Capital District Transportation Authority (CDTA)

**Albany, New York**

**March 27--30, 2006**

***Summary of Observations***

###### Review of Stop Announcement {#review-of-stop-announcement .unnumbered}

**and Route Identification Efforts**

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, DC**

**Prepared by**

**Planners Collaborative, Inc.**

#######  {#section .unnumbered}

####### Final Report: February 7, 2006 {#final-report-february-7-2006 .unnumbered}

CONTENTS

[[1. Introduction 1]{.smallcaps}](#introduction)

[1.1 Overview of the Review 1](#overview-of-the-review)

[1.2 Overview of CDTA 3](#overview-of-cdta)

[1.3 Formal Complaints 4](#formal-complaints)

[1.4 Agency and Rider Comments 4](#agency-and-rider-comments)

[2. Summary of Findings 6](#summary-of-findings)

[2.1 Findings Regarding Efforts to Comply with Stop Announcements and
Route Identification Requirements
6](#findings-regarding-efforts-to-comply-with-stop-announcements-and-route-identification-requirements)

[2.2 Findings Regarding Stop Announcements
6](#findings-regarding-stop-announcements)

[2.3 Findings Regarding Route Identification
7](#findings-regarding-route-identification)

[3. Efforts to Comply with Stop Announcements and Route Identification
Requirements
8](#efforts-to-comply-with-stop-announcements-and-route-identification-requirements)

[3.1 Policies and Procedures 8](#policies-and-procedures)

[3.2 Driver Training 9](#driver-training)

[3.3 Monitoring Procedures 10](#monitoring-procedures)

[3.4 Driver Discipline 12](#driver-discipline)

[3.5 Automated Stop Announcement and Route Identification
13](#automated-stop-announcement-and-route-identification)

[3.6 Findings 15](#findings)

[3.7 Recommendations 16](#recommendations)

[4. Review of On-Board Stop Announcements
17](#review-of-on-board-stop-announcements)

[4.1 Regulatory Requirements 17](#regulatory-requirements)

[4.2 Consumer Comments 17](#consumer-comments)

[4.3 Bus Operator Interviews 17](#bus-operator-interviews)

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

[4.5 Selection of Stops for Announcing
19](#selection-of-stops-for-announcing)

[4.6 Findings 22](#findings-1)

[4.7 Recommendations 23](#recommendations-1)

[5. Review of Vehicle/Route Identification
24](#review-of-vehicleroute-identification)

[5.1 Regulatory Requirements 24](#regulatory-requirements-1)

[5.2 Consumer Comments 24](#consumer-comments-1)

[5.3 Bus Operator Interviews 24](#bus-operator-interviews-1)

[5.4 Review Team Observations 24](#review-team-observations-1)

[5.5 Findings 25](#findings-2)

[5.6 Recommendations 25](#recommendations-2)

*Attachment A* On-Site Review Schedule

*Attachment B* CDTA Response to Draft Report

*Attachment C* Customer Service Checklist

*Attachment D* Quality of Service Check Sheet

*Attachment E* TD-4 Incident Report

*Attachment F* On-Board Ride Questionnaire

*Attachment G* On-Board Observation/Ride Check List

*Attachment H* Service Performance Analysis Report: Garage/Layover Check

*Attachment I* Service Performance Analysis Report: On-Board Check

*Attachment J* On-Line Problem Report

*Attachment K* MDCS Driver Problem Report

*Attachment L* Fixed Route Driver Interview Form

*Attachment M* On-Board Fixed Route Stop Announcement Assessment Form
(sample for Route #3 North)

*Attachment N* On-Board Stop Announcement Data

*Attachment O* Suggested Stop List for Announcement for CDTA Route #1

*Attachment P* External Route Identification Data

# Introduction

## Overview of the Review

The Federal Transit Administration (FTA) is responsible for ensuring
compliance with the Americans with Disabilities Act of 1990 (ADA) and
the U.S. Department of Transportation regulations (49 CFR Parts 27, 37,
and 38) that implement this civil rights law. As part of its compliance
efforts, FTA, through its Office of Civil Rights, conducts periodic
reviews of fixed route transit services operated by grantees. In a
letter dated December 30, 2005, FTA notified the Capital District
Transportation Authority (CDTA) that a fixed route review had been
scheduled and would be conducted within 120 days of the date of the
letter. The FTA notification letter also explained that the review would
consider:

1.  On-board stop announcements

2.  Route identification efforts

The requirements for stop announcements and route identification are set
forth in 49 CFR §37.167:

> *(b) On fixed route systems, the entity shall announce stops as
> follows:*
>
> *(1) The entity shall announce at least transfer points with other
> fixed routes, other major intersections and destination points, and
> intervals along a route sufficient to permit individuals with visual
> disabilities to be oriented to their location.*
>
> *(2) The entity shall announce any stop on request of an individual
> with a disability.*
>
> *(c) Where vehicles or other conveyances for more than one route serve
> the same stop, the entity shall provide a means by which an individual
> with a visual impairment or other disability can identify the proper
> vehicle to enter or be identified to the vehicle operator as a person
> seeking to ride on a particular route.*

Planners Collaborative, Inc. of Boston, Massachusetts conducted the
review. David Chia served as the review team leader. Don Kidston and
Brian Barber assisted with the review.

The stop announcement and route identification fieldwork began Monday,
March 27, 2006, and continued on March 28. The opening conference took
place on Wednesday, March 29, 2006. The following individuals attended
the opening meeting:

> Ray Melleady Deputy Executive Director, CDTA
>
> Terrilia Henry IT Project Coordinator, CDTA
>
> David Chia Planners Collaborative
>
> Don Kidston Planners Collaborative
>
> Brian Barber Planners Collaborative

David Knight, ADA Team Leader, and Donna Walton, both from the FTA
Office of Civil Rights, participated in the opening conference via
telephone.

Mr. Knight opened the meeting by thanking CDTA for its assistance with
the review. He noted that the review team had been on site since Monday,
March 27. He explained that reviews of on-board stop announcements were
conducted by providing a general timeframe for the review, having the
team make initial observations, and then notifying the agency and
requesting an opening conference. This process was used to ensure that
the results of the observations of stop announcements would not be
skewed by the transit property knowing when the FTA review team was on
site.

Mr. Knight noted that FTA viewed the review not just as part of its
overall ADA compliance effort, but also as a chance to provide technical
assistance on ADA issues. He indicated that the review team was
available to answer any questions from CDTA staff, or to offer
suggestions on addressing any issues that CDTA might have.

Mr. Chia thanked Mr. Melleady in advance for the cooperation of his
staff over the next two days. He summarized the activities of the review
team for the previous two days. He then presented a proposed schedule of
meetings with CDTA staff for Wednesday and Thursday. Attachment A
presents a copy of the review team's on-site schedule.

During the remainder of March 29, team members met with various CDTA
managers to gather information about CDTA policies and procedures for
stop announcements and route identification. They gathered information
about the ongoing program to fully automate the stop announcements and
route identification. They also interviewed CDTA bus drivers.

On March 30, team members interviewed additional CDTA bus drivers. They
compiled the data from their field observations and prepared preliminary
findings for presentation at the exit conference.

The exit conference took place on Thursday, March 30, 2006, at 1 p.m.
Those present at the exit conference were:

> Stephen Bland Executive Director, CDTA
>
> Ray Melleady Deputy Executive Director, CDTA
>
> Terrilia Henry IT Project Coordinator, CDTA
>
> Gary Guy Superintendent of Field Operations, CDTA
>
> Thomas Guggisberg IT Director, CDTA
>
> Gary Cook Troy Superintendent, CDTA
>
> David Palmer Albany Superintendent, CDTA
>
> Stephanie Conroy Manager of Operations Systems, CDTA
>
> David Chia Planners Collaborative
>
> Don Kidston Planners Collaborative
>
> Brian Barber Planners Collaborative

Mr. Knight and Dr. Walton of FTA again participated via telephone. Mr.
Knight began the exit conference by thanking CDTA staff for their
cooperation and assistance with the review. He indicated that a draft
report would be prepared and forwarded to CDTA for review and comment.
CDTA's comments on the draft would then be incorporated into a final
report. Mr. Knight noted that once the report became a final document,
it would be subject to release in response to Freedom of Information Act
(FOIA) requests and available on FTA's website.

The review team then presented the preliminary findings and
recommendations from the on-site visit. Mr. Knight noted that CDTA will
need to respond to the findings once they are finalized. The
recommendations are offered as suggestions and will not require a
response. CDTA may, however, consider the recommendations in developing
responses to the findings.

Section 2 of this report provides a summary of the findings and
recommendations. Section 3 presents information on CDTA's efforts to
comply with the regulations, including written policies and procedures,
operator training, and its automated announcements project. Section 4
presents the review team's observations, analysis, and findings related
to on-board stop announcements. Section 5 includes the observations,
analysis, and findings regarding route identification efforts.

CDTA was provided a draft copy of the report for review and response. A
copy of the correspondence received from CDTA on December 18, 2006
documenting their response to the draft report, is included as
Attachment B.

The remainder of this section presents an overview of the transportation
services provided by CDTA, formal ADA complaints received by FTA
regarding CDTA stop announcement and route identification efforts, and
recent rider comments regarding the fixed route service.

## Overview of CDTA

The Capital District Transportation Authority (CDTA) was formed by an
act of the New York State legislature in 1970. The authority is a public
benefit organization with a legislative purpose "to provide for the
continuance, further development and improvement of transportation and
other services related thereto within the Capital District
Transportation Authority by railroad, omnibus, marine and air." The
primary activity of CDTA is operating the fixed route bus and ADA
complementary paratransit services in a four-county region of New York
(Albany, Rensselaer, Saratoga, and Schenectady).

