Metro

**St. Louis, MO**

ADA Complementary Paratransit Service

Compliance Review

April 11-14, 2005

*Summary of Observations*

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, DC**

**Prepared by**

**Planners Collaborative, Inc.**

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**Final Report: February 5, 2007**

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**CONTENTS**

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

[II. Overview 3](#overview)

[III. Background 7](#background)

[IV. Summary of Findings 11](#summary-of-findings)

[V. ADA Complementary Paratransit Service Criteria
17](#ada-complementary-paratransit-service-criteria)

[VI. ADA Complementary Paratransit Eligibility
24](#ada-complementary-paratransit-eligibility)

[VII. Telephone Access 34](#telephone-access)

[VIII. Trip Reservations and Scheduling
40](#trip-reservations-and-scheduling)

[IX. Service Performance 46](#service-performance)

[A. Performance 48](#performance)

[B. Transportation Operations 59](#transportation-operations)

[X. Resources 64](#resources)

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*Attachment A.* St. Louis Metro Response

*Attachment B.* On-Site Review Schedule

*Attachment C.* Metro Call-A-Ride Brochure

*Attachment D.* ADA Paratransit Application

*Attachment E.* Metro Unconditional Eligibility Letter

*Attachment F.* Metro Conditional Eligibility Letter

*Attachment G.* Metro Not Eligible Letter

*Attachment H.* Metro Temporary Eligibility Letter

*Attachment I.* Metro Mobility Aid Not Eligible Letter

*Attachment J.* Call-A-Ride Plus Identification Card

*Attachment K.* "Public Transit Options for Customers with Disabilities"

*Attachment L.* ADA Paratransit Eligibility Appeals Process

*Attachment M.* Call-A-Ride Service Zones

*Attachment N* Analysis of Metro Data for Trip Disposition and On-Time
Performance

# Purpose of the Review

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Public entities that operate fixed route transportation services for the
general public are required by the U.S. Department of Transportation
(DOT) regulations implementing the Americans with Disabilities Act of
1990 (ADA) to provide ADA complementary paratransit service for persons
who, because of their disability, are unable to use the fixed route
system. These regulations (49 CFR Parts 27, 37, and 38) include six
service criteria, which must be met by ADA complementary paratransit
service programs. Section 37.135(d) of the regulations requires that ADA
complementary paratransit services meet these criteria by January 26,
1997.

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

The purpose of these reviews is to assist the transit agency and the FTA
in determining whether capacity constraints exist in ADA complementary
paratransit services. The reviews examine policies and standards related
to service capacity constraints such as those measured by on-time
performance, on-board travel time, telephone hold times, trip denials,
and any other trip-limiting factors. The reviews consider whether there
are patterns or practices of a substantial number of trip limits, trip
denials, early or late pickups or arrivals after desired arrival (or
appointment) times, long trips, or long telephone hold times as defined
by established standards (or typical practices if standards do not
exist). The examination of patterns or practices includes looking not
just at service statistics, but also at basic service records and
operating documents, and observing service to determine whether records
and documents appear to reflect true levels of service delivery. Input
also is gathered from local disability organizations and customers.
Guidance is provided to assist the transit operator in monitoring
service for capacity constraints.

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An on-site compliance review of ADA complementary paratransit service
provided by Metro Transit of St. Louis was conducted April 11 to 14,
2005. Planners Collaborative, Inc., located in Boston, Massachusetts,
conducted the review for the FTA Office of Civil Rights. The review
addressed compliance of Metro's ADA complementary paratransit service
with focus on one specific regulatory service criterion: the "capacity
constraints" criterion. Section 37.131(f) of the regulations requires
that ADA complementary paratransit services be operated without capacity
constraints.

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This report summarizes the observations and findings of the on-site
review of Metro's ADA complementary paratransit service. First, a
description of the approach and methodology used to conduct the review
is provided. Then, a description of key features of transit services
provided by Metro---light rail, fixed route, and ADA complementary
paratransit service---is provided. All of the findings of the review are
summarized in Section IV. Observations and findings related to each
element of the capacity constraint criteria are then presented in
Sections V through XI. Recommendations for addressing some of the
findings are also provided.

