letter to AMA**

![](media/image1.png){width="8.666666666666666in"
height="10.444444444444445in"}

![](media/image2.png){width="8.01388888888889in"
height="10.458333333333334in"}

![](media/image3.png){width="7.986111111111111in"
height="10.319444444444445in"}

Attachment C

**On-Site Review Schedule**

**ADA Fixed Route Lift/Ramp Service Review**

**Autoridad Metropolitana de Autobuses (AMA)**

**San Juan, Puerto Rico**

**March 5-8, 2007**

**SCHEDULE**

+-------+------------------------------------+---------------+--------+
| **T   | **Activity**                       | **Who**       | **W    |
| ime** |                                    |               | here** |
+-------+------------------------------------+---------------+--------+
| **Mo  |                                    |               |        |
| nday, |                                    |               |        |
| March |                                    |               |        |
| 5,    |                                    |               |        |
| 2     |                                    |               |        |
| 007** |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| 9:00  | Opening Conference (requires       | FTA, AMA,     | AMA    |
| AM    | conference call connection to FTA) | Review Team   |        |
|       |                                    | Members       |        |
+-------+------------------------------------+---------------+--------+
| 9:30  | Interview AMA managers. Review     | Suarez, AMA;  | Same   |
| AM-   | operating policies and procedures, |               | as     |
| 11:00 | fleet information, service issues  | Review Team   | above  |
| AM    | and monitoring, and operator       | Members       |        |
|       | training.                          |               |        |
+-------+------------------------------------+---------------+--------+
| 11:00 | Review details of recent           | Suarez, AMA;  | Same   |
| AM-   | ramp/accessibility-related         | Review Team   | as     |
| 11:30 | complaints                         | Members       | above  |
| AM    |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| 11:30 | Tour facility                      | AMA, All      | Same   |
| AM-12 |                                    | Review Team   | as     |
| PM    |                                    | Members       | above  |
+-------+------------------------------------+---------------+--------+
| 1:00  | Observe service                    | Review Team   | []{    |
| PM    |                                    | Members       | .mark} |
| -6:00 |                                    |               |        |
| PM    |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| **Tue |                                    |               |        |
| sday, |                                    |               |        |
| March |                                    |               |        |
| 6,    |                                    |               |        |
| 2     |                                    |               |        |
| 007** |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| 4:00  | Observe ramp, lift and kneeler     | Review Team   | AMA    |
| AM    | Cycling                            | Members       |        |
| -9:00 |                                    |               |        |
| AM    | Inspect securement systems         |               |        |
+-------+------------------------------------+---------------+--------+
| 10:00 | Interview maintenance              | AMA, Review   | Same   |
| AM    | supervisor/staff                   | Team Members  | as     |
| -2:00 |                                    |               | above  |
| PM    | Review lift/ramp maintenance       |               |        |
|       | procedures and records             |               |        |
+-------+------------------------------------+---------------+--------+
| 11:00 | Interview drivers                  | Rodriguez     | Same   |
| AM    |                                    |               | as     |
| -2:00 |                                    |               | above  |
| PM    |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| **    |                                    |               |        |
| Wedne |                                    |               |        |
| sday, |                                    |               |        |
| March |                                    |               |        |
| 7,    |                                    |               |        |
| 2     |                                    |               |        |
| 007** |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| 8:00  | Observe service                    | Review Team   |        |
| AM    |                                    | Members       |        |
| 12:00 |                                    |               |        |
| PM    |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| 1:00  | Review lift/ramp maintenance       | AMA; Review   | AMA    |
| PM    | records                            | Team Members  |        |
| -5:00 |                                    |               |        |
| PM    | Inspect vehicles                   |               |        |
|       |                                    |               |        |
|       | Review driver & mechanic training  |               |        |
|       | procedures                         |               |        |
|       |                                    |               |        |
|       | Interview drivers                  |               |        |
+-------+------------------------------------+---------------+--------+
| *     |                                    |               |        |
| *Thur |                                    |               |        |
| sday, |                                    |               |        |
| March |                                    |               |        |
| 8,    |                                    |               |        |
| 2     |                                    |               |        |
| 007** |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| 9:00  | Final data tabulations & prepare   | Review Team   |        |
| AM    | for Exit Conference                | Members       |        |
+-------+------------------------------------+---------------+--------+
| 1:00  | Exit Conference (requires          | FTA, AMA,     | Same   |
| PM    | conference call connection to FTA) | Review Team   | as     |
|       |                                    | Members       | above  |
+-------+------------------------------------+---------------+--------+

