**Port Authority of Allegheny County (PAT)**

**Pittsburgh, PA**

**Assessment of Fixed Route Stop Announcement**

**and Route Identification Efforts**

**August 21-24, 2000**

***Summary of Observations***

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, D.C.**

**Prepared by**

**Planners Collaborative, Inc.**

**Final Report**

**February 6, 2001**

# CONTENTS

CONTENTS [i](#contents)

Purpose of the Assessment [1](#purpose-of-the-assessment)

Background [2](#background)

Overview of the Assessment [3](#overview-of-the-assessment)

Observations of On-Board Stop Announcements
[5](#observations-of-on-board-stop-announcements)

PAT Policies and Procedures Regarding On-Board Stop Announcements
[5](#pat-policies-and-procedures-regarding-on-board-stop-announcements)

PAT Training [5](#pat-training)

Monitoring and Discipline [6](#monitoring-and-discipline)

Operator and Supervisor Interviews
[7](#operator-and-supervisor-interviews)

Rider Experiences and Observations
[7](#rider-experiences-and-observations)

Assessment Team Observations [8](#assessment-team-observations)

Automated Voice Announcement Equipped Buses
[12](#automated-voice-announcement-equipped-buses)

Findings and Recommendations [13](#findings-and-recommendations)

*Findings:* [13](#findings)

*Recommendations:* [15](#recommendations)

Observations of Route Identification System
[17](#observations-of-route-identification-system)

PAT Policies and Procedures Regarding a Route Identification System
[17](#pat-policies-and-procedures-regarding-a-route-identification-system)

PAT Training [17](#pat-training-1)

Monitoring and Discipline [18](#monitoring-and-discipline-1)

Operator and Supervisor Interviews
[18](#operator-and-supervisor-interviews-1)

Rider Experiences and Observations
[18](#rider-experiences-and-observations-1)

Assessment Team Observations [18](#assessment-team-observations-1)

Findings and Recommendations [19](#findings-and-recommendations-1)

*Findings:* [19](#findings-1)

*Recommendations:* [20](#recommendations-1)

Attachment A. PAT Bus and Rail Routes

Attachment B. PAT ADA Policies on Stop Announcements and Vehicle
Identification

Attachment C. PAT Quality Assurance Program

Attachment D. Sample ADA Stop Announcement List

Attachment E. Vehicle Stop Announcement and Identification Tabular Data

Attachment F. Port Authority Letter, December 14, 2000

# Purpose of the Assessment

The U. S. Department of Transportation (USDOT) regulations implementing
the Americans with Disabilities Act of 1990 (ADA) contain two
requirements that are meant to assist persons with vision impairments
and other disabilities to use fixed route transportation services.
Section 37.167, subsections (a) and (b), which apply to public and
private entities that operate fixed route systems, requires that:

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

Section 37.167 (c) requires that:

> *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.*

The Federal Transit Administration (FTA) is responsible for ensuring
compliance with the ADA and the USDOT regulations which address
implementation of this civil rights law. As part of its compliance
efforts, FTA, through the FTA Office of Civil Rights, conducts periodic
assessments of fixed route transit services operated by grantees.

An on-site assessment of the fixed route service provided by the Port
Authority of Allegheny County in Pittsburgh, Pennsylvania was conducted
August 21-24, 2000. Planners Collaborative, Inc. of Boston,
Massachusetts conducted the assessment for the FTA Office of Civil
Rights. Donald Kidston of Planners Collaborative served as the
assessment team leader. Brian Barber and David Loutzenheiser of Planners
Collaborative assisted with the review. The assessment focused on Port
Authority Transit's (PAT) efforts and successes in implementing the stop
announcement and route identification requirements noted above.

This report summarizes the observations and findings of the on-site
assessment of PAT's fixed route service. A description of key features
of the service is first provided. A description of the approach and
methodology used to conduct the assessment is then provided. The
assessment of stop announcements and route identification are presented
separately. For each area, observations regarding PAT policies and
procedures, employee training PA equipment, service monitoring and
customer concerns are provided. Field observations of the assessment
team are then presented. Finally, the major findings of the assessment
and recommendations of the review team are summarized at the end of the
two report sections.

# Background

PAT provides bus, light rail, rail incline (funicular) and ADA
Complementary Paratransit Service in the greater Pittsburgh region
including Allegheny County and minor portions of Armstrong, Beaver,
Washington, and Westmoreland Counties. PAT directly operates bus and
light rail service and the Monongahela Incline. A complete list of PAT
fixed routes appears in Attachment A. A private party operates the
Duquesne Incline through a contract with PAT. A private party also
provides the ADA Complementary Paratransit Service, ACCESS, through a
contract with PAT.

PAT has a fleet of 1036 buses, 80 small transit vehicles, 55 light rail
vehicles, and 4 incline vehicles. The fixed route system includes, 25.2
miles of light rail, 11.1 miles of busway, 3.7 miles of contraflow bus
lanes, and 6.9 miles of High Occupancy Vehicle lanes. The light rail
system serves five downtown stations. The routes are generally oriented
in a radial pattern serving Pittsburgh's Downtown and Oakland areas.
Topography further limits the alignment of bus routes. The Allegheny
River on the north and Monongahela on the south form the boundaries of
the Downtown area. The rivers and steep hills of Pittsburgh limit the
number of streets available for bus routes. As a result many routes
share common street segments for long portions of their route.