Metro was provided with a draft copy of the report for review and
response. A copy of the correspondence received from Metro on October
11, 2006 documenting their response to the draft report, is included as
Attachment A.

# Overview

The review addressed service elements that affect an ADA complementary
paratransit eligible person's ability to use the service as defined by
the DOT ADA regulations. While addressing service area and eligibility,
the review focused on compliance with the ADA complementary paratransit
capacity constraints requirements of the DOT ADA regulations. Several
possible types of capacity constraints are identified by the
regulations. These include "wait listing" trips, having caps on the
number of trips provided, or recurring patterns or practices that result
in a substantial number of trip denials or missed trips, untimely
pickups, or significantly long trips. Capacity constraints also include
other operating policies or practices that significantly limit the
amount of service to persons who are ADA complementary paratransit
eligible.

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To assess each of these potential types of capacity constraints, the
review focused on observations and findings regarding:

-   Trip denials and "wait listing" of trips

-   Trip caps

-   On-time performance

-   Travel times

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Observations and findings related to two other policies and practices
that can affect ADA complementary paratransit use also are provided,
including:

-   Determinations of ADA complementary paratransit eligibility

-   Telephone capacity

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ADA complementary paratransit eligibility determinations were assessed
to ensure that access to service was not adversely impacted by
inappropriate denials of eligibility for the service or unreasonable
delays in the eligibility process. Telephone capacity was assessed
because access to reservations and customer service staff is critical to
the effective use of any ADA complementary paratransit service.

The review also addressed scheduling, dispatch, and operation of service
as potential causes of, or contributors to, capacity constraints.
Similarly, adequacy of resources was reviewed as a potential contributor
to capacity constraints.

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**Pre-Review**

The review first involved the collection and examination of key service
information provided by Metro prior to the on-site visit. This
information included:

-   A description of how the ADA complementary paratransit service is
    structured.

-   Public information describing the ADA complementary paratransit
    service

-   A description of the St. Louis Metro's standards for on-time
    performance, trip denials, travel times, and telephone service

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Metro was requested to make additional information available during the
on-site visit. This information included:

-   Copies of completed driver manifests for the most recent six month
    period (for each carrier)

-   Six months of service data, including the number of trips requested,
    scheduled, denied, canceled, no-shows, missed trips, and trips
    provided by Metro

-   A breakdown of trips requested, scheduled, and provided

-   Detailed information about trips denied in the last six months
    including origin and destination information, day and time
    information, and customer information

-   On-time performance information

-   Detailed information about trips identified in the last six months
    with excessively long travel times

-   Telephone call management records

-   Records of recent customer comments and complaints related to
    capacity issues (trip denials, on-time performance, travel time, and
    telephone access)

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**On-Site Review**

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An on-site review of the service was conducted from April 11 to 14,
2005. The on-site review began with an opening conference, held at 9
a.m. on Monday, April 11, 2005. In attendance were the following:

*Metro representatives*:

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  Larry E. Salci            President & CEO

  Thomas Sehr               Executive Vice President, Administration

  Raymond A. Friem          Senior Vice President, Transit Operations

  Patricia Hall             Director ADA Services

  Janis Shetley             Chief of ADA Services

  Todd Plesko               
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*FTA review team*:

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  David Knight              FTA Office of Civil Rights

  Don Kidston               Planners Collaborative

  David Chia                Planners Collaborative

  Terry Regan               Planners Collaborative
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FTA Region VII, participating in the opening conference via telephone:

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  Mokhtee Ahmad             Administrator

  Paula Schwach             Regional Counsel

  Joan Roeseler             Team Leader - Office of Planning and Program
                            Development
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David Knight opened the meeting by thanking Metro for their cooperation
in the review. He described the purpose of the review and emphasized
that it was intended to assist Metro in providing effective ADA
complementary paratransit service. Mr. Knight outlined the steps in the
review process:

-   Preliminary findings and an opportunity to respond would be provided
    at a closing meeting on Thursday, April 14, 2005.

-   A draft report would be provided to Metro for review and comment.