**Review Team Members:**

Rosemary Gerty, TranSystems, Team Leader

Pilar Rodriguez, TranSystems, Reviewer/Translator

David Chia, Planners Collaborative, Reviewer

Don Kidston, Planners Collaborative, Reviewer

**AMA Facility:**

37 Ave de Diego, Rio Piedras, PR

Attachment D

**On-Site Review Forms**

**AMA (San Juan, PR)**

**Fixed Route Driver Interview Form**

This interview will take about 15 minutes. Your comments will be
summarized with other driver's responses and you will not be identified
individually. Feel free to let me know if there is a question you do not
wish to answer.

**Tell me a little about yourself...\
**

> How long have you been a bus driver for AMA? \_\_\_\_\_\_\_\_\_\_
>
> Are you a \_\_\_\_full-time or \_\_\_\_part-time/relief driver?
>
> Do you usually drive a \_\_\_ lift-equipped bus or \_\_\_\_
> ramp-equipped bus or \_\_\_\_ both
>
> How often do you transport a person using a wheelchair or scooter?
> (daily, weekly...)

**Training**

> When you started working for AMA, how much and what type of training
> were you given about the use of lifts, ramps, securement systems, and
> passenger assistance?
>
> Was the training adequate? *(What would make it better?)*
>
> Is there refresher/update training for lift, ramp, and securement use?
> What type and how often?

**Lift/Ramp/Securement Information**

> When and how often do you test cycle the lift/ramp? *(Listen for daily
> during pre-trip inspection)*
>
> What do you do if a lift/ramp doesn't work when you are test cycling
> it? *(How reported/action taken?)*
>
> If you report that a lift/ramp is broken, how quickly is it fixed?
>
> Are you ever sent out with a bus that has a broken lift/ramp? If so,
> how often?
>
> If the lift/ramp breaks while you are in service, what do you do?
>
> If you are driving a bus with a broken lift/ramp, what do you do if
> you see a person who uses a wheelchair waiting at a stop?
>
> Do you usually deploy the ramp/lift in the street or on a sidewalk?
>
> What type of assistance do you offer to people who use wheelchairs
> when they are boarding?
>
> If someone using a "scooter" gets on the bus and there are no standard
> places to attach the securement system straps, what do you do?
>
> What do you do if a person with a disability gets on the bus and asks
> for priority seating but the priority seats are taken?
>
> Is there anything else you would like to tell me about wheelchair
> lifts, ramps or securements that I didn't ask?

**AMA (San Juan, PR)**

**Formulario de Entrevista a Conductores de Rutas Regulares:**

Esta entrevista se demorará aproximadamente 15 minutos. Sus comentarios
se van a unir y resumir junto con las respuestas de otros conductores y
usted no será identificado individualmente. Por favor dígame en su
momento si existe alguna pregunta que usted no quiera responder.

**Cuénteme un poco sobre usted mismo...\
**

> Desde hace cuánto es usted conductor de la AMA? \_\_\_\_\_\_\_\_\_\_
>
> Trabaja usted \_\_\_\_ tiempo completo (full time) o \_\_\_\_tiempo
> parcial/conductor de relevo (part time)?
>
> Usted normalmente guía una \_\_\_ guagua equipada con ascensor
> \_\_\_\_ equipada con rampa o \_\_\_\_ ambas
>
> Que tan frecuentemente transporta usted una persona en silla de ruedas
> o scooter? (diaramente, semanalmente, mensualmente...)