Most of the bus fleet and all of the Light Rail Vehicle (LRV) fleet is
equipped with Public Address (PA) systems to assist drivers in making
stop announcements. The exception to use of traditional PA equipment is
160 new Neoplan low floor buses that are equipped with computerized stop
announcement systems. The new equipment, manufactured by Clever Devices,
provides automatic interior stop and exterior route identification
announcements along with text displays of stops inside the bus.

# Overview of the Assessment

As noted above, this assessment focused on compliance with the fixed
route stop announcement and external vehicle/route identification
requirements of the regulations. The assessment first involved the
collection and review of key service information prior to the on-site
visit. This information included:

-   The most recent fixed route system map;

-   A complete set of schedules for fixed routes;

-   A copy of individual stop announcement lists developed by PAT;

-   The Fixed Route Operator Manual which outlines operating policies
    and procedures;

-   Notices, bulletins, and memoranda detailing stop announcement and
    route identification policies including PAT's ADA Manual and ADA
    Stop Announcement List;

-   PAT's Quality Assurance Program using undercover riders on a monthly
    basis to monitor stop announcements and route identification; and

-   Recent service complaints regarding stop announcements or route
    identification.

    Prior to the on-site visit, the assessment team also reviewed formal
    complaints on file with FTA concerning stop announcements and route
    identification by PAT. Finally, telephone interviews were conducted
    with several local human service agency representatives and persons
    with vision disabilities who regularly use the PAT fixed route
    service in order to gain a sense of their experience with PAT stop
    announcements and route identification.

    PAT was notified in July 2000 that an assessment would be conducted
    in the near future. In order to get a representative observation of
    performance, the exact dates of the on-site visit were not provided.
    The notification letter indicated that after spending a few days
    on-site, the assessment team would contact PAT to arrange for
    meetings with staff and to schedule an exit conference.

    The on-site assessment was conducted during the week of August
    21-24, 2000. On Monday and Tuesday the review team rode on the fixed
    route system and made observations of stop announcements and route
    identification. On Tuesday afternoon, PAT staff were contacted and
    apprised of the assessment team's arrival and arrangements were made
    for meetings.

    On Wednesday morning, the review team met with Dan DeBone, Special
    Services Manager; Laurie Andrews, Assistant Operations Officer;
    Richard Wojnar, Operations Training Manager; and Joseph Ferlic,
    Assistant Manager of Electronic Systems. The parties were
    interviewed on their understanding of the ADA stop announcement and
    route identification requirements, PAT procedures and training,
    equipment used in implementation of PAT's procedures, and service
    monitoring efforts. During the afternoon, the review team traveled
    to two bus garages; West Mifflin and Harmar. West Mifflin is the
    largest of five garages, Harmar the smallest. At each garage, the
    team met with the Director of Service Delivery, drivers, and
    training personnel. Again PAT staff was interviewed with respect to
    their understanding of the ADA policies and related PAT procedures,
    the adequacy of resources including training to implement the
    procedures, and service monitoring.

    On Thursday afternoon, an exit conference was conducted. Attending
    the exit conference for PAT were Ms. Andrews, Mr. DeBone, and Mr.
    Wojnar. Ms Cheryl Hershey, FTA's ADA Team Leader, and Ms. Roberta
    Wolgast of the FTA also participated by phone.

    PAT reviewed the draft report and provided comments and identified
    corrective actions in a December 14, 2000 letter to FTA (Attachment
    F).

# Observations of On-Board Stop Announcements

To assess PAT's current performance in providing on-board stop
announcements, the assessment team collected the following information.

-   Information about PAT's policies and procedures for announcing stops
    was reviewed;

-   The Training Manager and two regional trainers were interviewed;

-   Two supervisors and 13 drivers were interviewed to verify their
    understanding of stop announcement policies;

-   Six visually impaired or blind persons who regularly ride the PAT
    system were interviewed; and

-   On Monday and Tuesday, the review team rode on 55 buses covering 38
    routes, and 5 light rail trips and observed and noted stop
    announcements.

## PAT Policies and Procedures Regarding On-Board Stop Announcements

PAT's policy and procedures regarding on-board stop announcements are
detailed in the "Americans with Disabilities Act, Educational Manual and
Reference Guide." Applicable references from the Guide appear in
Attachment B. Specifically, the guide states that

> *The Port Authority shall announce at least [transfer
> points]{.underline} with other fixed routes, [other major
> intersections]{.underline} and [destination points]{.underline}, and
> [intervals]{.underline} along a route, sufficient to permit
> individuals with visual impairments or other disabilities to be
> oriented to their location. In addition, the Port Authority shall
> announce any stop upon request of an individual with disabilities.*
>
> *Operators announce at least the stops listed in the Stop Announcement
> handbook/List and any stop upon request.*

Senior management indicated that operators are to announce all Downtown
stops in addition to those on the stop list.

PAT also published a summary sheet of ADA Compliance Rules (See
Attachment B).

The 160 new low floor buses are equipped with automated stop enunciator
equipment.

## PAT Training

While on site, the reviewers met with Richard Wojnar, Operations
Training Manager.

Mr. Wojnar noted that all new drivers undergo an extensive 10-week
training course. From the start, drivers are trained to call out the
stops. One day of the course is dedicated entirely to ADA training.
People with disabilities attend the training to make drivers aware of
the importance of transit service to them, to sensitize drivers to
appropriate forms of assistance, and to establish a personal connection
between the drivers and people with disabilities.