CDTA has a nine-member board of directors, all selected by the state
governor. Three members represent Albany County, while two members each
represent the other three counties. The executive director is the
authority's chief executive officer.

Fixed route service operates on more than 50 bus routes providing a
combination of local and express service. Most routes operate within
Albany's 150-square-mile urbanized area. The fixed route fleet consists
of 250 buses. All buses have lifts or ramps. The entire four-county area
is 1,760 square miles and has a population of 750,000.

The administrative office and main garage are in Albany at 110
Watervliet Avenue. CDTA also has two other bus facilities: 2410 Maxon
Road in Schenectady; and 40 Hoosick Street in Troy.

Service is provided on all routes on weekdays. A limited set of routes
operate on Saturday and yet fewer routes operate on Sundays and
holidays. The earliest weekday service begins at 4:30 a.m. and the
latest service operates until 2:05 a.m. Service begins at 5 a.m. and
5:45 a.m., on Saturdays and Sundays, respectively. Late night service is
provided until 4:10 a.m. on one route on Friday and Saturday nights
(Saturday and Sunday mornings).

The base fare for the bus is \$1 per unlinked trip. There are no free or
discounted transfers. Multi-ride passes provide discounted fares. CDTA's
fiscal year 2006 operating budget is \$56 million.

According to CDTA, more than half of its ridership is concentrated on
its top six routes. An additional 25 percent of its ridership is carried
by its next top 10 routes. The average weekday ridership for the last
quarter of 2005 was 43,700.

## Formal Complaints

FTA received one written complaint concerning CDTA's fixed route
service. The complaint was filed by a rider in April 2004. However, the
complaint did not address stop announcements or route identification.

## Agency and Rider Comments

Prior to the review team's on-site visit, team members interviewed (by
telephone or e-mail) eight people who work for agencies that support
individuals who have visual impairments in the Albany area and/or people
who have visual impairments and ride CDTA fixed route buses. These
interviews provide anecdotal information about stop announcements on the
CDTA fixed route bus system. Agencies represented were:

-   Independent Living Services of New York State

-   Northeast Association for the Blind

-   New York State Commission for the Blind and Visually Handicapped

-   Disability Advocates, Inc.

-   Capital District Chapter of the American Council of the Blind

-   Capital District Center for Independent Living

During the interviews, these individuals referred to 13 CDTA bus routes
(1, 2, 4, 5, 6, 9, 10, 12, 13, 19, 22, 55, and 63).

The principal comment offered in the interviews was that the automated
stop announcement system did not work much of the time, and that drivers
did not give oral announcements when the automated system did not work.
Some respondents believed that the bus drivers turned off the automated
system because it announced only some stops. Most respondents said bus
drivers would agree to make stop announcements when asked to do so, but
even then drivers would sometimes forget, usually because they were
preoccupied with something else.

A second major comment was that drivers rarely announced their route but
would respond if asked by customers who were either on the bus or at
stops. They noted that drivers announced routes if they saw someone who
was recognizably visually impaired waiting for a bus. A related comment
by riders was that drivers often did not see people with visual
impairments at bus stops that were shared by several bus routes,
especially during peak traffic times. People with visual impairments
waiting for buses usually had to ask fellow sighted passengers the route
of the bus that had stopped.

Some respondents said they had filed complaints with CDTA and generally
did not get satisfactory replies. Most respondents said they rely on
advocacy groups to make complaints to CDTA.

# Summary of Findings

This section of the report summarizes the findings made based on this
review. The background discussions for these findings are addressed in
other sections of this report. The findings should be used as the basis
for any corrective actions proposed by CDTA. Recommendations are also
included in the report for CDTA's consideration in developing corrective
actions.

## Findings Regarding Efforts to Comply with Stop Announcements and Route Identification Requirements

1.  CDTA periodically reminds its drivers of the requirements to
    announce stops and to make external route identifications through
    Transportation Department Notices. The most recent notice was issued
    on October 4, 2004. Based on these notices, there appears to be
    greater emphasis on stop announcements than route identification.

2.  CDTA does not appear to emphasize route identification in its driver
    training or its identification of driver responsibilities.

3.  CDTA has in-house procedures and an outside contractor to monitor
    stop announcements. CDTA has been collecting the forms completed by
    its employees but has not analyzed the data. The secret riders
    employed by the contractor rarely observed the drivers making stop
    announcements or route identifications.

4.  CDTA has a progressive discipline program for drivers who violate
    CDTA policies or job requirements, including the announcement of
    stops and identification of routes. As of the time of the review
    team's visit, no CDTA driver had been suspended for not making stop
    announcements.

5.  At the time of the site visit, CDTA was implementing a mobile data
    communication system (MDCS). When fully implemented, this system
    will include automated stop announcements and route identification
    on all buses. The IT project coordinator and IT director have
    created inspection and reporting procedures for problems that arise
    with the MDCS. However, they had not received much information on
    problems from drivers, dispatchers, or supervisors.

6.  CDTA managers have noted vandalism on the speaker wires for the
    internal bus speakers. Based on the location of these wires, they
    believe that drivers may have cut the wires.

## Findings Regarding Stop Announcements

1.  In a two-day sample of 48 on-board observations covering 33 CDTA
    routes, the review team observed that the automated stop
    announcement system was operational 24 times (50 percent).

2.  For the 24 observations that the automated stop announcement system
    was not working, the review team observed one driver making one oral
    stop announcement. No other driver made any other stop announcement.

3.  The automated stop announcements were clear and audible in 23 of the
    24 observations. In the one exception, there was unusually loud
    background noise.

4.  All seven drivers that the review team interviewed said that they
    understood the requirements to make stop announcements and that they
    made the announcements when the automated system is not working.

5.  Departments within CDTA have compiled separate lists for stop
    announcements; each list is different. The stop lists used as input
    to the automated announcement system appear to be the least
    comprehensive in terms of complying with the ADA regulations.

6.  Team members noted that the automated system did not announce all
    transfer points. In addition, cross streets were used to identify
    most stops. Landmarks were rarely used to identify stops.

7.  Team members also observed uneven intervals in the announcement of
    stops. When the automated system was working, intervals between
    announcements ranged from one minute to 26 minutes. The average
    (mean) interval between stop announcements on route segments that
    had a working automated stop announcement system was over six
    minutes.

8.  The review team analyzed two sample CDTA bus routes to develop lists
    of bus stops for announcements. Based on this analysis, the bus stop
    lists developed by the CDTA operations department included most of
    the stops required for compliance with the ADA regulations. However,
    the bus stop list that CDTA uses as input to the automated
    announcement system excludes many of the stops required for
    compliance.

## Findings Regarding Route Identification

1.  The review team observed only one route announcement in 93
    observations.

2.  During interviews CDTA drivers indicated that they make route
    announcements only when needed, i.e., when they see a visually
    impaired person or a person who seems confused or lost.

3.  CDTA plans to have all buses equipped to make automated external
    route announcements. At the time of the site visit, however, this
    feature was not working on any CDTA bus.

# Efforts to Comply with Stop Announcements and Route Identification Requirements

#  {#section-1 .unnumbered}

This section of the report presents information about CDTA's efforts to
comply with the regulations to announce stops and to identify routes to
its fixed route bus service customers. This includes:

-   CDTA policies and procedures

-   CDTA driver training practices and written material

-   CDTA monitoring procedures

-   CDTA's ongoing automated stop announcements and route identification
    project

Prior to the site visit, the review team received written information
from CDTA on its policies and procedures for stop announcements and
route identification, as well as sample completed monitoring reports.
CDTA also provided excerpts from its driver training material. While on
site, team members interviewed several CDTA managers about training,
monitoring, and the implementation of the automated system. Team members
also reviewed additional information about the automated system.

## Policies and Procedures

CDTA's policies regarding stop announcements and route identification
are set forth in various notices from the director of transportation or
garage superintendents.

**Transportation Department Notices**

The most recent notice (dated October 4, 2004) was distributed by the
director of transit services to CDTA operators and supervisors. In part,
it stated:

> *OPERATORS ARE RESPONSIBLE FOR ANNOUNCING ALL MAJOR BUS STOPS AND
> TRANSFER POINTS.*
>
> *Operators are also responsible for announcing any additional stops
> requested by ANY PATRON*.

Prior to that notice, a notice dated November 27, 2002, from the Troy
superintendent to Troy operators emphasized the need to make stop
announcements:

> *[The Americans with Disabilit\[ies\] Act requires bus operators to
> announce all major bus stops, transfer points and any other stop
> requested by a passenger.]{.underline}*
>
> *This requirement is **[not]{.underline}** elective!!!*
>
> *Operators found not announcing stops, will be subject to disciplinary
> action.*

This notice also referred to the buses' public address system:

> *Further, operators are to check the PA system of the bus during the
> pre-trip inspection and write up disabled systems on the Operator
> Equipment Report.*
>
> *A faulty PA system, does not relieve the operator of the
> responsibility to make the required ADA announcements.*

In March 2000, CDTA's director of transportation issued a notice to all
operators and supervisors that stated, "[Operators at a minimum must
announce each time point on their paddle, and all major transfer
points]{.underline}." The notice provided a list of 10 stops that
drivers were to announce. In addition, drivers were required to announce
"all shopping malls" and "each terminus."