**Training**

> Cuando usted empezó a trabajar para la AMA, cuánto y qué tipo de
> entrenamiento recibió con respecto al uso de rampas, ascensores,
> cinturones para asegurar a los impedidos y asistencia a los pasajeros
> impedidos?
>
> El entrenamiento fue el adecuado? *(Qué lo haría mejor?)*
>
> Existe un entrenamiento de actualización sobre el uso de rampas,
> ascensores, y cinturones? De qué tipo y qué tan frecuente?

**Información sobre Ascensor/Rampa/Cinturones**

> Cuándo y qué tan frecuentemente usted revisa la rampa/ascensor? *(OJO:
> diariamente durante la inspección pre-viaje)*
>
> Que hace usted si una rampa/ascensor no funciona cuando usted la
> revisa? *(Que reportes/acciones se toman?)*
>
> Si usted reporta que una rampa/ascensor está dañado, cuánto se demoran
> en arreglarla?
>
> Alguna vez ha salido usted del garaje a prestar servicio con una
> guagua que tiene la rampa/ascensor dañado? Si sí, cada cuánto?
>
> Si la rampa/ascensor se daña mientras que la guagua está en servicio,
> qué hace usted?
>
> Si usted está guiando una guagua con la rampa/ascensor dañada, que
> hace usted si ve una persona impedida esperando en una parada?
>
> Usted usualmente baja la rampa/ascensor en la calle o en la acera?
>
> Qué tipo de asistencia le ofrece usted a personas en sillas de ruedas
> cuando están abordando la guagua?
>
> Si alguien que usa un "scooter" se sube a la guagua y no hay espacios
> designados para asegurar los cinturones de seguridad, qué hace usted?
>
> Qué hace usted si una persona impedida se sube en la guagua y requiere
> una silla de las asignadas a impedidos pero éstas están ocupadas?
>
> Hay algo más que usted me quisiera decir con respecto a las sillas de
> ruedas, rampas, o sistemas de cinturones de seguridad que yo no le
> haya preguntado?

**In-Service Assessment Form**

Transit Agency: [AMA (San Juan, PR)]{.underline}

Check one:  Consumer Ride-Along  In-service Observation

Check applicable:  Power wc  manual wc  standee on lift/ramp 
kneeler required

Route \# \_\_\_\_\_\_\_\_\_\_ Bus \# \_\_\_\_\_\_\_\_\_\_

Check one:  Lift-equipped  Ramp-equipped

Boarding Location: Time: \_\_\_\_\_\_ am/pm

Alighting Location: Time: \_\_\_\_\_\_ am/pm

  ------------- ------------------------------ -------- -------- -------- -------- -------- --------- ------------------------------------------------------------
  **Path of                                             **Y**             **N**             **N/A**   **Comments**
  Access**                                                                                            

  1\.           Did the stop and the path of            \_\_\_            \_\_\_            \_\_\_    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                travel to the stop appear to                                                          
                be accessible?                                                                        

  **Boarding                                                                                          
  the Bus**                                                                                           

  1\.           Did the driver stop for the    \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                passenger?                                                                            

                If so, did he pull to the curb \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                (if applicable)?                                                                      

  2\.           Did the driver kneel the bus?  \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

  3\.           Did the ramp/lift work         \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                properly?                                                                             

                If not, did the driver         \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                manually deploy the ramp?                                                             

                If [not]{.underline}, did      \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                driver appear to call                                                                 
                dispatch?                                                                             

                If [not]{.underline}, did the  \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                driver tell the passenger when                                                        
                & how they would be                                                                   
                transported?                                                                          

  4\.           Was the rider able to board    \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                independently? In what                                                                
                direction?                                                                            