A 10-minute ADA video was produced in conjunction with the Committee for
Accessible Transportation and the labor union to personalize the need
for stop announcements and other ADA related services.

According to Dan DeBone, Manager of Special Services, PAT began ADA
retraining in March 2000 for veteran bus and light rail operators,
customer service representatives, police officers, and the Road
Operations Department staff. The driver refresher course is scheduled
for two-year cycles.

## Monitoring and Discipline

For the last three years, PAT has hired a temporary agency to provide
undercover riders to observe PAT service. The riders address a variety
of issues, however their primary purpose is to assess whether drivers
are announcing stops in compliance with PAT and ADA policies. A summary
of PAT's Quality Assurance Program and QAO form appear in Attachment C.
According to PAT management, the quality assurance observers check 75 to
100 trips per week. Based upon summary results for June 2000 it appears
that the number of trip observations is closer to 50 per week
(Attachment C). Their observations are compiled and verified at the main
office, then sent out to supervisors at the individual garages. PAT does
not maintain a central system for tracking driver non-compliance and
associated corrective actions. Each garage uses its own system for
tracking non-compliance. These systems vary depending upon staff
knowledge of computer systems at each garage. PAT management indicated
that the tracking system being developed at the West Mifflin Garage is
intended as a model for all the garages.

It is PAT procedure to counsel or discipline drivers who fail to make
stop announcements according to progressive discipline procedures.

PAT has a five-step progressive discipline program as follows:

1.  Counseling

2.  Verbal Warning

3.  Written Warning

4.  Final Written warning and possible suspension

5.  Termination

The time period is one year from the first warning. If there are no
disciplinary incidents in one year the process reverts to the first
step. According to PAT, no terminations (due only to stop calling) have
occurred in the past 3 years, however several actions have advanced to
third party arbitration. There have been no reversals of PAT decisions
in this arbitration process. Counseling can include retraining as well
as counseling by a supervisor. According to PAT management, drivers with
several (3 -- 4) infractions have been sent for a week of retraining.

## Operator and Supervisor Interviews

Two supervisors and 13 drivers were interviewed at the West Mifflin and
Harmar garages. Employees were asked to describe their understanding of
the policy regarding stop announcements. Most drivers interviewed
appeared to be aware of a requirement to call out stops. However, many
understood this requirement to apply only when a passenger appears to be
blind or disabled. Several drivers did not appear to know that cards
with stop lists were available. Several drivers indicated that they did
not have, or could not obtain copies of the stop announcement lists in
recent months. Supervisors indicated that this is a temporary situation
resulting from PAT's transition to a new bus stop inventory system.
Other than this temporary situation, supervisors indicated that stop
lists are provided to drivers each time they pick a new work schedule.
In addition, supervisors indicated that laminated copies of stop lists
are available for drivers who do not have fixed schedules. Drivers
appeared to understand the importance of announcing all downtown stops
in addition to those on the stop lists. Supervisors did not appear to
clearly understand this requirement.

Drivers generally indicated a preference for making announcements with
unassisted voice rather than the PA system. Reasons cited were 1.)
Removal of hands from the steering wheel to use the PA interferes with
driving; 2) Use of the microphone is unsanitary; 3) the position of the
microphone interferes with driving. Some drivers indicated a preference
for the PA to amplify the announcement. Some drivers said that the PA
system works well while others cited problems with volume and sound
quality.

PAT management personnel indicated that it is PAT procedure to have
operators check the PA system at daily pullout. If the PA is not working
it is to be noted on the vehicle checklist and the vehicle is to be
pulled from service if there is another vehicle available. The checklist
is forwarded to the radio repairman who logs the information into the
maintenance database and proceeds with the repair. Supervisors indicated
that repairs to the PA systems are made in one day and that garages were
well stocked with replacement parts.

Drivers indicated that programming the new automated enunciators, as
originally installed, and was cumbersome. Revisions to the driver
programming procedures, that are currently being made, have made driver
programming much easier. Several drivers noted that the automated system
sometimes announces stops at the wrong location, particularly in the
Downtown area.

###  

## Rider Experiences and Observations

Prior to the on-site visit, six individuals were interviewed by phone
about their experiences with stop announcements on the PAT fixed route
system. The individuals interviewed were either people with disabilities
who use the PAT system or staff of organizations whose clients are
people with disabilities who use the PAT system. Most of those
interviewed commented that stop announcements have improved over the
past several years, but improvement is still needed. Common complaints
from the riders include:

-   Stop Announcement calling is very spotty. It seems to depend on the
    driver;

-   Most people think that when the driver does call the stops it is
    because either the driver recognizes the rider, and/or the driver
    can see that the rider is blind because a cane, dog, or other
    identifying feature is visible;

-   Drivers are less likely to call stops during rush hour or in
    downtown area due to distractions;

-   Driver attitudes range from nice and helpful to bad;

-   Many drivers do not use the PA system, and therefore it is often
    hard to hear the stops called; and

-   The automated system sometimes announces stops in the wrong
    location.

## Assessment Team Observations

As noted above, the three assessment team members rode on 55 bus runs on
38 unique routes observing 402 scheduled and unscheduled announcements.
Several routes were observed more than once. The assessment team also
rode on 5 light rail trips observing 31 scheduled stop announcements.