-   Metro's comments would be incorporated into a final report, which
    would then become a public document.

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Don Kidston described the objective of the review to identify
significant impediments, if any, to people with disabilities receiving
the service to which their entitled under ADA, and to assist Metro in
improving service if warranted. He described the scope of the review as
including review of policies, procedures, practices, and performance
that can affect availability of effective service. The areas to be
addressed include service design criteria, eligibility, telephone
access, reservations and scheduling, operating procedures, practices and
performance, and adequacy of resources. Mr. Kidston went on to present
the schedule for the on-site review, including the parts of the
operation that would be observed by day. A copy of the review schedule
is provided in Attachment B. The review team conducted the review
generally in accordance with the review schedule.

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An exit conference was then held on Thursday, April 14, 2005 at 1 p.m.
Attending the exit conference were:

*Metro representatives*:

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  Thomas Sehr               Executive Vice President, Administration

  Raymond A. Friem          Senior Vice President, Transit Operations

  Patricia Hall             Director ADA Services

  Paul Willett              
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*FTA review team*:

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  David Knight              FTA Office of Civil Rights

  Don Kidston               Planners Collaborative

  David Chia                Planners Collaborative

  Terry Regan               Planners Collaborative
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FTA Region VII:

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  Cindy Terwilliger         Supervisory Senior Operations Manager

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Mr. Knight opened the exit conference by thanking the RTA staff for
their cooperation in the review. The review team members, including Mr.
Knight, then presented an overview of the review and initial findings in
each of the following areas:

-   Consumer input

-   Service design parameters

-   Eligibility determinations

-   Telephone access

-   Handling of trip requests and trip denials

-   Trip scheduling

-   On-time performance and service delivery

-   Trip duration

-   Operations

-   Resources (vehicles, manpower, and financial resources)

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The review team again thanked Metro for their cooperation during the
field review.

# Background

St. Louis Metro was established in 1949 through a Compact as the
Bi-State Development Agency. Establishment of Bi-State required passage
of Federal and Missouri and Illinois state legislation. Metro, or the
Bi-State Development Agency, is overseen by a Board of Commissioners
consisting of representatives of: the Governor of Missouri; St. Louis,
St. Charles and Jefferson Counties in Missouri; the City of St. Louis,
MO; and St. Clair County in Illinois.

St. Louis Metro provides public transportation service in the St. Louis
Metropolitan Region with Metro Bus, Metro Link, and Call-A-Ride. Through
an agreement between Metro and St. Clair County in Illinois, Metro is
responsible for operation of all Metro Link service including service in
both Missouri and Illinois. Metro is also responsible for operation of
Metro Bus routes, which are principally in Missouri. Madison County and
St. Clair County Transit Districts are responsible for operation of most
of the fixed route bus service in the Illinois portion of the Greater
St. Louis transit service area.

Metro is a member of a Transit Management Agency (TMA), with Call-A-Ride
providing both TMA and Metro services. Metro's principal Call-A-Ride
service is "Call-A-Ride Plus," which is Metro's ADA complementary
paratransit service. Metro also serves Medicare, Job Access Reverse
Commute, and other trips as a member of the TMA, Metro staff operates
Call-A-Ride directly without the assistance of contracted service
providers.

Trip requests are received and scheduled seven days a week at a Central
Call Center located at the Metro Main Repair Facility at 3300 Spruce
Street in St. Louis. Customers may call up to seven days in advance to
schedule trips. Trips are also dispatched at the Central Dispatch
Center.

**Metro ADA Complementary Paratransit Performance Standards**

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Metro has established the following service performance standards for
ADA complementary paratransit service:

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-   **Telephone response time**: Metro's goal for hold times, or "wait
    times in queue" is an average of 4.18 minutes. Metro does not have a
    standard for number or percentage of calls by increments of time in
    queue.

-   **Trip denials**: Metro's standard for trip denials is 0.