  5\.           Did the driver assist the      \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                rider getting up the ramp? If                                                         
                yes, in what direction?                                                               

  **Securing                                                                                          
  the Mobility                                                                                        
  Aid**                                                                                               

  1\.           If needed, did the driver      \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                request a passenger to vacate                                                         
                the securement area?                                                                  

  2\.           Did the driver assist in       \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                securing the wheelchair?                                                              

  3\.           Did the wheelchair appear to            \_\_\_            \_\_\_            \_\_\_    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                be properly secured?                                                                  

  **Alighting                                                                                         
  from the                                                                                            
  Bus**                                                                                               

  1\.           Did driver pull to the curb    \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                (if applicable)?                                                                      

  2\.           Did the driver kneel the bus?  \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

  3\.           Did the ramp/lift work         \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                properly?                                                                             

                If not, did the driver         \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                manually deploy the ramp?                                                             

  4\.           Was the driver professional    \_\_\_            \_\_\_            \_\_\_             \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                and courteous?                                                                        

  **Path of                                                                                           
  Egress**                                                                                            

  1\.           Did the stop and path of                \_\_\_            \_\_\_            \_\_\_    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
                travel from the stop appear to                                                        
                be accessible?                                                                        

                                                                                                      
  ------------- ------------------------------ -------- -------- -------- -------- -------- --------- ------------------------------------------------------------

Notes:

**Record of Lift Cycling/Working Condition of Lifts and Access
Features**

Transit Agency: [AMA (San Juan, PR)]{.underline} **Bus
#:\_\_\_\_\_\_\_\_\_\_ Route #:\_\_\_\_\_\_\_\_\_\_**

**Check one:  Ramp-equipped  Lift-equipped**

**Cycled By:  Driver  Mechanic  Starter (check one)**

**Lift/Ramp Worked?  Yes  No**

**Ramp Tool On Bus?  Yes  No**

**Kneeler Worked?  Yes  No**

ISA displayed near door?  Yes  No

Illuminated front and side destination signs?  Yes  No

Sign requesting passengers to vacate securement area upon request?  Yes
 No

**Securements available and functional?  Yes  No**

**Three-point passenger restraint available and functional?  Yes  No**

**Securements and passenger restraints clean?  Yes  No**

PA Worked?  Yes  No

Auditory & visual stop request?  Yes  No

**Operator Familiar with Equipment:  Yes  No
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

Comments:

**\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\--**

**Bus #:\_\_\_\_\_\_\_\_\_\_ Route #:\_\_\_\_\_\_\_\_\_\_  Ramp  Lift
(check one)**

**Cycled By:  Driver  Mechanic  Starter (check one)**

**Lift/Ramp Worked?  Yes  No**

**Ramp Tool On Bus?  Yes  No**

**Kneeler Worked?  Yes  No**

ISA displayed near door?  Yes  No

Illuminated front and side destination signs?  Yes  No

Sign requesting passengers to vacate securement area upon request?  Yes
 No

**Securements available and functional?  Yes  No**

**Three-point passenger restraint available and functional?  Yes  No**

**Securements and passenger restraints clean?  Yes  No**

PA Worked?  Yes  No

Auditory & visual stop request?  Yes  No

**Operator Familiar with Equipment:  Yes  No
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

Comments:

**Bus and Van Specification Checklist**

**Name of Recipient:**

**Fleet \# Assigned by Recipient/Operator (if applicable):**

**Type of Vehicle: (check one) \_\_\_ Minivan \_\_\_ Van \_\_\_ Minibus
(\< = 22\')**

**\_\_\_Minibus(\> 22\') \_\_\_ Bus (\> 22\')**

**Make/Model:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Year**

**Name of Person Conducting
Review:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Signature:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Date:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Following is a summary of the provisions of Subpart B of 49 CFR Part
38 - the \"Americans with Disabilities Act (ADA) Accessibility
Specifications for Transportation Vehicles." This portion of the ADA
regulations applies to all new, used, or remanufactured buses and vans
(except over-the-road, intercity buses). Also, if portions of a vehicle
are modified in a way that affects or could affect accessibility, each
portion must comply, to the maximum extent practicable.**