An "On-Board Fixed Route Stop Announcement Assessment Form" was used to
collect information. Prior to boarding buses to observe stop
announcements on a particular route, assessment team members recorded
the stops that were supposed to be announced on these forms. The list of
stops to be announced was taken from the PAT "ADA Stop Announcements --
Operators Handbook" lists. A sample of PAT's ADA stop list appears in
Attachment C.

Reviewers recorded whether or not announcements were made at each
identified stop. If an announcement was made, reviewers noted whether it
was made by unassisted voice, by PA or by the Clever Devices automated
system (on selected buses). Reviewers also noted whether the
announcements were clear and audible. Observers sat about half way back
in each bus (typically near the mid-vehicle door). Tables of individual
observations are provided in Attachment D.

Table 1 provides a summary of assessment team observations.

> Table 1. Bus On-Board Stop Announcements

+--------------------------------------+----------+----------+----------+
| Total Bus Trip Observations          | 55       |          |          |
+--------------------------------------+----------+----------+----------+
| Bus Routes Observed                  | 38       |          |          |
+--------------------------------------+----------+----------+----------+
| #### Listed Stops Observed           | 402      |          |          |
+--------------------------------------+----------+----------+----------+
|                                      |          |          |          |
+--------------------------------------+----------+----------+----------+
| [Observed Announcements]{.underline} | [        | [No]{.un |          |
|                                      | Yes]{.un | derline} |          |
|                                      | derline} |          |          |
+--------------------------------------+----------+----------+----------+
| Stop Announcements Made              | 27%      | 73%      |          |
+--------------------------------------+----------+----------+----------+
| Trips with Announcements Made        | 45%      | 55%      |          |
+--------------------------------------+----------+----------+----------+
|                                      |          |          |          |
+--------------------------------------+----------+----------+----------+
| [Audibility]{.underline}             | [        | [No]{.un | [S       |
|                                      | Yes]{.un | derline} | ome]{.un |
|                                      | derline} |          | derline} |
+--------------------------------------+----------+----------+----------+
| Announcement Audible?                | 76%      | 4%       | 20%      |
+--------------------------------------+----------+----------+----------+
|                                      |          |          |          |
+--------------------------------------+----------+----------+----------+
| [Method of Announcement]{.underline} | [A       | [PA]{.un | [Vo      |
|                                      | uto]{.un | derline} | ice]{.un |
|                                      | derline} |          | derline} |
+--------------------------------------+----------+----------+----------+
| Method                               | 4%       | 40%      | 56%      |
+--------------------------------------+----------+----------+----------+

As indicated in Table 1, approximately 27% of all required stop
announcements were made. On a trip basis, some, but not all, stops were
announced on 45% of all bus trips observed. A PAT Garage Manager
indicated that it is her practice to apply PAT's disciplinary program,
described above, when drivers call less than 80% of the stops. The
assessment team found that 80% or more of the stops were announced on
16% of observed runs. On 55% of the observed runs no stop announcements
were made.

For the most part, when stops were announced, the announcement was
audible. That is, about 76% of observed announcements were audible, 20%
were partially audible, and the announcements were not audible on only
one trip. Slightly more than half of the drivers who made announcements
used unassisted voice. About 40% used the PA system. One run had the
Clever Devices enunciator system in operation.

Table 2 presents the results of the assessment team's observations on
the LRT Line. All announcements on the LRT line were made using the PA
system and were audible.

> Table 2. LRT On-Board Stop Announcements

+-------------------------------------------------+----------+----------+
| Total LRT Trip Observations                     | 5        |          |
+-------------------------------------------------+----------+----------+
| ##### Stops Observed                            | 31       |          |
+-------------------------------------------------+----------+----------+
|                                                 |          |          |
+-------------------------------------------------+----------+----------+
| [Announcements]{.underline}                     | [        | [No]{.un |
|                                                 | Yes]{.un | derline} |
|                                                 | derline} |          |
+-------------------------------------------------+----------+----------+
| Announcements Made?                             | 87%      | 13%      |
+-------------------------------------------------+----------+----------+
| Announcements Audible?                          | 100%     | 0        |
+-------------------------------------------------+----------+----------+

All stop announcements on the LRT system are prerecorded and automated.
As a result, the stop announcement rate on the LRT was much higher than
bus. Based on PAT's stop announcement list, 87% of observed stops were
called. On all five observed trips, the announcements were called at 73%
or more of the stops. Since the LRT system is automated it was unclear
why any stop announcements were missed. All LRT stops announcements
observed by the assessment team were audible.

The observations were further analyzed to assess the influence of the
method used to make announcements. As can be seen from the limited
observations presented in Table 2, the unassisted voice announcements
appear to be audible more consistently than the announcements made using
the public address systems.