-   **On-time performance**: Metro's goal for on-time performance is
    94.6 percent, with an on-time trip defined as a trip that originates
    within 15 minutes before or after the scheduled pickup time
    (-15/+15). The computation of on-time performance includes counting
    trips picked up more than 15 minutes early as on time. Metro's
    policy is to pick up customers early only if the customers wish to
    board early. Additionally, Metro does not count a trip as late
    unless it is more than five minutes later than the on-time window,
    i.e., more than 20 minutes after the scheduled pickup time.
    Accordingly, for performance measurement, trips are considered on
    time if they are less than 20 minutes late (+20).

-   **Travel time**: Metro's travel time standards are a maximum travel
    time of 45 minutes for intra-zonal trips and 90 minutes for
    inter-zonal trips, with a goal of completing inter-zonal trips in 60
    minutes or less.

**Consumer Input**

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Prior to and during the on-site visit, the review team gathered input
from the perspective of consumers to assist the reviewers in identifying
regulatory issues of concern to consumers. Input was collected from
review of complaints on-file with FTA, consumer interviews, and review
of customer complaints on file with Metro.

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**Formal ADA Complaints Received by FTA**

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There were two closed complaints relating to Metro's ADA complementary
paratransit service on file with FTA. Both of the complaints addressed
eligibility issues. They focused on the length of time before a
determination of eligibility was received by the applicant.

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**Consumer Interviews**

During the two weeks before the on-site visit, a team member conducted
telephone interviews of nine users of Metro's ADA complementary
paratransit service. These consumer comments were used to gain a better
insight into, and identification of, issues to be addressed during the
site visit. Concerns raised during the interviews were as follows.

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**Eligibility determinations:** Several interviewees said that their
eligibility was not determined within 21 days of submitting a completed
application and they were not apprised of their rights to use the
service after 21 days until a determination of eligibility was made. One
said that because she was not assigned a Dial-a-Ride number, Call-A-Ride
reservationists were not able to schedule a ride for her.

**Half-hour window:** Several interviewees were unclear as to the
application of the 30 minute pickup window used for scheduling vehicle
arrivals. Metro advises customers to be ready to board the vehicle 15
minutes before or after the scheduled time (-15/+15). Interviewees
believed that they were expected to be ready to board vehicles 30
minutes before the schedule time they were given.

**Telephone Access:** Most interviewees complained that the amount of
time required to make a reservation was too long. This included both a
long wait time when the caller was on hold and a long time involved in
making a reservation after the call was answered.

**Time vehicle would wait before leaving:** Several interviewees
complained that the van driver did not wait a full three minutes for the
person to get to the van, as described in Metro procedures. Several
commented that they wanted Metro's dispatcher to give them a call if
they were not at the stop, or if they were at the location but the
driver did not see them, in order to avoid missed connections. When the
driver leaves without waiting, the rider is assessed a penalty as a
no-show for the scheduled trip.

**Inappropriate transfer station locations:** Several interviewees
complained that the locations being used as transfer points between
vehicles were not appropriate places for ADA complementary paratransit
customers. They felt that locating the transfer stations at busy, noisy
locations was uncomfortable and disorienting for customers who have
certain disabilities, such as blindness.

**Removal of the voucher program:** Several interviewees complained
about the discontinuation of the voucher program that let passengers pay
with a voucher rather than cash. Several of the interviewees have
trouble handling cash, a problem that vouchers addressed.

**Rudeness of administrators:** Several interviewees complained that the
senior program administrators "had an attitude" and would not listen to
suggestions from the community.

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**Rider Comments on File at Metro**

Metro receives consumer comments for all of its services through three
media: telephone, e-mail, and written letters. The majority of comments
are made by telephone to the Metro Customer Service Center.

If a complaint is received by Metro through its central call center, the
complaint is forwarded to Call-A-Ride for investigation and resolution.
When a complaint is received at Call-A-Ride headquarters, the complaint
is entered into its database and the complaint is given to the
Operations Manager to investigate. There is no standard procedure for
following up with the customer on the resolution of the complaint. If
there is further customer communication, most times it is by way of a
phone call.