**Vehicles purchased by public as well as private entities operating
services covered by the ADA, regardless of whether or not they receive
federal funding, must comply with these specifications. Existing
inaccessible buses do not have to be retrofitted to be brought into
compliance.**

**All dimensions listed are subject to conventional engineering
tolerances, including normal anticipated wear not exceeding accepted
industry-wide standards and practices.**

**For each required specification below, indicate in the left-hand
margin if the vehicle meets the specification, does not meet the
specification, or the specification is not applicable to the vehicle
being inspected. If the vehicle does not meet the specification, note
actual measurements in the space provided to the right. Clearly indicate
what the measurements are.**

**For some specifications (such as lift design load, securement
strength, etc.), it may be appropriate to refer back to manufacturers
information that was provided with the vehicle.**

**Lift Specifications: \_\_\_ N/A (ramp specs p. 4)**

**The design load of a lift must be at least 600 pounds. Working parts
must have a safety factor of at least six. Non-working parts shall have
a safety factor of at least three.**

**Controls must be interlocked with the brakes, transmission, or door so
that the vehicle cannot move unless the interlock is engaged.**

**Controls must be \"momentary contact type\" (meaning they require
constant pressure) and must allow the up/down cycle to be reversed
without causing the platform to \"stow\" while occupied.**

**Lifts must be equipped with an emergency back-up system. The emergency
back-up system shall be capable of being operated both up and down
without the platforms \"stowing\" while occupied.**

**Must be designed so that in the event of a power failure, the platform
cannot fall faster than 12 inches per second.**

**Must have an inner barrier or inherent design feature to prevent the
mobility aid from rolling off the side closest to the vehicle until the
platform is in its fully raised position.**

**Side barriers must be at least one and one-half inches high.**

**The \"loading-edge\" (or outer barrier) shall be sufficient to prevent
a power wheelchair from riding over or otherwise defeating it (note that
this test must be performed with the wheelchair facing both toward the
vehicle and away from the vehicle as boarding in both directions must be
permitted). If this barrier is automatic, it must close when the
platform is no more than 3 inches off the ground. If the outer-barrier
is to be driver operated, it must have an interlock or inherent design
that prevents the platform from being raised until the barrier is closed
or other system is engaged.**

**The platform surface must be slip-resistant with no protrusions over
1/4 of an inch.**

**The platform must be at least 28 1/2 inches wide measured at the
platform surface and at least 30 inches wide measured from 2 inches
above the platform surface to 30 inches above the surface. It must also
be at least 48 inches long measured from 2 inches above the surface to
30 inches above the surface.**

**Gaps between the platform surface and any barrier can be no more than
5/8 of an inch. Semi-automatic lifts can have a handhold in the platform
that measures no more than 1 1/2 inches by 4 1/2 inches.**

**When in the fully raised position, the platform surface must be
vertically within 5/8 inch of the finished floor and horizontally within
1/2 inch of the finished floor.**

**The ramp from ground to platform (often the lowered outer barrier)
must have a slope of no more than 1:8 for a maximum rise of 3 inches
(i.e., if platform I inch off the ground, ramp must be at least 8 inches
long). If the threshold from ground to ramp (i.e., the thickness of the
ramp material) is more than 1/4 inch; it must be beveled with a slope no
greater than 1:2.**

**The platform must not deflect more than 3 degrees in any direction
when a 600 pound load is placed on the center of the platform.**

**The platform must raise or lower in no more than 6 seconds. The
platform must be stowed or deployed in no more than 12 seconds.
Horizontal acceleration can be no more than .3g.**