Table 3. Audibility of Announcements

<table>
<colgroup>
<col style="width: 18%" />
<col style="width: 11%" />
<col style="width: 9%" />
<col style="width: 10%" />
<col style="width: 9%" />
<col style="width: 10%" />
<col style="width: 8%" />
<col style="width: 11%" />
<col style="width: 9%" />
<col style="width: 0%" />
</colgroup>
<tbody>
<tr class="odd">
<td>Announcement Method</td>
<td colspan="8">Audible</td>
<td></td>
</tr>
<tr class="even">
<td rowspan="2"><p> </p>
<p> </p></td>
<td colspan="2">Yes</td>
<td colspan="2">Somewhat</td>
<td colspan="2">No</td>
<td colspan="2">Total</td>
<td></td>
</tr>
<tr class="odd">
<td>Number</td>
<td>%</td>
<td>Number</td>
<td>%</td>
<td>Number</td>
<td>%</td>
<td>Number</td>
<td>%</td>
<td></td>
</tr>
<tr class="even">
<td>Automated</td>
<td>1</td>
<td>100%</td>
<td>0</td>
<td>0%</td>
<td>0</td>
<td>0%</td>
<td>1</td>
<td>4%</td>
<td></td>
</tr>
<tr class="odd">
<td>PA</td>
<td>5</td>
<td>50%</td>
<td>4</td>
<td>40%</td>
<td>1</td>
<td>10%</td>
<td>10</td>
<td>40%</td>
<td></td>
</tr>
<tr class="even">
<td>Voice</td>
<td>13</td>
<td>93%</td>
<td>1</td>
<td>7%</td>
<td>0</td>
<td>0%</td>
<td>14</td>
<td>56%</td>
<td></td>
</tr>
<tr class="odd">
<td> </td>
<td> </td>
<td></td>
<td> </td>
<td></td>
<td> </td>
<td></td>
<td> </td>
<td></td>
<td></td>
</tr>
<tr class="even">
<td>Total</td>
<td>19</td>
<td>76%</td>
<td>5</td>
<td>20%</td>
<td>1</td>
<td>4%</td>
<td>25</td>
<td></td>
<td></td>
</tr>
</tbody>
</table>

Repair records of the PA systems on PAT's fleet of 1036 buses were
analyzed. As summarized in Table 4, 439 repairs involving the PA and/or
microphone system were reported during the first five months of 2000.
This averages to roughly 3 repairs per day system wide. Overall the
repair rate for PA systems appears to approach 1 repair for each PA
system per year. Many of the repairs are related to the microphones,
including the goosenecks. The higher than average repair rates at Harmar
Garage appear to be related to the new automated stop announcement
system. PAT personnel indicated that they have experienced as many as 24
failures to the automated PA system in one day. One hundred sixty buses
are equipped with the automated system. It is unclear why the repair
rates at Collier Garage are lower than the norm.

Table 4. PA Equipment Repairs January-May 2000

  -------------- --------- --------- --------- --------- --------- ---------
  Garage         Harmar    E Liberty Collier   W Mifflin Ross      Totals

                                                                    

  Vehicles\*     219       157       183       217       128       904

  January        18        14        6         26        17        81

  February       35        22        6         21        11        95

  March          27        22        9         13        18        89

  April          23        23        8         14        12        80

  May            42        11        6         24        11        94

                                                                   

  Total/Garage   145       92        35        98        69        439

  \% of Fleet    66.2%     58.6%     19.1%     45.2%     53.9%     48.6%
  -------------- --------- --------- --------- --------- --------- ---------

**\***Based on 1999 fleet assignments -- does not include recent fleet
expansion.

PAT provided the assessment team with a summary quality assurance (QAO)
report for the month of June 2000 (see Attachment Y). This summary
indicates that of 219 bus trips observed during the month, all stops
were announced on 61% of the trips, some were announced on 6% and none
were announced on 34% of the trips. This compares with assessment team
observations of 15%, 30% and 55% respectively.

Additional, more detailed records on monitoring and remedial action for
no stop announcements from QAO Reports were provide by PAT for two
garages. Records for West Mifflin Garage included the year 1999. The
available records for Hamar Garage were for the month of August 2000. A
summary of the assessment teams review of the records appears in Table
5.

Table 5. Monitoring & Remedial Action

  --------- -------------- ------------- ------ -------- ------ -------- ----- -------- -----
  Garage    Remedial       Observation                                                   
                           of Stops                                                     
                           Called                                                       

  Period    Action         All                  Some            None           Total     

                           Number        \%     Number   \%     Number   \%    Number   \%

                                                                                         

  West      Commendation   10            71%             0%              0%    10       9%
  Mifflin                                                                               

  1999      Counseling                   0%     0        0%     3        4%    3        3%

            None           4             29%    34       100%   64       96%   102      89%

            Total          14                   34              67             115       

            \%             12%                  30%             58%                      

                                                                                         

  Harmar    Commendation   7             100%            0%                    7        88%

  Aug-00    Counseling                   0%     1        100%   0              1        13%

            None           0             0%     0        0%     0              0        0%

            Total          7                    1               0              8         

            \%             88%                  13%             0%                       
  --------- -------------- ------------- ------ -------- ------ -------- ----- -------- -----

Based upon the review team's limited assessment, it appears that the
number of observations in which stops are not called is significantly
understated in PAT's QAO Reports.

Based upon PAT's monitoring program that reviews 50 trips per week, the
system-wide monthly trip observations should be approximately 200 and
annual observations should be approximately 2,500. Based on fleet
assignment to each garage, the number of annual observations for West
Mifflin would be approximately 575 (23%) and monthly trip observations
for Harmar would be 45 (23%). The assessment team observed that no stop
announcements were made on approximately 55% of the trips observed.
Accordingly, one would expect approximately 315 monitoring program
observations of no stop announcements for West Mifflin Garage in the
course of a year, rather than the 67 reflected in the West Mifflin QAO
Report. Similarly, one would expect 25 observations of no stop
announcements in a month for Harmar Garage rather than 1. The
distribution of driver performance for West Mifflin Garage (12% - all
announcements, 30% - some, and 58% - none) appears very consistent with
assessment team observations (15% - all, 30 % - some, and 55% - none).
The distribution of driver performance at Harmar Garage (88% - all,
13% - some and 0% - none) is inconsistent with assessment team
observations. It appears that monitoring results are not being entered
into the QAO reports in a consistent way at the garages.