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During the site visit, the team reviewed complaints for the period from
July 1, 2004, through March 31, 2005. During this nine-month period
there were a total of 69 complaints received concerning Call-A-Ride
service. Table III.1 lists categories of complaints by month for the
nine-month period. The most frequent complaint categories were service
contact, operator behavior, equipment, and administration.

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[Table III.1  Call-A-Ride Complaints Reported to Metro: July, 2004 --
March 2005]{.mark}

  -------------------- ---------- --------- --------- --------- --------- --------- ---------- --------- --------- ----------- ----------
  **COMPLAINT**        **2004**                                                     **2005**                       **TOTAL**   

  **CATEGORY**         **JUL**    **AUG**   **SEP**   **OCT**   **NOV**   **DEC**   **JAN**    **FEB**   **MAR**   **No.**     **% by
                                                                                                                               cat.**

  **Service Contact**  4          4         2         3         6         9         1          2         1         **32**      **46**

  **Operator           0          2         4         0         2         2         7          4         4         **25**      **36**
  Behavior**                                                                                                                   

  **Equipment: Van**   0          1         0         0         2         0         2          1         0         **6**       **9**

  **Administration**   2          0         0         1         3         0         0          0         0         **6**       **9**

  **Totals**           **6**      **7**     **6**     **4**     **13**    **11**    **10**     **7**     **5**     **69**      **100%**
  -------------------- ---------- --------- --------- --------- --------- --------- ---------- --------- --------- ----------- ----------

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The two categories that comprise the vast majority of complaints are
service contact and operator behavior.

1.  Complaints within **service contact** include:

-   Late vehicles

-   Vehicles not arriving

-   Proposed schedule changes

-   Customer appealing of a penalty

-   Miscellaneous service issues

2.  Subcategories under **operator behavior** include:

    -   Driver being rude to the customer

    -   Speeding or reckless driving (predominantly from non-passengers)

    -   Leaving the van unattended

    -   Detouring from the route

    -   Miscellaneous operations conduct

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**Observations**

The Metro complaint procedure does not include provision for
communicating the disposition of complaints to customers. When there is
follow-up communication with customers it is usually through a phone
call. The absence of a feedback loop can be construed by the complainant
that they are not being heard or that there is no interest in their
complaint, thereby discouraging customers from raising service or other
issues with Metro.

Metro maintains two separate comment tracking systems for comments about
Call-A-Ride: one at Metro headquarters; and one at Call-A-Ride offices.
Metro and Call-A-Ride maintain separate databases to track the comments
and complaints. The two databases are not integrated, but are separate,
stand-alone systems. Duplicate systems can result in redundancy of
effort and can impede understanding system-wide customer concerns.

Although not a regulatory issue, Metro may wish to consider modifying
its complaint tracking procedures to include a timely response to
customers as a means of improving customer relations and communications
and encouraging customer feedback. A central complaint system can
eliminate redundant tracking of complaints and facilitate a company-wide
approach to customer service.

# **Summary of Findings**

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The following summarizes the findings made as a result of the review.
The findings are observations of policies, procedures, practices and
performance related to delivery of service as required by DOT ADA
regulations at the time of the review. Findings may be positive,
neutral, or identify opportunities to improve service. The bases for
these findings are presented in other sections of this report. Findings
of opportunities to improve service should be used to identify
corrective actions proposed by Metro. Recommendations are also included
in the body of the report for Metro's consideration in developing
corrective actions.

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**A. ADA Complementary Service Criteria**

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1.  The Metro ADA complementary paratransit service area includes all
    locations in St. Louis City and St. Louis County, within 3/4-miles
    of all Metro fixed route services.

2.  Metro does not provide Call-A-Ride Plus service to service areas
    within 3/4-miles of Metro Link Stations that it serves in Illinois.

3.  Metro and ATS effectively coordinate interregional service for ADA
    complementary paratransit eligible customers. It is a seamless
    process for riders, including reservation and fare payment.

4.  Metro Call-A-Ride Plus service schedule does not include service for
    all days and hours of scheduled service for several Metro Bus
    routes.

5.  For trips of two or three zones, it appears that the Call-A-Ride
    Plus fare of \$3.50 can be more than two times the fare of a
    comparable fixed route trip on Metro by a typical user, if that user
    is traveling without a transfer on Metro Link one of the many Metro
    Bus routes that serve multiple Call-A-Ride zones.