**Lift must be designed to allow boarding in either direction.**

**Must be equipped with two handrails which move in tandem with the lift
platform. Handrails must be 30 - 38 inches above the platform surface
and must have a useable gasping area of at least 8 inches. Handrails
must be capable of supporting 100 pounds, must have a cross-sectional
diameter of 1 1/4 to 1 1/2 inches, and must have at least 1 1/2 inches
of \"knuckle clearance\".**

**Lifts may be marked to identify the preferred standing position.**

**Ramp Specifications: \_\_\_\_ N/A**

**Ramps 30 inches or greater in length must have a design load of 600
pounds. Ramps under 30 inches in length must have a design load of 300
pounds.**

**Ramp surface must be continuous and sup-resistant. Protrusions can be
no more than 1/4 inch.**

**Ramps must be at least 30 inches wide.**

**Ramps must accommodate both three-wheeled and four-wheeled mobility
aids (e.g., they must be designed to support a wheel in the center of
the ramp).**

**If the threshold from the ground to the ramp surface (e.g., the
thickness of the ramp surface) exceeds 1/4 inch, it must be beveled with
a maximum slope of 1:2.**

**Side barriers, at least 2 inches high, must be provided.**

**Ramps must have the least slope practicable. When the ramp is deployed
to ground level the slope cannot exceed 1:4 (i.e., for a vehicle with a
finished floor 12 inch above the ground, a 48 inch ramp would be
needed). When deployed to a 6 inch curb the following maximum slopes
would apply:**

**finished floor height**

**[above 6 inch curb]{.underline} [maximum slope]{.underline}**

**3\" or less 1:4**

**6\" or less, but \> 3\" 1:6**

**9\" or less, but \> 6\" 1:8**

**greater than 9\" 1:12**

**The ramp must be firmly attached to the vehicle.**

**Gaps between the ramp and vehicle finish floor can be no more than 5/8
of an inch.**

**A compartment of securement system must be provided for the ramp to
keep it from impinging on the space set aside for mobility aid users and
to keep it from becoming a hazard in the event of a sudden stop.**

**Handrails are not required. If they are provided, however, they must
support 100 pounds, be between 30 inches and 38 inches above the ramp
surface, have a cross-sectional diameter of 1 1/4 to 1 1/2 inches, be
continuous for the full length of the ramp, and provide at least 1 1/2
inches of \"knuckle clearance\".**

**Securement Area:**

**Vehicles over 22 feet in length must have two (2) securement
locations. Vehicles 22 feet and under must have one (1) securement
location. Vehicles are to be measured from the front-most part to the
rear-most item (including the bumpers).**

**Wheelchairs and mobility aids must be oriented as follows:**

**For vehicles greater than 22 feet in length, at least one securement
position must be forward facing. Other securement areas can be either
forward or rear-facing.**

> **For vehicles 22 feet in length or less, the one required position
> can be either forward or rear facing.**

**If wheelchair and mobility-aid-users are secured in a rear-facing
orientation, a padded barrier must be provided. The barrier must be 18
inches wide and extend from 38 inches to 56 inches above the floor.**

**Securement systems must have the following design loads:**

**For vehicle with a GVWR of 30,000 pounds or more: 2,000 pounds for
each strap/clamp, and 4,000 pounds per mobility aid.**

**For vehicles with a GVWR of less than 30,000 pounds: 2,500 pounds per
clamp/strap, and 5,000 pounds per mobility aid.**

**Securement area must be located as close to the accessible entrance as
possible.**

**A clear floor area of 30 inches wide by 48 inches long must be
provided for each securement area. This can include an area up to 6
inches under a seat as long as there is a vertical clearance of at least
9 inches. If flip-seats are utilized, they cannot obstruct the required
floor area. The required floor area can overlap the access path (the
path of travel from the accessible entrance to the securement area).**

**The securement system must accommodate all common wheelchairs and
mobility aids (any mobility aid not exceeding 30 inches in width and 48
inches in length and weighing no more than 600 pounds when occupied) and
be able to be operated by someone with average dexterity who is familiar
with the system.**