PAT appeared to do a good job of commending drivers for making stop
announcements. However it appears that there is little consequence to
drivers for not making stop announcements. At West Mifflin Garage all 34
of the drivers who made some announcements and 63 of the 67 drivers who
made no announcements faced no remedial action. Only 3 drivers at West
Mifflin and 1 at Harmar received counseling, the first step in PAT's
five step disciplinary program.

## Automated Voice Announcement Equipped Buses

PAT purchased 160 low floor Neoplan buses in 1999. Delivery took place
through the spring of 2000. All of the new buses are equipped with the
Clever Devices automated stop announcement system. The system is
designed to automatically announce all designated stops. The route
number and destination as it appears on the buses head sign is announced
from a speaker mounted on the outside of the bus. The stop announcements
are also displayed on a scrolling LED within the bus.

The automated system uses a global positioning system (GPS) to identify
the bus location to within 15-ft of its actual location. GPS technology
involves receiving signals from three or more satellites and
triangulating the location on the ground based on the distance between
the satellites and the receiver on the ground. GPS satellites circle the
earth in an orbit that holds the position of the satellite fixed with
respect to the earth's surface. Concurrently, the satellites emit a
signal that identifies the transmitting satellite. The geometric
relationship between the receiving location and the satellites can be
identified by measuring the difference in time between receipt of three
or more GPS signals that travel at constant speeds. Since the
satellite's location is fixed with respect to the earth's surface, the
location of the GPS signal receiver can be calculated to within 15 feet.
The time it takes a signal to reach the receiver can be affected by
deflection off of physical objects in its path (buildings, topography,
etc) or by atmospheric interference. As a result the location of the
receiver can be incorrectly identified.

The driver activates the automated announcement system at the beginning
of each route by entering the route number and direction
(inbound/outbound) into the system. When PAT first put the system into
operation, the driver had to enter each run into the system by using a
relatively cumbersome multi-step process. Because of this cumbersome
process, drivers indicated that entering the information at the downtown
ends of trips was particularly impractical. (PAT buses operate on a
continuous loop through heavy downtown traffic with large numbers of
boarding and alighting passengers, leaving little time to enter the
route identifiers.) To address this problem, PAT's contractor is
modifying the method of activation to simply entering a four-digit code,
which represents the route number. The modifications will also permit
drivers to enter all their runs at the beginning of their shift and
permit them to advance to the next run by simply entering one command.
If the bus is shut off the preprogrammed run information is deleted from
the system and has to be reentered. PAT is midway through this software
and hardware conversion process.

As shown in Table 1, eight trips were recorded on the
enunciator-equipped buses (Series 5000). Of these trips, only one was
observed with the enunciator working properly. On the other trips, the
system was turned off or otherwise disengaged. On three of those trips,
the driver made voice announcements, and made no announcements on the
other four trips. On one trip, in which the video display was operating,
stops were not announced consistently with one stop being announced both
before and after the stop.

## Findings and Recommendations

### *Findings:*

1.  PAT written policies and procedures for on-board stop announcements
    adequately conform to ADA requirements.

2.  PAT appears to have a comprehensive training program for new
    drivers. According to PAT personnel, stop announcement requirements
    are presented and reinforced throughout the training program.
    Drivers are required to make stop announcements early in the program
    as part of a simulated bus trip. The training program uses several
    features to sensitize and train drivers in the importance of stop
    announcements including a training video, sensitivity training and
    participation of volunteers who have disabilities. A refresher
    course was implemented in the spring of 2000 to retrain drivers.
    However, based upon driver interviews, it appears that many drivers
    do not understand stop announcement procedures.

3.  PAT management, including garage supervisors appeared to understand
    the requirement to call stops.

4.  Stop Lists appear to include all transfer points, other major
    intersections and destinations, and intervals sufficient to orient
    people with disabilities as required by ADA outside of the Downtown
    area. Otherwise PAT stop lists appear to be very comprehensive for
    areas outside of Downtown.

5.  Stop Lists did not include Downtown stops. Although operators
    appeared to understand that they are supposed to announce all
    Downtown stops, omission of these stops from the list may be causing
    some confusion as to this requirement.

6.  Some drivers indicated that stop lists were not readily available.
    Supervisors indicated that it is PAT's practice to provide stop
    lists to drivers at each driver work schedule change but this
    practice had been temporarily suspended during transition to a new
    bus stop inventory system.

7.  Most drivers interviewed appeared to be aware of a requirement to
    call out stops. However, many understood this requirement to apply
    only when a passenger appears to be blind or disabled. Several
    drivers did not know that stop cards existed.

8.  Drivers announced 109 (27 %) of 402 listed bus stops observed by the
    assessment team.

9.  On the 55 bus trips observed, 8 drivers (15%) announced all of the
    stops from PAT's stop announcement list. Of those drivers who
    announced all of the stops 4 announced far more stops than those on
    PAT's stop list. A total of 10 drivers (18%) announced more than 80%
    of the stops, 25 drivers (45%) announced at least one stop and 30
    drivers (55 %) announced no stops at all.