6.  The transfer charge for Call-A-Ride Plus trips that include
    transfers to fixed route service can further increase the difference
    between Call-A-Ride Plus fares and fixed route fares for trips with
    the same trip origin and destination.

**B.** **ADA Complementary Paratransit Eligibility**

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1.  Metro's policy is to make determinations of ADA complementary
    paratransit eligibility based on whether the applicant's mobility
    aid meets the definition of a "common wheelchair." This
    determination fails to make the distinction between the eligibility
    of the applicant and the applicant's mobility aid. The determination
    of eligibility should be made solely based on the applicant's
    ability to use fixed route service as addressed in 49 CFR §37.123,
    and not on the mobility aid that the applicant uses. The decision to
    limit service to mobility aids that meet the definition of a common
    wheelchair should be addressed by Metro as a separate issue from
    eligibility.

2.  Based on review of a sample of 34 applications for Metro's
    Call-A-Ride service submitted during 2004 and 2005, the
    determinations made by Metro seem reasonable. Other than the policy
    regarding common wheelchairs, Metro's eligibility determination
    process does not appear to deny or restrict ADA complementary
    paratransit service to eligible individuals.

3.  Approximately 25 percent of applicants receive conditional
    eligibility. At the time of the on-site review Metro provided
    service to individuals who have conditional eligibility as if they
    had unconditional eligibility. As a result, any rider with
    conditional eligibility could be scheduled for any trip requested.

4.  Metro has defined its eligibility process such that the application
    is complete after the in-person assessment. Based on this standard,
    Metro made determinations within 21 days for only 4 of the 12
    applications in the review team's sample of applications filed
    between March and December of 2004. Four applications took at least
    90 days and two applications took up to 170 days. In a February 2005
    sample, Metro greatly improved the timeliness of its application
    processing, making determinations for 20 of 22 completed
    applications within 21 days.

5.  The time from submittal of a written application and an in-person
    interview is significant and could be an impediment to ADA
    complementary paratransit eligible individuals obtaining access to
    service. The average number of days in the 2004 sample was 63 days
    between receipt of written application and the in-person assessment.
    This decreased to 33 days in the 2005 sample. Metro did not have any
    documentation to identify the reason for the extended period between
    application submission and in-person assessment.

6.  The DOT ADA regulations (49 CFR §37.125 (c)) requires that
    applicants be treated as eligible for service if a determination of
    eligibility has not been made within 21 days following the
    submission of a complete application. The application and other
    public information provided by Metro do not inform applicants of
    their right to service if they have not received a determination on
    their completed application within 21 days.

7.  Metro has a process in place for appealing eligibility
    determinations. However, as of the time of the review team's site
    visit, there had not been a formal appeal for more than three years.
    As a result it was not possible to review determinations made on
    requests for appeal.

8.  In its letter to applicants who are determined ineligible for ADA
    complementary paratransit service, Metro does not provide specific
    reasons for why the applicant is determined ineligible for service.
    Absence of such information could impede applicant's decision on
    whether or not to appeal the determination.

9.  In its letter to applicants who receive temporary eligibility for
    ADA complementary paratransit service and in its letter to
    applicants who are denied eligibility for ADA complementary
    paratransit service because the mobility aid that they use, Metro
    does not refer to or include information on its appeals process. As
    a result, applicants who are determined ineligible may not be aware
    of their right to appeal the decision.

10. Metro's appeals process description states, "Appeals must be made in
    writing" and "The written appeal should state the reason or reasons
    you believe the determination to be incorrect." To require the
    appeal be made in writing and state the reason for the appeal could
    deprive the appellant of an opportunity to be heard and present
    information and arguments that the appellant would otherwise have if
    the appeal were made orally and without advance written reasons.

11. Metro's Director of ADA services handles request for appeals on an
    informal basis. The Director of ADA services has the formal
    responsibility for approving all initial eligibility determinations.
    This practice is at variance with the requirements of the DOT ADA
    regulations that decisions on appeals be made by a person not
    involved in the initial decision to deny eligibility, or "separation
    of functions."