**Securement systems must keep mobility aids from moving no more than 2
inches in any direction.**

**The securement system must be located to be readily accessed when
needed, but must not interfere with passenger movement or be a hazard to
passengers. It should also be reasonably protected from vandalism.**

**A seat belt and shoulder harness must be provided for each securement
position. The seat belt and shoulder harness must be separate from the
securement system for the mobility aid.**

**A sign must be provided which indicates that the securement area is to
be used by persons who use wheelchairs and mobility aids. Characters on
these signs shall have a width to height ratio between 3:5 and 1:1 and a
stroke width to height ratio between 1:5 and 1:10. Minimum character
height (using a capital X) shall be 5/8 inch. Wide spacing shall be used
(generally the space between letters shall be 1/16 the height of upper
case letters). Letters must contrast with the sign\'s background
color.**

**General Vehicle Specifications:**

**Aisles, steps, and floor areas must be slip resistant.**

**Step edges, thresholds, and the boarding edge of ramps or lift
platforms must have a band of color which contrasts with the step/floor
surface. Typically, white or bright yellow is used to contrast against
dark floors.**

**The height of doors at accessible entrances and the interior height
along the path of travel between accessible entrances and securement
areas shall be as follows:**

**For vehicles 22 feet or longer, the clearance from the raised lift
platform or the ramp surface to the top of the door must be at least 68
inches.**

**For vehicles less than 22 feet, the overhead clearance must be at
least 56 inches.**

**At least one set of forward-facing seats must be designated as
priority seats for persons with disabilities. Signs identifying these as
priority seats must be provided. Characters on these signs shall have a
width to height ratio between 3:5 and 1:1 and a stroke width to height
ratio between 1:5 and 1:10. Minimum character height (using a capital X)
shall be 5/8 inch. Wide spacing shall be used (generally the space
between letters shall be 1/16 the height of upper case letters). Letters
must contrast with the sign\'s background color.**

**Interior handrails and stanchions should not interfere with the path
of travel of a common wheelchair from the accessible entrance to the
securement areas.**

**Handrails and stanchions shall be provided in the entrance area and
through the fare collection area to assist persons with disabilities as
they enter and pay a fare. Some portion of this handrail/stanchion
system must be able to be grasped from outside the vehicle to assist the
person as they start to board. Handrails shall have a cross-sectional
diameter of between 1 1/4 and 1 1/2 inches, shall provide a minimum of 1
1/2 inches of \"knuckle clearance,\" and shall have eased edges with
corner radii of not less than 1/8 inch.**

**On vehicles 22 feet in length or longer which have fare collection
systems, a horizontal assist shall be provided across the front of the
vehicle to allow a person to lean against the assist while paying a
fare.**

**Handrails and stanchions shall also be provided to assist with
on-board circulation, sitting and standing, and exiting the vehicle.**

**For vehicles longer than 22 feet, an overhead handrail or handrails
shall be provided which are continuous from front to back except for a
gap at the rear doorway.**

**For vehicles longer than 22 feet which have front door lifts or ramps,
vertical stanchions immediately behind the driver shall either terminate
at the lower edge of the aisle-facing seats or be \"dog-legged\" so that
the floor attachment does not impede or interfere with wheelchair
footrests.**

**If the driver\'s seat must be passed by a wheelchair user, the
pedestal shall not extend into the aisle or vestibule beyond the
wheelhousing, to the maximum extent practicable.**

**Lighting of at least 2 foot-candles, measured on the step treads or
lift platform, shall be provided in the stepwell or doorway immediately
adjacent the driver. Lighting shall activate when the door is opened.**

**Other stepwell and doorways shall have similar lighting at all
times.**

**Lighting of at least 1 foot-candle shall be provided outside all
doorways to illuminate the street surface for an area up to 3 feet
perpendicular to the bottom step tread outer edge. Lighting shall be
located below window level and shall be shielded to protect the eyes of
entering and exiting passengers.**