10. Fourteen (56%) of the stop announcements that were made were made by
    unassisted voice. Ten (40%) were made using the PA system.
    Ninety-three percent of the voice announcements were audible while
    50% of the announcements using the PA were audible.

11. It appears that drivers with strong voices prefer to use unassisted
    voice to make announcements in order to avoid interference with
    driving and/or handling potentially unsanitary microphones
    associated with use of the PA system. It appears that drivers with
    weaker voices prefer to use the PA system.

12. PAT appears to have an effective program in place to test and repair
    PA systems. System-wide, an average of three repairs per day on the
    PA system have been recorded during the first five months of 2000.
    This corresponds to an approximate rate of one PA repair per bus per
    year. Many of the repairs are for problems with the microphone and
    gooseneck. The ongoing development of the automated system has
    contributed to relatively high repair rates at Hamar Garage.

13. The automated stop calling system on the LRT produced more
    announcements than the bus system, with 87% of required stops
    called. However, 13% of observed stops were not announced.

14. Only 1 out of 8 observed automated stop announcement equipped buses
    was working properly. The new automated stop announcement system is
    currently being phased into operation. Accuracy is expected to
    improve as system corrections are made. The stop announcements are
    sometimes made in the wrong location.

15. It appears that Quality Assurance Monitors may be overstating the
    number of drivers who are making stop announcements. PAT reported
    61% of drivers making all stop announcements verses 15% observed by
    the assessment team.

16. It appears that some observations of stop announcements by Quality
    Assurance Monitors may not be entered into the QAO Reporting
    Systems. The number of entries for no stop announcements is far
    below what would be expected based upon assessment team
    observations.

17. While PAT appears to do a good job of commending drivers who make
    stop announcements, it appears that PAT takes limited remedial
    action with drivers who fail to make stop announcements. PAT took no
    action with 64 of 67 drivers who made no stop announcements at West
    Mifflin Garage in 1999.

### *Recommendations:* 

1.  It is recommended that PAT clarify its procedures to implement the
    stop calling policy to specifically require calling out all stops on
    the stop list. Stop lists should be available on a continual basis
    at each garage where the driver checks out to begin the run in
    addition to being distributed to drivers upon picking new work
    schedules.

2.  PAT should revise the stop lists to include all Downtown stops. To
    avoid an excessively long stop list, the list could include
    instructions to announce all stops between the first and last
    Downtown stops on the route.

3.  It is recommended that PAT review the LRT automated PA system to
    identify the cause of missing stop announcements and take corrective
    action.

4.  It is recommended that PAT fully test the automated stop
    announcement system before final acceptance from the equipment
    supplier to assure that stops are called at the correct location. An
    alternative procedure to use of the automated system for stop
    announcements in the CBD should be implemented if the automated
    system proves unreliable in this area. MTA should be prepared to
    quickly implement a back-up procedure, such as driver voice
    announcements, if needed.

5.  Should PAT specify a manual PA system in future bus procurements, it
    is recommended that PAT consider a hands-free microphone to
    facilitate use of the PA by drivers and eliminate maintenance
    associated with goosenecks.

6.  It is recommended that PAT re-instruct Quality Assurance Monitors in
    recording stop announcements to assure complete and accurate
    reporting.

7.  It is recommended that PAT implement a central reporting and
    monitoring system for tracking driver compliance to ADA stop
    announcement requirements (as opposed to the existing system of
    separate tracking at each garage).

8.  It is recommended that QAO reports from monitors be entered into a
    tracking system before distribution to garages for remedial action.

9.  PAT should consider more aggressive remediation of drivers who fail
    to make stop announcements. Otherwise, failure to make announcements
    may be considered an acceptable practice by many drivers. Likewise,
    PAT should continue to commend drivers that make stop announcements
    in compliance with PAT policy.

# Observations of Route Identification System

To determine PAT's current performance in identifying buses or
passengers at stops served by more than one route, the assessment team
collected the following information.

-   Information about PAT's policies and procedures on bus/passenger
    identification was collected and reviewed;

-   The Training Manager was interviewed and operator training materials
    were reviewed;

-   On Wednesday August 23, several drivers and two Service Delivery
    Managers were interviewed to verify their understanding of
    bus/passenger identification policies and operational practices;

-   The six riders with vision impairments who were interviewed were
    also asked about their experience with external bus announcements;

-   First-hand observations were made at six different transfer centers
    during the on-site visit.

## PAT Policies and Procedures Regarding a Route Identification System

PAT's policy and procedures regarding route identification are detailed
in the "Americans with Disabilities Act, Educational Manual and
Reference Guide."

*Where vehicles for more than one route serve the same stop, Port
Authority shall provide a means by which an individual with visual
impairments or other disabilities can identify the proper vehicle to
enter.*

The Guide further instructs the driver to identify the route number and
destination to 'persons with visual impairments or any other person who
may need assistance.' (See Attachment B.)

According to PAT management personnel, PAT's procedure for implementing
this policy is to have drivers make external announcements of route
number and destination at each stop shared by more than one bus route.

## PAT Training

The Training Manager indicated that operators are instructed to make
external announcements during the Operator Training Course. Two hours of
supplemental ADA training is planned for all operators.