In 2002, there were notices from the Troy superintendent (June 21) and
the Albany superintendent (April 24) that, in addition to emphasizing
stop announcements, also referred to the need to identify routes to
waiting customers. The Troy notice stated, "In order to accommodate
visually impaired patrons who may be waiting for a bus, you must
announce the bus line you are operating upon arrival at the stop." (The
Albany notice had similar wording.) Previously, a notice dated January
15, 2001, from CDTA's director of transportation to all operators and
supervisors stated that the ADA "also **[requires]{.underline}** that an
operator announce any other bus stop at a customer's request and *at
these key stops announce the route number to customers waiting*"
\[Italics added\].

**Supervisory Manual**

CDTA has an internal "Supervisory Manual" for CDTA field supervisors. At
the time of the review team's site visit, the superintendent of field
operations was revising this manual. The manual includes a short
section, "ADA/Assisting Customers with Disabilities." This section
states, "ADA requires that drivers announce all major stops and transfer
points on their route, whether people are visually impaired or not." The
manual does not mention the need for drivers to identify their routes to
customers waiting at bus stops.

## Driver Training

A team member met with CDTA's director of training and staff development
to discuss how stop announcements and route identification are
incorporated into driver training. The director referred to several
documents sent to the review team prior to the site visit. They all
include instruction on various ADA requirements. Specific citations
regarding the announcement of stops include:

> *For CDTA bus operators, the ADA means several things:*
>
> *. . . Bus stops must be announced under certain circumstances*.
>
> *The ADA requires that operators make a **reasonable effort** to
> assist customers with special needs. This includes such things as:*
>
> *. . . Announcing major bus stops, transfer points, and individual
> stops at a customer's request*.
>
> *This requirement applies to all trips regardless of whether or not
> there is a disabled person on the bus.*
>
> *Paddles are marked to indicate stops that must be announced. Major
> transfer points that must be announced include, but are not limited
> to:*
>
> *State and Pearl*
>
> *Empire State Plaza (State Museum)*
>
> *Swan and Washington*
>
> *Lark and Washington*
>
> *Western / Madison and Allen*
>
> *Colonie Center*
>
> *Crossgates* \[Mall\]
>
> *Northway Mall*
>
> *State and Washington (Schenectady)*
>
> *State and Jay (Proctor's -- Schenectady)*
>
> *Hoosick Street* \[Troy\]
>
> *Fulton and Third* \[Troy\]
>
> *Fulton and Fourth* \[Troy\]

The director of training also said that when drivers are in training,
they must announce stops, whether or not the automated system in their
bus is working. This gives them practice in remembering which stops
should be called. She also noted that drivers will always need to know
how to announce stops, since a passenger can request an announcement for
any stop along the route.

Soon after drivers complete their training, road supervisors conduct
on-board observations of driver practices. The supervisors use a
checklist (see Attachment C) to record their observations, including
"Announced service stops as required and requested."

In 2005, all CDTA drivers had ADA refresher training. This included
instruction on making stop announcements.

The training director stated that drivers are also trained to identify
the route that they are driving when stopping at stops shared by
multiple routes. However, none of the training material refers to the
requirement to identify routes.

## Monitoring Procedures

CDTA uses its own supervisors to monitor stop announcements and route
identification. CDTA also has an ongoing contract with a private company
to monitor various aspects of driver performance, including stop
announcements and route identification.

**Staff Monitoring**

CDTA has three ongoing programs for monitoring driver performance by its
own managers:

-   On-board ride checks

-   Field observations

-   "Employees in Motion" on-board observations

The most frequent type of driver monitoring performed by CDTA is
ride-alongs by field supervisors. The goal set by the superintendent of
field operations is for each field supervisor to conduct five
ride-alongs per week, yielding a total of 50 per week systemwide. In
practice, the field supervisors have generally been performing 35 to 40
ride-alongs per week. A field supervisor boards a vehicle in revenue
service and rides for a portion of a one-way trip. The field supervisor
observes the driver performance and completes a "Quality of Service
Check Sheet" (see Attachment D) that covers a wide range of driver tasks
and responsibilities. One item in the ADA compliance section of the
check sheet deals with stop announcements:

-   *MDCS Annunciator working properly?*

    -   *If not, did Operator announce stops?*

    -   *If not, was annunciator disabled or turned down?*

    -   *If not, does the Driver Problem Report indicate the defect?*

If the supervisor observes any performance issues, he notes them on the
check sheet. After the run, the supervisor is required to meet with the
driver within 48 hours to discuss the driver's performance. The
supervisor may point out areas that need improvement, as well as areas
in which the driver excels. If the driver had particularly severe
performance issues or repeat issues, this may lead to one of the steps
in CDTA's "positive performance counseling" (discussed further in
Section 3.4).

Field supervisors also observe driver performance while on the road.
When a supervisor sees a positive action from an operator, or sees an
action that is unsafe, unprofessional, or against CDTA rules, the
supervisor is supposed to fill out a "TD-4" incident report (see
Attachment E). Included on the TD-4's list of potential incidents is
"ADA announcement."

According to CDTA instructions, the supervisor's first observation of a
negative action by a driver leads to a "verbal reminder." The second
observation of a negative action by the same driver (it could be the
same action or a different one) leads to a written reminder. A third
observation of a negative action by the same driver leads to a second
written reminder.

Data from TD-4 reports is also transferred to individual driver files.

The "Employees in Motion" program began in spring 2005. All CDTA office
staff are supposed to ride the bus (at least once per week) and complete
a questionnaire about their ride. Among the questions is, "Did the
operator announce any stops? Yes/No" (see Attachment F). As of the time
of the review team's visit, CDTA had been collecting the completed
questionnaires but had not transferred the responses into a database or
analyzed the results.

**Covert Observations**

CDTA has had an ongoing contract with John R. Probst Investigations,
Inc. of Loudonville, New York (north of Albany) to conduct covert
("secret rider") observations of CDTA bus service. The secret riders
ride 30 runs each month, staying on board from 10 to 30 minutes. For
some of these 30 runs, CDTA's superintendent of field operations
requests certain drivers that he wants the secret riders to observe. The
request is based on:

-   Customer complaints

-   Referrals from garage superintendents

-   Referrals from other CDTA managers

-   Judgment of the superintendent of field operations

The remaining runs that the secret riders observe are randomly selected
from runs assigned to other drivers. For each run, the secret rider
completes an "On-board Observation/Ride Check List." Attachment G
presents a sample completed checklist. The rider observations cover a
wide range of driver responsibilities and behavior. Included among these
are a set of "ADA compliance" items:

-   Number of required stops announced by operator

-   Route announced each time door opened (by operator or annunciator)

-   Number of customer-requested stops announced by operator

CDTA uses these secret rider observations to identify new concerns about
driver performance or to confirm problems with driver performance. In a
sample of completed reports reviewed by the review team, the secret
riders rarely observed the drivers making stop announcements or route
identifications.

## Driver Discipline

Based on both CDTA's in-house and covert monitoring, drivers are subject
to progressive discipline for repeated violations of CDTA policies or
job requirements. Driver discipline is primarily handled at the garage
division level (Albany, Schenectady, Troy) by a supervisor or division
superintendent. CDTA "positive performance counseling" has a series of
steps for repeated incidents. The first two are less formal: a "verbal
reminder" and a "written reminder." These may be potentially followed
by:

-   Written warning

-   One-day suspension

-   Five-day suspension and final warning

-   Employee termination

Certain "serious" offenses may lead to an immediate suspension. At the
time of the review team's site visit, failure to make stop announcements
or route identifications was not included in CDTA's list of serious
offenses for drivers. CDTA managers, however, said that they were
discussing elevating failure to make stop announcements to a serious
offense. The superintendent of field operations said that over the past
year CDTA was placing a "heightened emphasis" on discipline for stop
announcements.

CDTA provided a sample of discipline records to drivers concerning stop
announcements. At the Troy garage, the superintendent issued four verbal
reminders and two commendations based on covert observations during July
2005. At the Schenectady garage, the superintendent issued five written
warnings based on covert observations during October and November 2005.
CDTA provided more extensive information for drivers from the Albany
garage: individual work records ("TD-61" reports) for 32 drivers that
cover 2001 to 2005. These are all the Albany garage drivers who have
been cited for stop announcements. Included in these citations are five
verbal reminders, 18 written warnings, and four commendations.

At the time of the review team's visit, no CDTA driver had been
suspended for failure to make stop announcements.

## Automated Stop Announcement and Route Identification

At the time of the review, CDTA was implementing its mobile data
communication system (MDCS) project. The project consists of multiple
components, one of which is vehicle announcements. The overall project
began in 2003. It is scheduled for completion in late 2007.

CDTA's objective is to have automated stop and route identification
announcements that would comply with the requirements of the ADA
regulations on all CDTA routes. CDTA drivers would still be required to
announce any stops that are requested by passengers. In addition,
drivers would have to announce stops when the automated system was not
working.

**Vehicle Announcements Component**

All 198 CDTA transit coaches were equipped with the MDCS. The equipment
includes internal and external speakers, an internal variable message
sign, automated vehicle locator (AVL) with global positioning system
(GPS) and odometer input, and a mobile computer with INIT software,
which controls the system. The system uploads data from CDTA's
scheduling system, HASTUS, to identify the driver and driver routing and
to link the AVL information to the street network for each route. HASTUS
includes geo-coded location coordinates and route distance between all
CDTA bus stops. The system also uploads geo-coded, pre-recorded audio
stop and route announcements.

The AVL system takes a GPS reading from up to eight satellite signals
every 30 seconds. The AVL then computes the bus location from: the
coordinates provided by the most recent GPS reading; the odometer
distance traveled from those coordinates; and the route and distance
information input from HASTUS. If the GPS signal is unreliable, the AVL
continues to compute the vehicle location from the last reliable GPS
reading. As the bus approaches the coordinates for a bus stop, the INIT
system activates the stop announcement. Each unique stop announcement is
coded to the coordinates for each bus stop. The stop is announced three
times, both audibly and visually, as the bus approaches the stop. At the
stop, opening the door of the bus activates the audible route
announcement.