**Fareboxes are to be located as far forward as possible and must not
obstruct traffic in the vestibule area, particularly wheelchairs and
mobility aids.**

**Vehicles in excess of 22 feet used in multiple-stop, fixed route
service must be equipped with a public address system.**

**For vehicles in excess of 22 feet where passengers are permitted to
exit at multiple stops at their option, a \"stop request\" control must
be provided adjacent to the securement locations. The system shall
provide both auditory and visual indications that the stop has been
requested. Controls shall be located from 15 inches to 48 inches above
the floor, shall be operable with one hand, shall not require tight
grasping, pinching, or twisting of the wrist, and shall be activated by
a force no greater than 5 lbf.**

**If destination or route information is displayed on the exterior of a
vehicle, illuminated signs shall be provided at the front and boarding
side of the vehicle. Characters on these signs shall have a width to
height ratio between 3:5 and 1:1 and a stroke width to height ratio
between 1:5 and 1:10. Minimum character height (using a capital X) shall
be I inch for signs on the boarding side and 2 inches for front
\"headsigns\". Wide spacing shall be used (generally the space between
letters shall be 1/16 the height of upper case letters). Letters must
contrast with background color.**

**Lift Maintenance and Repair Summary Form**

Transit Agency: [AMA (San Juan, PR)]{.underline}

  -------------------------- ------------ ------------ -------------------
  **Bus \# and Repair        **Date       **Date       **In Service In
  Needed**                   Breakdown    Repaired**   Interim? Spares
                             Reported**                Available?**

  \# \_\_\_\_\_                                        

  \# \_\_\_\_\_                                        

  \# \_\_\_\_\_                                        

  \# \_\_\_\_\_                                        

  \# \_\_\_\_\_                                        

  \# \_\_\_\_\_                                        

  \# \_\_\_\_\_                                        

  \# \_\_\_\_\_                                        

  \# \_\_\_\_\_                                        
  -------------------------- ------------ ------------ -------------------

Notes

Attachment E

**Customer Comment Form**

![](media/image5.png){width="5.555555555555555in"
height="8.98611111111111in"}

Attachment F

**OPPI Strategic Plan Agreement**

![](media/image6.png){width="6.497916666666667in"
height="8.465277777777779in"}![](media/image7.png){width="5.995833333333334in"
height="8.649305555555555in"}

![](media/image8.png){width="5.997222222222222in"
height="3.7805555555555554in"}

Attachment G

**AMA Notices and Bulletins Regarding Accessible Fixed Route Service
Operation Policies and Procedures**

![](media/image9.png){width="6.492361111111111in"
height="8.942361111111111in"}

![](media/image10.png){width="6.489583333333333in"
height="7.513194444444444in"}

**\
**

![](media/image11.png){width="6.495138888888889in"
height="8.292361111111111in"}

![](media/image12.png){width="6.49375in" height="8.354166666666666in"}

![](media/image13.png){width="6.4944444444444445in"
height="7.480555555555555in"}

Attachment H

**Sample AMA Maintenance Logs, Reports, and Forms**

![](media/image14.png){width="6.488194444444445in"
height="8.63888888888889in"}

![](media/image15.png){width="6.497916666666667in"
height="8.180555555555555in"}

![](media/image16.png){width="5.858333333333333in"
height="8.991666666666667in"}

![](media/image17.png){width="6.493055555555555in" height="9.5in"}

[^1]: The word "lift" is used in the DOT's ADA regulations to describe
    the accessibility feature for boarding and alighting riders using
    wheelchairs and others unable to use the steps of the vehicle.
    Similar requirements would apply to other boarding technologies and
    systems, such as ramps used on low-floor buses. AMA uses the Spanish
    word "rampa" to describe both lifts and ramps.

[^2]: The PMI information was identified through a review of bus
    maintenance files.