## Monitoring and Discipline

Through PAT's Quality Assurance Program undercover riders observe
approximately 50 bus trips each week. Among the items the riders are
supposed to observe is whether the route is called at stops (See QAO
Form in Attachment C).

## Operator and Supervisor Interviews

In addition to senior managers, two supervisors and 13 drivers were
interviewed at the West Mifflin and Harmar garages. According to
supervisors at one garage, the drivers are instructed to identify their
route to a customer waiting at a bus stop if the customer appears to be
blind and to stop the bus even if the person is not at a bus stop. At
the other garage, the supervisors and trainers appeared to be unclear as
to the requirement to identify the bus route to passengers waiting at
stops that are shared by multiple routes. It appears that no instruction
is given to drivers to identify routes at stops by supervisors at this
garage. Most drivers interviewed indicated that they identify their
route to people who appear to be blind.

## Rider Experiences and Observations

Interviews with six blind and visually impaired riders resulted in
varying responses. Common complaints from riders include:

-   Drivers only call out route identification if the waiting passenger
    looks blind; i.e. carries a cane or is accompanied by a guide dog.

-   Often drivers will not open the doors and will pass by waiting
    passengers if they don't make a motion for the bus to stop.

-   Many interviewees indicated that drivers stop the bus away from the
    bus stop, causing the rider to miss the bus if he/she is unable to
    identify the route.

## Assessment Team Observations

At various times on Monday and Tuesday, assessment team members waited
at stops served by many bus routes to observe external route
identification. Observations were made at the following five locations:

-   Fifth & Smithfield

-   Penn Loop

-   Liberty & Wood

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-   Fifth & Tennyson

-   Ninth & Penn

A total of 41 buses were observed stopping at these locations. As buses
pulled in, reviewers would note the route number and the bus number.
They would then listen and observe to see if the bus operator made any
external announcement or otherwise identified the bus and route to
waiting passengers. Reviewers did not observe external announcements or
other identification at any of the sites by any of the buses observed.
Copies of the completed "Vehicle/Passenger Identification Assessment
Forms" completed by the reviewers are provided in Attachment E.

Although no buses equipped with active automated external route
identifications were observed as part of the assessment teams sample,
some were observed in operation. In those observations the external
route identification appeared to be quite clear and effective.

It should be noted that by virtue of Pittsburgh's topography and
corresponding bus route design many bus stops serve multiple routes.
This abundance of stops serving multiple routes provides a greater
challenge in announcing stops than for other major transit systems.

The automated external announcements on the LRT routes were observed and
the external announcements appeared to be clear and effective.

The assessment team was unable to identify any reported failure of
drivers to make external route identifications or associated remedial
action in PAT's QAO monitoring reports.

## Findings and Recommendations

### *Findings:*

1.  PAT's procedures, as expressed in the "Americans with Disabilities
    Act, Educational Manual and Reference Guide," appear to instruct
    drivers to announce route number and destination only to passengers
    who have visual impairments or appear to need assistance. In
    instances where individuals with visual impairments or other
    disability are not recognized as such by the driver, and the driver
    fails to identify the route, the individual may be unable to
    identify the correct vehicle to enter. PAT's procedures could result
    in failure to identify routes to individuals with visual impairments
    or other disabilities.

2.  Supervisors appear to be unclear as to the requirement to identify
    routes to customers waiting at bus stops that are served by multiple
    routes. In at least one garage, drivers are not instructed to make
    external announcements.

3.  Drivers interviewed do not appear to understand the requirements for
    external stop announcements. Many drivers indicated that they only
    make external route announcements if the passenger "looks" blind.

4.  External stop announcements were not made at bus stops shared by
    multiple routes for any of the 41 buses observed.

5.  Lack of clarity in route identification requirements makes it
    difficult for PAT to monitor performance through its QAO program and
    initiate remedial action with drivers.

### *Recommendations:*

1.  It is recommended that PAT consider revising its policy regarding
    route identification to require drivers to announce route number and
    destination to waiting passengers at all stops shared by more than
    one route. Such an approach would assure that all passengers with
    disabilities are able to identify the proper vehicle to enter.

2.  It is recommended that PAT's training program, including
    supplemental ADA training, emphasize the need for drivers to
    identify routes to **all** waiting passengers at stops shared by
    more than one route. The training program should identify the
    reasons for this requirement noting that some individuals with
    visual impairments or other disabilities, such as developmental
    disabilities, will not be recognizable to the driver. PAT should
    also provide training to driver supervisors and QAO monitors.

3.  Upon completion of training/retraining of all drivers in revised
    route identification requirements it is recommended that monitors
    carefully record driver performance on QAO reports and that the
    information be entered into a central monitoring database.

4.  It is recommended that PAT address failure of drivers to identify
    routes to waiting passengers at stops shared by multiple routes with
    retraining and/or progressive driver discipline as appropriate.

**Attachment A**

####### PAT Bus and Rail Routes

**Attachment B**

####### PAT ADA Policies on Stop Announcements 

####### and 

####### Vehicle Identification 

**Attachment C**

####### PAT Quality Assurance Program 

**Attachment D**

**Sample ADA Stop Announcement List**

**Attachment E**

**Vehicle Stop Announcement and Identification Tabular Data**

####### Attachment F 

####### 

####### Port Authority Letter 

**December 14, 2000**