At the time of the review team's visit, CDTA was reviewing and revising
GPS coordinates for bus stops to correct data inconsistencies. This
effort was being undertaken in conjunction with a bus stop sign
replacement program. CDTA was also investigating anomalies in uploading
information from HASTUS to INIT. CDTA was also pursuing the linking of
odometer data to vehicle transmissions rather than speedometers.

CDTA is testing the entire system and is trying to address problems as
they are identified. CDTA has vendors on site to help with the testing,
repair, and installation on the coaches. The testing program is more
fully described below. The current schedule calls for completion of
installation in late 2007.

**Inspection of Automated Equipment**

At pullout, drivers enter their identification number and block into the
MDCS. The block, or driver's block of work, identifies the sequence of
routes the driver is scheduled to operate during the driver's work
shift. A driver is not able to test the system to determine whether or
not it is operational while still at the garage.

Field supervisors check a sample of buses at pullout. Supervisors
inspect from 0 to 50 buses per day, with an average of 35 to 40
inspections per day. This represents approximately 20 percent of the 265
scheduled weekday pullouts. The distribution of weekday vehicle pullouts
is presented in Table 3.1.

**Table 3.1 -- Weekday Pullo**uts by Garage

  --------------------- --------------- --------------- ------------------
  **Garage**            **AM**          **PM**          **TOTAL**

  Albany                88              40              128

  Schenectady           29              32              61

  Troy                  47              29              76

  **TOTAL**             **164**         **101**         **265**
  --------------------- --------------- --------------- ------------------

The field supervisors test the MDCS and record the results using a
"Service Performance Analysis Report: Garage/Layover Check" (see
Attachment H). In addition, supervisors conduct approximately 50 to 55
field operations and on-board checks each day. The results are reported
on CDTA's "Service Performance Analysis Report: On Board Check" (see
Attachment I) and "Quality of Service Check Sheet" (see Attachment D).
All reports are provided to the CDTA Information Technology (IT)
Department.

The radio supervisor can identify whether a driver has logged his or her
ID and block into the MDCS and whether or not the GPS is working. If the
driver is not logged in or the GPS is not working, the radio dispatcher
completes an "On-line Problem Report" (see Attachment J), which is also
provided to CDTA's IT department.

Finally, when drivers observe that the MDCS is not working properly,
they complete an "MDCS Driver Problem Report" (see Attachment K), which
is transmitted to the IT department and entered into a database.

CDTA provided detailed data for the period March 20 to March 29, 2006.
During this time, drivers reported 14 problems with the automated
announcements on 13 buses (7 percent of the coach fleet). As discussed
above, dispatcher reports do not contain information specific to
operation of the stop or route announcements. CDTA did not have data
available from supervisor observations.

**Repair Procedures**

All reported problems with the MDCS are logged by the Central
Communications night dispatcher. Logs are reviewed by the IT project
coordinator and the superintendent of field operations. Problems are
classified as either "field operations" or "technical" and are addressed
by IT project staff. Technical problems are further identified as
hardware or software. Hardware issues are addressed by INIT field staff.
Software interface or application problems are addressed by the IT
project coordinator, and software design problems are addressed by INIT
Technical Support.

**Current Issues**

The CDTA project managers believe that they have identified both
systemic hardware and software issues and are addressing them. Speaker
wires have been severed or vandalized. In response, the speakers were
being reinstalled to eliminate exposed wires. There have also been
problems with drivers turning the speaker volumes down, making them
inaudible to passengers. In response, CDTA removed volume controls from
the buses. As of March 22, 2006, these modifications had been completed
on 50 buses, or approximately a quarter of the fixed route fleet. During
the reinstallation of the 50 speakers, 10 of the gooseneck microphones
were identified as inoperable.

## Findings

1.  CDTA periodically reminds its drivers of the requirements to
    announce stops and to make external route identifications through
    Transportation Department Notices. The most recent notice was issued
    on October 4, 2004. Based on these notices, there appears to be
    greater emphasis on stop announcements than route identification.

2.  CDTA does not appear to emphasize route identification in its driver
    training or its identification of driver responsibilities.

3.  CDTA has in-house procedures and an outside contractor to monitor
    stop announcements. CDTA has been collecting the forms completed by
    its employees but has not analyzed the data. The secret riders
    employed by the contractor rarely observed the drivers making stop
    announcements or route identifications.

4.  CDTA has a progressive discipline program for drivers who violate
    CDTA policies or job requirements, including the announcement of
    stops and identification of routes. As of the time of the review
    team's visit, no CDTA driver had been suspended for not making stop
    announcements.

5.  At the time of the site visit, CDTA was implementing a mobile data
    communication system (MDCS). When fully implemented, this system
    will include automated stop announcements and route identification
    on all buses. The IT project coordinator and IT director have
    created inspection and reporting procedures for problems that arise
    with the MDCS. However, they had not received much information on
    problems from drivers, dispatchers, or supervisors.

6.  CDTA managers have noted vandalism on the speaker wires for the
    internal bus speakers. Based on the location of these wires, they
    believe that drivers may have cut the wires.

#  {#section-2 .unnumbered}

## Recommendations

1.  CDTA should reinforce to drivers during initial and refresher
    training the importance of making stop announcements and route
    identifications. It should consider having passengers with visual
    disabilities participate in the training if they are not already
    included in the training program.

2.  CDTA should more actively monitor its drivers in stop announcements
    and route identification. It should make better use of its existing
    in-house monitoring programs and analyze the data that it collects.

3.  CDTA should consider more aggressive discipline of its drivers for
    failing to announce stops or make route identifications.

# Review of On-Board Stop Announcements

This section of the report focuses on CDTA's performance in making stop
announcements. Included in this section are:

-   Description of the regulatory requirements related to on-board stop
    announcements

-   Summary of consumer comments from telephone interviews

-   Summary of driver comments from interviews with team members

-   Description of the review team's method for observing on-board stop
    announcements

-   Summary of information collected and observations of stop
    announcement efforts

-   Analysis of stops selected for announcements

## Regulatory Requirements

Section 37.167(b) of the U.S. Department of Transportation regulations
implementing the ADA contains the following requirement related to the
announcement of stops on fixed route systems operated by public or
private entities:

> *(b) On fixed route systems, the entity shall announce stops as
> follows:*
>
> *(1) The entity shall announce at least transfer points with other
> fixed routes, other major intersections and destination points, and
> intervals along a route sufficient to permit individuals with visual
> disabilities to be oriented to their location.*
>
> *(2) The entity shall announce any stop on request of an individual
> with a disability.*

## Consumer Comments

As noted in Section 2 of this report, FTA did not receive any written
complaints concerning CDTA's stop announcements. However, consumers and
advocacy groups interviewed by the review team prior to the on-site
visit had several concerns about the stop announcements made by CDTA
drivers. Many of the individuals interviewed believed that the automated
stop announcement system often did not work and that drivers did not
make oral announcements when the automated system was not functioning.
They also said that bus drivers would agree to make stop announcements
when asked to do so, but even then drivers would sometimes forget,
usually because they were preoccupied with something else.

## Bus Operator Interviews

The review team interviewed seven CDTA drivers. The primary purpose of
the interviews was to assess drivers' understanding of the requirements
to announce stops and identify routes. In addition, the drivers provided
their perspective on the effectiveness of the automated stop
announcement system. Attachment L lists the questions posed by team
members during the interviews.

On average, the operators interviewed by the team had 16 years'
experience driving for CDTA. All drivers said they understood how to
make stop announcements. They all said that they made a stop
announcement when asked to do so by a rider.

All drivers recognized that they have automated stop announcement
systems on board. They all noted that the on-board automated stop
announcement system works sporadically, although they said the system
worked most of the time. They all said they make oral stop announcements
when the automated system is not working. Most said they use the public
address (PA) system to make oral announcements if it was working. Some
said the PA system did not work most of the time.

Most drivers said they check the PA system before they take their bus
into passenger service. If the PA system was not working, some drivers
said they report it to maintenance in the routine reporting system.

All drivers mentioned that they only know if the automated stop
announcement system is working after they leave the garage in the
morning. There is no way for drivers to test the announcement system
before they pull out. Only one of the drivers said he knew how to
restart or "re-boot" the announcement system if it stopped working. That
driver was not a full-time driver but did trouble-shooting on all
aspects of CDTA bus services when he was not driving. He was trained in
how to restart the automated stop announcement system for his
trouble-shooting duties.

## Review Team Observations

On Monday, March 27, and Tuesday, March 28, the three review team
members rode buses throughout the CDTA service area. While on the buses,
they observed and made note of stop announcements. The purpose of these
observations was to determine whether stop announcements were being made
at transfer points, major intersections, and destinations, and at
intervals sufficient for individuals with visual impairments to orient
themselves. Team members also noted the method and clarity of the
announcements. Team members positioned themselves at mid-bus to make
observations and recorded the results on a form (see Attachment M).

On Monday, the review team made on-board observations from 7:18 a.m.
until 6:40 p.m. On Tuesday, observations were made from 7:51 a.m. until
12:12 p.m. Individual observations ranged in duration from 6 minutes to
68 minutes, with an average (mean) observation of 25 minutes. During
this period, team members were on vehicles for more than 20 hours and
made observations of 48 route segments. Four pairs of the 48
observations were covered the same vehicle and route. This occurred when
a team member rode the same bus in both directions on a route.

Two observations were for a vehicle that had been previously observed.
The driver's identification number was not recorded for all of these
observations; however, for both duplicate bus observations, the
observations occurred on different routes and at different times of the
day. The automated system for one bus (#2063) was operational during one
observation but not operating during the other.

The variable message signs (VMS) located near the driver were
operational and identified upcoming stops in 31 (65 percent) of the
observations. In general, the VMS appeared to accurately identify stop
locations. The stop message appeared three times as the bus approached a
stop. In several instances, the third time that the stop name appeared
was just after the bus passed the stop.

During the two days of on-board observation, team members recorded a
total of one driver making one oral stop announcement.

The automated audio stop announcements were working on 24 (50 percent)
of the team members' observations. In one of those observations, the
stop announcements were not audible. In the remaining 24 instances, the
announcements seemed clear and audible without being loud or obtrusive.
The only exception to the audibility was caused by unusually loud
background noise, such as caused by buses rattling over rough road
sections. Table 4.1 summarizes key data compiled from the on-board stop
announcement observations.

**Table 4.1 -- On-Board Observations for Stop Announcements**

+--------------------------------------+----------+---------+---------+
|                                      | **       |         | **Dur   |
|                                      | Number** |         | ation** |
|                                      |          |         |         |
|                                      |          |         | **(hr   |
|                                      |          |         | :min)** |
+--------------------------------------+----------+---------+---------+
| **Total Observations**               | 48       | 100 %   | 20:03   |
+--------------------------------------+----------+---------+---------+
| **Different Routes Covered**         | 33       |         |         |
+--------------------------------------+----------+---------+---------+
| **VMS/GPS Operating**                | 31       | 65 %    | 12:17   |
+--------------------------------------+----------+---------+---------+
| **Audio Operating**                  | 24       | 50 %    | 10:11   |
+--------------------------------------+----------+---------+---------+
| **Total Automated Stop               | 95       |         |         |
| Announcements**                      |          |         |         |
+--------------------------------------+----------+---------+---------+
| **Driver's Stop Announcements**      | 1        |         |         |
+--------------------------------------+----------+---------+---------+

Attachment N provides more detailed data for each observation.

## Selection of Stops for Announcing

The regulatory requirement for identifying which stops to announce
provides some flexibility to the transit system in directing its drivers
and in the development of stop lists for automated stop announcements.
The requirement to announce transfer points implies that the stops where
any two routes converge or diverge must be announced. According to the
Interpretation of the regulation (Appendix D to 49 CFR Part 37),
announcements must be made at transfer points to other fixed routes or
modes of transit service. For the CDTA service area, this includes, at
minimum, intercity bus terminals and Amtrak stations. The requirement to
announce "any stops on request of an individual with a disability" is
also straightforward and applies to any stop beyond those that may be on
CDTA's designated lists.

The other requirement is to announce "other major intersection and
destination points, and intervals along the route sufficient to permit
individuals with visual impairments or other disabilities to be oriented
to their location." This allows CDTA (and its drivers) to use judgment
in selecting the specific stops to announce and the frequency of the
announcements.

For each route, CDTA has compiled bus stop lists for stop announcements.

-   For the MDCS project, there is a list of stops for each route (and
    each route variation). According to the IT project coordinator,
    these stop lists come from CDTA Business Development. A unique set
    of these stops for the entire CDTA system (i.e., one record
    regardless of how many routes share a stop, and one record for both
    sides of the street for a common intersection/destination) is
    included in an electronic file ("playlist_4_08_04") used to generate
    the visual and audio announcements for the automated system.

-   CDTA operations has developed a stop list for each route. These
    lists are for use by the drivers when the automated announcement
    system is not working. According to the CDTA director of training,
    when CDTA trains drivers, the drivers practice calling out stops
    from these lists.

-   CDTA provided the review team with bus stop lists for bus routes in
    the Schenectady division. These were last updated in May 2005.
    \[*These lists may be a subset of the lists from CDTA operations*.\]

-   CDTA lists timepoints on its public bus schedules that can serve as
    partial stop lists for each bus route.

When the review team was conducting its on-board observations, the data
forms were pre-printed with the bus schedule timepoints, along with the
bus stops for the Schenectady division bus routes. As the automated
system made additional announcements, team members added these stops to
the data forms.

Team members noted that the automated system did not announce all
transfer points. In addition, cross streets were used to identify most
stops. For purposes of orienting riders, it would be helpful to include
in stop announcements the names of major destinations, such as
government buildings and complexes, hospitals, museums, and arenas.

The team members observed uneven intervals in the announcement of stops.
Intervals between announcements ranged from 1 minute to 26 minutes. The
average (mean) interval between stop announcements on route segments
that had a working automated stop announcement system was over 6
minutes. In some instances, stops were announced frequently along one
segment of a route and not at all for other segments of the same route.
For example, bus route #22 travels between downtown Albany and downtown
Troy, with a scheduled trip time of 35 minutes. Often no announcements
were made along route segments in which the route made multiple turns.
As a result, it would be difficult for individuals with visual
impairments to identify their location. During one team member's
observation of this route, after a stop announcement in downtown Albany
(Broadway and Orange), the bus traveled over 20 minutes before the
subsequent stop announcement---at the second to last stop in Troy
(Congress and Fourth).

The review team analyzed two sample CDTA bus routes. The team then
developed suggested alternate lists of bus stops for announcements.
Table 4.2 presents the review team's alternate stop list for CDTA's
Route #24 northbound from downtown Albany to Troy. Table 4.3 presents
the review team's alternate stop list for Route #24 in the return
direction. The stops on these lists fit at least one of the following
criteria, which correspond to the requirements for stop announcements in
49 CFR §37.167(b):

-   Transfer point with another bus route or transportation mode

-   Terminal point

-   Major destination

-   Direction change (turn) of route

**Table 4.2 -- List for Stop Announcements** for CDTA Route #24
Northbound

  ------------------------- ---------------------------------------------------------------------------------------- --------- ---------
  **Stop**                  **Connecting with Route(s)**                                                             **O\***   **A\^**

  South Swan and Washington 1,2,4,5,7,9,10,11,12,13,14,15,16,18,19,21,22,29,30,31,33,35,40,41,42,43,48,49,55,57,63   Yes       No

  Pearl and State           1,2,4,5,7,9,10,11,12,13,14,15,16,18,19,21,22,29,30,31,35,40,41,42,43,48,49,55,57,63      Yes       No

  Rensselaer (Amtrak) Rail  14,15,49                                                                                 Yes       Yes
  Station                                                                                                                      

  Adams and 3rd             14,15,49                                                                                 Yes       No

  Yankee Trails and 3rd     No other routes but it is a direction change                                             Yes       No
  Ave. Extension                                                                                                               

  Rensselaer County Plaza   No other routes but it is a direction change                                             Yes       No
  and 3rd Ave. Extension                                                                                                       

  D'Ville Park and Ride Lot 14,15,25,29                                                                              Yes       Yes

  Hudson Valley Community   48,85                                                                                    Yes       Yes
  College                                                                                                                      

  Burden and Cross          85                                                                                       Yes       No

  Congress and 4th, Troy    22,35,70,80,82,84,85,89,90,96                                                            Yes       No

  Fulton and 4th, Troy      22,35,44,70,80,82,84,85,86,87,89,90,96                                                   Yes       Yes
  ------------------------- ---------------------------------------------------------------------------------------- --------- ---------

\* Stop on CDTA operations list

\^ Stop on CDTA automated system list

Along with the connecting routes, the tables identify whether each stop
is included on the list for the automated announcement system and/or the
list developed by CDTA operations. As summarized in Table 4.4, the stop
list for the automated system includes fewer than half of the stops that
meet one of the criteria. The list from CDTA operations includes most of
the stops in Tables 4.2 and 4.3.

**Table 4.3 -- List for Stop Announcements for CDTA Route #24
Sout**hbound

  ------------------------- --------------------------------------------------------------------------------- --------- ---------
  **Stop**                  **Connecting with Route(s)**                                                      **O\***   **A\^**

  Congress and 3rd          22,35,70,80,84,85,89,90,96                                                        Yes       No

  Morrison and Vandenburg   No other routes but it is a direction change                                      Yes       No

  Hudson Valley Community   25,44,85                                                                          Yes       Yes
  College                                                                                                               

  D'Ville Park and Ride Lot 14,15,25,29                                                                       Yes       Yes

  Rensselaer County Plaza   No other routes but it is a direction change                                      Yes       No
  and 3rd Ave. Extension                                                                                                

  Yankee Trails and 3rd     No other routes but it is a direction change                                      Yes       No
  Ave. Extension                                                                                                        

  Herrick and East          14,15,49                                                                          Yes       No

  Rensselaer (Amtrak) Rail  14,15,49                                                                          Yes       Yes
  Station                                                                                                               

  Market Street at Pepsi    15,33                                                                             Yes       Yes
  Arena                                                                                                                 

  Empire State Plaza and    3,11,14,15,16,19,21,22,30,33,35,48,57                                             Yes       No
  Madison                                                                                                               

  Hudson and Broadway       1,2,5,7,10,11,12,13,14,15,18,19,21,22,29,30,31,33,35,40,41,42,43,48,49,55,57,63   No        Yes

  Greyhound Station         1,2,10,12,13,14,22,55                                                             No        Yes
  ------------------------- --------------------------------------------------------------------------------- --------- ---------

\* Stop on CDTA operations list

\^ Stop on CDTA automated system list

**Table 4.4 -- Comparison of Stop Announcement Lists for Route #24**

  ---------------- ------------------- ------------------ ------------------
                   **Number of Stops**                    

                   **Suggested List**  **Automated System **CDTA Operations
                                       List**             List**

  **Northbound**   11                  4                  11

  **Southbound**   12                  6                  10
  ---------------- ------------------- ------------------ ------------------

Attachment O provides the same analysis for CDTA's Route #1 (downtown
Albany to Colonie Center Mall). For Route #1 westbound (from Albany to
the Colonie Center Mall), of the 12 stops that meet the criteria listed
above, the CDTA operations list includes all 12, while the automated
system list includes only three. For Route #1 eastbound (Colonie Center
Mall to downtown Albany), of the 15 stops that meet the criteria listed
above, the CDTA operations list includes 14, while the automated list
includes only six.

## 4.6 Findings {#findings-1 .unnumbered}

1.  In a two-day sample of 48 on-board observations covering 33 CDTA
    routes, the review team observed that the automated stop
    announcement system was operational 24 times (50 percent).

2.  For the 24 observations that the automated stop announcement system
    was not working, the review team observed one driver making one oral
    stop announcement. No other driver made any other stop announcement.

3.  The automated stop announcements were clear and audible in 23 of the
    24 observations. In the one exception, there was unusually loud
    background noise.

4.  All seven drivers that the review team interviewed said that they
    understood the requirements to make stop announcements and that they
    made the announcements when the automated system is not working.

5.  Departments within CDTA have compiled separate lists for stop
    announcements; each list is different. The stop lists used as input
    to the automated announcement system appear to be the least
    comprehensive in terms of complying with the ADA regulations.

6.  Team members noted that the automated system did not announce all
    transfer points. In addition, cross streets were used to identify
    most stops. Landmarks were rarely used to identify stops.

7.  Team members also observed uneven intervals in the announcement of
    stops. When the automated system was working, intervals between
    announcements ranged from one minute to 26 minutes. The average
    (mean) interval between stop announcements on route segments that
    had a working automated stop announcement system was over six
    minutes.

8.  The review team analyzed two sample CDTA bus routes to develop lists
    of bus stops for announcements. Based on this analysis, the bus stop
    lists developed by the CDTA operations department included most of
    the stops required for compliance with the ADA regulations. However,
    the bus stop lists that CDTA use as input to the automated
    announcement system excludes many of the stops required for
    compliance.

## 4.7 Recommendations {#recommendations-1 .unnumbered}

1.  CDTA should develop one list of stops to be announced by drivers and
    incorporated into the automated stop announcement system. For each
    route, the list of stops to be announced should include all transfer
    points, major destinations, terminal points, and changes in route
    direction. Also, taken as a whole, the stops to be announced should
    be sufficient to orient a passenger with a vision or cognitive
    disability.

2.  As discussed in Section 3 of this report, through training,
    monitoring and discipline, CDTA should reinforce the need for
    drivers to announce stops at transfer points, major destinations,
    and changes of direction, and stops that passengers specifically
    request, regardless of the status of the automated announcement
    system.

3.  CDTA should continue implementation of its automated stop
    announcement system with associated improvements as identified in
    the findings.

# Review of Vehicle/Route Identification

This section of the report focuses on CDTA's efforts in implementing the
vehicle/route identification requirement. Included in this section are:

-   Description of the regulatory requirements related to vehicle/route
    identification

-   Summary of consumer comments from telephone interviews

-   Summary of driver comments from interviews with team members

-   Description of the review team's method for reviewing route
    identification efforts

-   Summary of information collected and observations regarding route
    identification

## Regulatory Requirements

Section 37.167(c) of the U.S. Department of Transportation regulations
implementing the ADA contains the following requirement related to the
identification of fixed route services:

*Where vehicles or other conveyances for more than one route serve the
same stop, the entity shall provide a means by which an individual with
a visual impairment or other disability can identify the proper vehicle
to enter or be identified to the vehicle operator as a person seeking a
ride on a particular route.*

## Consumer Comments

There were no FTA formal complaints concerning external route
announcements.

In the telephone interviews, no concerns were raised regarding the
external route announcements. In its review of rider complaints on file
at CDTA, the review team observed no complaints related to external
route announcements.

## Bus Operator Interviews

As discussed in Section 4 of this report, the review team interviewed
seven CDTA drivers. Most drivers said they make external route
announcements only when they thought that the announcements were needed,
i.e., when they see a visually impaired person or a person who seems
confused or lost.

Most drivers said the training and training updates they received for
all aspects of their duties were adequate but that stop and route
announcements are not stressed in the training.

## Review Team Observations

##  {#section-3 .unnumbered}

On Monday, March 27, and Tuesday, March 28, the three review team
members made observations at major bus stops shared by more than one
route to assess CDTA's performance in identifying bus routes to waiting
passengers. Because the ADA regulations require route identification
only at stops served by more than one bus route, the best opportunity to
observe route identification was at stops served by numerous routes with
frequent service. These bus stops included:

-   State and Lodge, Albany (outbound)

-   South Pearl and State, Albany

-   Washington and Dove, Albany

-   State and Washington, Schenectady

Many of these observations took place during the morning and afternoon
peaks of March 27 and the morning peak of March 28. In addition, team
members noted whether there were route identification announcements when
they boarded buses during the two days.

As part of its MDCS project, all CDTA buses will be equipped to make
automated external route identification announcements. However, at the
time of the review team's site visit, this feature was not working on
any CDTA bus. The IT project manager said that there were wiring
problems on some buses that caused the announcements to be made inside
the buses but not outside. CDTA was planning to correct the wiring
problem and have the automated route announcements operational later in
2006. CDTA managers understood that the drivers were responsible for
making these announcements in the meantime.

The review team recorded a total of 93 observations of buses stopping at
stops shared by more than one route. They observed one external route
announcement. In this instance, a driver noticed a blind customer who
was using a cane waiting at a bus stop. That driver announced his bus
route to that customer as she boarded the bus.

Attachment P presents detailed data for each observation.

## Findings

1.  The review team observed only one route announcement in 93
    observations.

2.  During interviews CDTA drivers indicated that they make route
    announcements only when needed, i.e., when they see a visually
    impaired person or a person who seems confused or lost.

3.  CDTA plans to have all buses equipped to make automated external
    route announcements. At the time of the site visit, however, this
    feature was not working on any CDTA bus.

## 5.6 Recommendations {#recommendations-2 .unnumbered}

1.  CDTA should immediately direct its operators to make external route
    announcements at shared stops on all its bus routes.

2.  As discussed in Section 3, CDTA should emphasize the requirements
    for route identification by operators at all stops served by more
    than one route, in its operator training, monitoring, and discipline
    programs. Training should emphasize the need for drivers to make
    route announcements at any time that the automated system is not
    operating.

3.  CDTA should continue to expeditiously advance the implementation of
    its program for automated route announcements.

**Attachment A**

**On-Site Review Schedule**

**Review of ADA Stop Announcements**

**Capital District Transportation Authority (CDTA), Albany, NY**

**March 27--30, 2006**

On-Site Schedule

+--------+--------------------------------------+---------+-----------+
| **     | **Activity**                         | **Who** | **Where** |
| Time** |                                      |         |           |
+--------+--------------------------------------+---------+-----------+
| **M    |                                      |         |           |
| onday, |                                      |         |           |
| March  |                                      |         |           |
| 27,    |                                      |         |           |
| 2006** |                                      |         |           |
+--------+--------------------------------------+---------+-----------+
| All    | -   Ride selected routes and record  | All     | CDTA      |
| Day    |     stop announcements               |         | buses and |
|        |                                      |         | stops     |
|        | -   Check for route announcements at |         |           |
|        |     transfer points                  |         |           |
+--------+--------------------------------------+---------+-----------+
| **Tu   |                                      |         |           |
| esday, |                                      |         |           |
| March  |                                      |         |           |
| 28,    |                                      |         |           |
| 2006** |                                      |         |           |
+--------+--------------------------------------+---------+-----------+
| All    | -   Check for route announcements at | Barber  | CDTA      |
| Day    |     transfer points                  |         | buses and |
|        |                                      |         | stops     |
+--------+--------------------------------------+---------+-----------+
| M      | -   Ride selected routes and record  | All     | CDTA      |
| orning |     stop announcements               |         | buses and |
|        |                                      | Chia    | stops     |
|        | -   Call CDTA (Ray Melleady) to      |         |           |
|        |     arrange meetings on Wednesday    |         |           |
|        |     and Thursday                     |         |           |
+--------+--------------------------------------+---------+-----------+
| Aft    | -   Begin to tabulate data           | All     |           |
| ernoon |                                      |         |           |
+--------+--------------------------------------+---------+-----------+
| **Wedn |                                      |         |           |
| esday, |                                      |         |           |
| March  |                                      |         |           |
| 29,    |                                      |         |           |
| 2006** |                                      |         |           |
+--------+--------------------------------------+---------+-----------+
| 9:00   | -   Meet with deputy executive       | All     | 110       |
| AM     |     director of operations           |         | W         |
|        |                                      |         | atervliet |
|        |                                      |         | Ave.      |
+--------+--------------------------------------+---------+-----------+
| 9:30   | -   Review policies and procedures   | All     | 110       |
| AM     |     for stop announcements and route |         | W         |
|        |     identification                   |         | atervliet |
|        |                                      |         | Ave.      |
|        | -   Review CDTA practices for        |         |           |
|        |     monitoring driver practices      |         |           |
+--------+--------------------------------------+---------+-----------+
| 10:30  | -   Meet with IT project manager,    | All     |           |
| AM     |     director of training, manager of |         |           |
|        |     operations systems               |         |           |
+--------+--------------------------------------+---------+-----------+
| Aft    | -   Conduct driver interviews        | K       |           |
| ernoon |                                      | idston, |           |
|        | -   Meet with field operations and   | Barber  |           |
|        |     garage superintendents           |         |           |
|        |                                      | All     |           |
+--------+--------------------------------------+---------+-----------+
| **Thu  |                                      |         |           |
| rsday, |                                      |         |           |
| March  |                                      |         |           |
| 30,    |                                      |         |           |
| 2006** |                                      |         |           |
+--------+--------------------------------------+---------+-----------+
| M      | -   Conduct additional driver        | All     | 110       |
| orning |     interviews                       |         | W         |
|        |                                      |         | atervliet |
|        | -   Team meeting to tabulate         |         | Ave.      |
|        |     observations and prepare for     |         |           |
|        |     exit conference                  |         |           |
+--------+--------------------------------------+---------+-----------+
| 1:00   | -   Exit Conference                  | All     |           |
| PM     |                                      |         |           |
+--------+--------------------------------------+---------+-----------+

**Attachment B**

**CDTA Response to Draft Report**

**Attachment C**

**Customer Service Checklist**

**Attachment D**

**Quality of Service Check Sheet**

**Attachment E**

**TD-4 Incident Report**

**Attachment F**

**On-Board Ride Questionnaire**

**Attachment G**

**On-Board Observation/Ride Check List**

**Attachment H**

**Service Performance Analysis Report:**

**Garage/Layover Check**

Attachment I

**Service Performance Analysis Report:\
On-Board Check**

**Attachment J**

**On-Line Problem Report**

**Attachment K**

**MDCS Driver Problem Report**

**Attachment L**

**Fixed Route Driver Interview Form**

**[Fixed Route Driver Interview Form]{.underline}**

Agency: [Capital District Transportation Authority]{.underline}

Driver Name
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Date and Place of Interview
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Reviewer
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

1\. How long have you been a bus operator?

2\. When do you make on-board stop announcements?

3\. What do you do if a passenger asks you to announce a stop?

4\. Do you drive buses that have automated stop announcement systems?
How often

In your experience, does the automated stop announcement system
typically work?

What do you do if the stop announcement system is not working?

5\. Do you use the PA system to make on-board stop announcements? How
often?

In your experience, does the PA system typically work?

What do you do if the PA is not working?

5\. Do you use the PA system to make on-board stop announcements? How
often?

In your experience, does the PA system typically work?

What do you do if the PA is not working?

6\. Do you check at the beginning of each shift to see if the PA is
working?

7\. Do you feel that you have all the information and training that you
need to make the proper on-board stop announcements? Is there anything
that would help you?

8\. Are there any other issues about making on-board stop announcements?

9\. Do you drive buses that make automated external bus route
announcements? How often?

In your experience, does the external route announcement system
typically work?

What do you do if the bus route announcement system is not working?

10\. Do you feel that you have all the information and training that you
need to make the proper on-board stop announcements? Is there anything
that would help you?

**Attachment M**

**On-Board Fixed Route Stop Announcement**

**Assessment Form**

**(sample for Route #3 North)**

On-Board Fixed Route Stop Announcements Assessment Form

Transit System Name: [CDTA: Albany, NY]{.underline} Date:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Route #/Line Name: #3 Quail Street NORTH\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Bus or Car #\_\_\_\_\_\_\_\_\_\_\_\_\_

Boarded at: Disembarked at:

Location: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Location: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Time: \_\_\_\_\_\_\_\_\_\_\_\_\_ AM / PM Time:
\_\_\_\_\_\_\_\_\_\_\_\_\_ AM / PM

+------------------------+-----+------+----+-----+-----+---+---+-----+
| Indicate below the     | *   |      |    | *   |     | * |   |     |
| stops that should be   | *In |      |    | *On |     | * |   |     |
| announced (transfer    | dic |      |    | -bo |     | E |   |     |
| points, major          | ate |      |    | ard |     | x |   |     |
| intersections, major   | Lo  |      |    | Ann |     | t |   |     |
| destinations).         | cat |      |    | oun |     | e |   |     |
|                        | ion |      |    | cem |     | r |   |     |
| **Source:** *bus       | Typ |      |    | ent |     | n |   |     |
| scheds, CDTA memos*    | e** |      |    | M   |     | a |   |     |
|                        |     |      |    | ade |     | l |   |     |
|                        |     |      |    | ?** |     | I |   |     |
|                        |     |      |    |     |     | D |   |     |
|                        |     |      |    |     |     | * |   |     |
|                        |     |      |    |     |     | * |   |     |
|                        |     |      |    |     |     |   |   |     |
|                        |     |      |    |     |     | * |   |     |
|                        |     |      |    |     |     | * |   |     |
|                        |     |      |    |     |     | A |   |     |
|                        |     |      |    |     |     | n |   |     |
|                        |     |      |    |     |     | n |   |     |
|                        |     |      |    |     |     | o |   |     |
|                        |     |      |    |     |     | u |   |     |
|                        |     |      |    |     |     | n |   |     |
|                        |     |      |    |     |     | c |   |     |
|                        |     |      |    |     |     | e |   |     |
|                        |     |      |    |     |     | m |   |     |
|                        |     |      |    |     |     | e |   |     |
|                        |     |      |    |     |     | n |   |     |
|                        |     |      |    |     |     | t |   |     |
|                        |     |      |    |     |     | M |   |     |
|                        |     |      |    |     |     | a |   |     |
|                        |     |      |    |     |     | d |   |     |
|                        |     |      |    |     |     | e |   |     |
|                        |     |      |    |     |     | ? |   |     |
|                        |     |      |    |     |     | * |   |     |
|                        |     |      |    |     |     | * |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
| **Location**           | *   | *    | ** | *   | **N | * | * | *   |
|                        | *Tr | *Int | De | *Ye | o** | * | * | *N/ |
|                        | ans | erse | st | s** |     | Y | N | A** |
|                        | f** | ct** | ** |     |     | e | o |     |
|                        |     |      |    |     |     | s | * |     |
|                        |     |      |    |     |     | * | * |     |
|                        |     |      |    |     |     | * |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
| Quail & Central        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
|                        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
|                        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
| Ten Eyck Plaza         |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
|                        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
|                        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
| State & Eagle          |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
|                        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
|                        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
| Madison & Eagle        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
|                        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
|                        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
| Quail & Madison        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
|                        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
|                        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
| Quail & Central        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
|                        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
|                        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+
|                        |     |      |    |     |     |   |   |     |
+------------------------+-----+------+----+-----+-----+---+---+-----+

Note: If announcements are made, how? using the PA system, by voice, or
by automated system:

\_\_\_\_\_PA \_\_\_\_\_Voice \_\_\_\_\_Auto

Announcements Clear/Audible? \_\_\_\_\_Yes \_\_\_\_\_No
\_\_\_\_\_Sometimes

Were other stops/locations called? \_\_\_\_\_Yes \_\_\_\_\_No

Notes:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Signature and Name:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

**Attachment N**

**On-Board Stop Announcement Data**

**Attachment O**

**Suggested Stop List for Announcement for CDTA Route #1**

**Table O.1 -- List for Stop Announcements for CDTA Route #1 West**bound

  ------------------------- ----------------------------------------------- --------- ---------
  **Stop**                  **Connecting with Route(s)**                    **O\***   **A\^**

  Greyhound Station         2,5,7,13,18,29,30,31,55                         Yes       Yes

  State and James           2,4,5,13,16,18,22,29,30,31,49,55,63             Yes       No

  State and Lodge (Crown    2,3,4,5,9,10,12,13,16,18,22,29,30,31,49,55,63   Yes       No
  Plaza)                                                                              

  State and Eagle           2,4,5,9,10,11,12,13,14,15,16,18,19,21,22,24,    Yes       No
                            29,31,33,35,40,41,42,43,48,49,55,57,63                    

  Washington at Capitol     2,4,5,9,10,12,13,17,18,29,31,49,55,63           Yes       No
  (Hawk)                                                                              

  Washington and Swan       2,4,5,9,10,12,13,18,29,31,49,55,63              Yes       No

  Washington and Lark       2,4,5,9,10,11,12,29,31,49,55                    Yes       Yes

  Central and Henry         2,9,10,11,12,49,55                              Yes       No
  Johnston Blvd.                                                                      

  Central and Lexington     2,55                                            Yes       No
  Avenue                                                                              

  Central and Quail         2,55                                            Yes       No

  Central and Osborne Road  55                                              Yes       No

  Central at Colonie Center 2,26,55,90,95                                   Yes       Yes
  ------------------------- ----------------------------------------------- --------- ---------

\* Stop on CDTA operations list

\^ Stop on CDTA automated system list

**Table O.2 -- List for Stop Announcements for CDTA Route #1 East**bound

  ------------------------ ----------------------------------------------------------------------------------------- --------- ---------
  **Stop**                 **Connecting with Route(s)**                                                              **O\***   **A\^**

  Central at Colonie       2,26,55,90,95                                                                             Yes       Yes
  Center                                                                                                                       

  Central at Northway Mall No connecting routes but is a major destination and change of direction for the bus       No        Yes

  Central and Osborne Road 55                                                                                        Yes       No

  Central and Allen        13,55                                                                                     Yes       Yes

  Central and Quail        2,40,43,55                                                                                Yes       No

  Central and Lexington    2,40,43,55                                                                                Yes       No

  Central and Henry        2,40,43,55                                                                                Yes       No
  Johnston Blvd.                                                                                                               

  Washington and Lark      2,4,5,9,10,11,12,29,31,40,43,49,55                                                        Yes       Yes

  Washington and Swan      2,4,5,9,10,11,12,13,14,15,16,18,19,21,22,24, 29,31,33,35,40,41,42,43,48,49,55,57,63       Yes       No

  Washington at Capitol    2,4,5,9,10,11,12,13,14,15,16,17,18,19,21,22,24,29,31,33,35,40,41,42,43,48,49,55,57,63     Yes       No
  (Hawk)                                                                                                                       

  State and Eagle          2,4,5,9,10,12,13,18,29,31,40,41,42,43,55,63                                               Yes       No

  State and Pearl          2,4,5,7,9,10,11,12,13,14,15,16,18,19,21,22,24,29,30,31,33,35,40,41,42,43,48,49,55,57,63   Yes       No

  Broadway and Hudson      2,5,7,10,11,12,13,14,15,18,19,21,22,24,29,30,31,33,35,40,41,42,43,48,49,55,57,63          Yes       Yes

  Madison and Green        5,13,14,18,24,29,30,31,49,55                                                              Yes       No

  Greyhound Station        2,5,7,13,18,29,30,31,55                                                                   Yes       Yes
  ------------------------ ----------------------------------------------------------------------------------------- --------- ---------

\* Stop on CDTA operations list

\^ Stop on CDTA automated system list

**Table O.3 -- Comparison of Number of Stop Announcement Lists for Route
#1**

  --------------- ------------------- ------------------ ------------------
                  **Number of Stops**                    

                  **Suggested List**  **Automated System **CDTA Operations
                                      List**             List**

  **Westbound**   12                  3                  12

  **Eastbound**   15                  6                  14
  --------------- ------------------- ------------------ ------------------

**Attachment P**

**External Route Identification Data**

  -----------------------------------------------------------------------------
  **Date**   **Location**          **Time**   **Route   **Bus    **Route
                                              \#**      \#**     Announced?**
  ---------- --------------------- ---------- --------- -------- --------------
  27-Mar     State & Lodge (outb)  7:16       55        2052     No

  27-Mar     State & Lodge (outb)  7:18       30        9965     No

  27-Mar     State & Lodge (outb)  7:18       13        9925     No

  27-Mar     State & Lodge (outb)  7:19       ??        9928     No

  27-Mar     State & Lodge (outb)  7:19       1         9937     No

  27-Mar     State & Lodge (outb)  7:20       29        2095     No

  27-Mar     State & Lodge (outb)  7:23       55        ??       No

  27-Mar     Washington & Dove     2:24 p.m.  ??        2040     No

  27-Mar     S. Pearl & State      3:35 p.m.  8         9972     No

  27-Mar     S. Pearl & State      3:36 p.m.  7         2001     No

  27-Mar     S. Pearl & State      3:40 p.m.  6         9933     No

  27-Mar     S. Pearl & State      3:45 p.m.  4         9981     No

  27-Mar     S. Pearl & State      3:47 p.m.  9         9963     No

  27-Mar     S. Pearl & State      3:48 p.m.  10        9939     No

  27-Mar     S. Pearl & State      3:50 p.m.  12        3021     No

  27-Mar     S. Pearl & State      3:53 p.m.  6         3008     No

  27-Mar     S. Pearl & State      3:54 p.m.  8         9962     No

  27-Mar     S. Pearl & State      3:58 p.m.  10        9930     No

  27-Mar     S. Pearl & State      4:03 p.m.  9         9982     No

  27-Mar     S. Pearl & State      4:04 p.m.  12        3006     No

  27-Mar     S. Pearl & State      4:05 p.m.  3         9956     No

  27-Mar     S. Pearl & State      4:06 p.m.  Walmart   2102     No

  27-Mar     S. Pearl & State      4:07 p.m.  10        9908     No

  27-Mar     S. Pearl & State      4:12 p.m.  10        9901     No

  27-Mar     S. Pearl & State      4:15 p.m.  4         3005     Yes: driver
                                                                 spoke to blind
                                                                 passenger

  27-Mar     S. Pearl & State      4:16 p.m.  6         9971     No

  27-Mar     S. Pearl & State      4:21 p.m.  8         9907     No

  27-Mar     S. Pearl & State      4:23 p.m.  12        9916     No

  27-Mar     S. Pearl & State      4:24 p.m.  10        9938     No

  27-Mar     S. Pearl & State      4:25 p.m.  9         2006     No

  27-Mar     S. Pearl & State      4:26 p.m.  8         9913     No

  27-Mar     S. Pearl & State      4:29 p.m.  12        9952     No

  27-Mar     S. Pearl & State      4:34 p.m.  7         2001     No

  27-Mar     S. Pearl & State      4:34 p.m.  10        9903     No

  27-Mar     S. Pearl & State      4:35 p.m.  6         3029     No

  27-Mar     S. Pearl & State      4:37 p.m.  3         9956     No

  28-Mar     State & Lodge (outb)  3:49 p.m.  18        9911     No

  28-Mar     State & Lodge (outb)  3:50 p.m.  22        2013     No

  28-Mar     State & Lodge (outb)  3:51 p.m.  9         9978     No

  28-Mar     State & Lodge (outb)  3:53 p.m.  12        9941     No

  28-Mar     State & Lodge (outb)  3:54 p.m.  22        2077     No

  28-Mar     State & Lodge (outb)  3:54 p.m.  1         3024     No

  28-Mar     State & Lodge (outb)  3:55 p.m.  13        9931     No

  28-Mar     State & Lodge (outb)  3:55 p.m.  63        2026     No

  28-Mar     State & Lodge (outb)  3:56 p.m.  10        9919     No

  28-Mar     State & Lodge (outb)  4:00 p.m.  55        2024     No

  28-Mar     State & Lodge (outb)  4:04 p.m.  3         9930     No

  28-Mar     State & Lodge (outb)  4:05 p.m.  29        2017     No

  28-Mar     State & Lodge (outb)  4:05 p.m.  13        9953     No

  28-Mar     State & Lodge (outb)  4:06 p.m.  2         3005     No

  28-Mar     State & Lodge (outb)  4:06 p.m.  18        3027     No

  28-Mar     State & Lodge (outb)  4:08 p.m.  9         9971     No

  28-Mar     State & Lodge (outb)  4:08 p.m.  1         3001     No

  28-Mar     State & Lodge (outb)  4:11 p.m.  13        3008     No

  28-Mar     State & Lodge (outb)  4:11 p.m.  10        9937     No

  28-Mar     State & Lodge (outb)  4:12 p.m.  12        3010     No

  28-Mar     State & Lodge (outb)  4:13 p.m.  22        2044     No

  28-Mar     State & Lodge (outb)  4:14 p.m.  55        2057     No

  28-Mar     State & Lodge (outb)  4:15 p.m.  10        9916     No

  28-Mar     State & Lodge (outb)  4:16 p.m.  30        9907     No

  28-Mar     State & Lodge (outb)  4:19 p.m.  18        9982     No

  28-Mar     State & Lodge (outb)  4:20 p.m.  12        9926     No

  28-Mar     State & Lodge (outb)  4:21 p.m.  4         3007     No

  28-Mar     State & Pearl (inb)   4:24 p.m.  29        2008     No

  28-Mar     State & Pearl (inb)   4:25 p.m.  9         9978     No

  28-Mar     State & Pearl (inb)   4:26 p.m.  2         9909     No

  28-Mar     State & Pearl (inb)   4:27 p.m.  33        3021     No

  28-Mar     State & Pearl (inb)   4:28 p.m.  35x       2022     No

  28-Mar     State & Pearl (inb)   4:30 p.m.  5         9912     No

  28-Mar     State & Pearl (inb)   4:31 p.m.  13        9934     No

  28-Mar     State & Pearl (inb)   4:33 p.m.  22        2044     No

  28-Mar     State & Pearl (inb)   4:35 p.m.  63        2056     No

  28-Mar     State & Pearl (inb)   4:36 p.m.  4         9976     No

  28-Mar     State & Pearl (inb)   4:38 p.m.  21x       9903     No

  28-Mar     State & Pearl (inb)   4:38 p.m.  30        9908     No

  28-Mar     State & Pearl (inb)   4:39 p.m.  12        9956     No

  28-Mar     State & Pearl (inb)   4:40 p.m.  10        3026     No

  27-Mar     State & Lodge (outb)  7:30       55        2036     No

  27-Mar     State & Washington,   9:08       54        2063     No
             Schenectady (inb)                                   

  27-Mar     State & Washington,   11:05      53        2061     No
             Schenectady (outb)                                  

  27-Mar     Altamont & Curry,     12:30 p.m. 53        2061     No
             Schenectady                                         

  27-Mar     State & Washington,   1:00 p.m.  51        2060     No
             Schenectady (outb)                                  

  27-Mar     State & Washington,   1:58 p.m.  62        2064     No
             Schenectady (outb)                                  

  27-Mar     State & Washington,   2:00 p.m.  70        2065     No
             Schenectady (outb)                                  

  27-Mar     Latham Circle Mall    2:49 p.m.  70        2036     No

  27-Mar     State & Broadway,     3:27 p.m.  63        2058     No
             Schenectady                                         

  28-Mar     State & Pearl (inb)   7:51       22        2092     No

  28-Mar     Fulton & 4th, Troy    9:39       84        2085     No

  28-Mar     State & 4th, Troy     10:04      80        2075     No

  28-Mar     State & 3rd, Troy     11:07      85        2076     No

  28-Mar     River & Front, Troy   11:42      22        2033     No

  28-Mar     State & Lodge (outb)  12:12 p.m. 22        2033     No
  -----------------------------------------------------------------------------

**Total observations: 93**

**Route identifications: 1**