12. Finding withdrawn (see Reporting Chart accompanying the Final
    Report).

13. Metro considers same day cancellations in its procedure for service
    suspensions. The DOT ADA regulations allow transit systems to
    suspend service for a reasonable period for riders who abuse the
    system by regularly "no-showing" for scheduled trips. While transit
    agencies have in recent years also considered "late cancellations"
    to be an abuse of the system and have considered this in their
    suspension policies, the effects of a late cancellation should be
    operationally equivalent to a no-show in terms of the negative
    impact on the service. Cancellations made several hours in advance
    of the scheduled pick-up time would still seem to allow the system's
    dispatchers to use the open vehicle time to respond to same-day
    operating issues. Accordingly, same day customer cancellations made
    several hours before the scheduled time should not be considered as
    a basis for suspending customer service.

14. Metro's ID card for ADA complementary paratransit service includes
    condition codes for individuals who are conditionally eligible.
    However, the card does not provide an explanation for these codes.

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**C. Telephone Access**

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1.  Metro's policy goal of average times in queue of 4.18 minutes likely
    results in many calls in queue for periods of time well in excess of
    4.18 minutes and would appear to significantly limit ADA
    complementary paratransit customers' ability to use Call-A-Ride
    service.

2.  During the week of February 7 to 11, 2005, Metro received a total of
    4,053 calls to the reservation center. Daily average hold times for
    the four phone lines ranged from 0.65 minutes to 2.45 minutes. Of
    the 4,053 calls, 737 were abandoned by the caller for an abandonment
    rate of 18 percent. This high abandonment rate is an indicator of
    difficulty in getting through on the phone lines to make
    reservations. Call Center staffing and equipment limits may be
    contributing to long hold times and high abandonment rates.

3.  The review team observed 76 calls during the two-day period of April
    12 and 13, 2005. These calls averaged over seven minutes to
    complete. The reservations system being used at the time of the
    review appeared to be antiquated and slow, contributing to the long
    call times. Metro was in the process of upgrading its computer
    reservations system with a scheduled implementation during the
    summer of 2005.

4.  Metro's advertised Call-A-Ride reservations hours are 7:30 a.m. to
    4:30 p.m. During the review, the Reservations Center closed at 4:21
    p.m., based on a wall clock that was nine minutes fast.

5.  Any calls left in the queue at the end of the day were abandoned. As
    a result, some customers calling before 4:30 p.m. are not being
    served.

6.  Metro accepts only four one-way trip requests per call during peak
    call times. This policy can increase the length of telephone queues
    by requiring reservationists to handle multiple calls rather than
    one to serve one customer and placing multiple calls rather than one
    in the phone queue.

7.  Metro tracks performance by measuring the callers' average time in
    the telephone queue. This performance measure does not capture the
    number of callers that have significantly long hold times, which
    provides a better index of customer service and telephone access.

8.  It is Metro's practice for reservation clerks to rotate into the
    dispatch center and handle customer assistance calls. This appears
    to be very beneficial because it allows the reservation clerk to
    understand additional aspects of the reservation process and gives
    the clerk a greater sensitivity to the customer's needs.

    D.  **Trip Reservations and Scheduling**

[]{.mark}

1.  Metro's web site and the Metro Call-A-Ride brochure dated June 28,
    2004, advise Call-A-Ride customers to "phone at least 24 hours in
    advance to schedule your trips." The DOT ADA regulations (49 CFR
    §37.131(b)) requires the transit entity (Metro) to schedule and
    provide trips in response to a request for service made the previous
    day.

2.  At the time of the review team's on-site visit, Metro regularly
    denied trip requests for ADA complementary paratransit service due
    to capacity constraints. The proportion of denials was generally two
    percent of total demand on weekdays. Of these denials approximately
    20 percent were for next day service requests and 80 percent were
    for service requests two or more days in advance of the service day.
    Metro managers said that many of the riders who have their trip
    requests denied call back on a subsequent day and get a trip.
    However, Metro has not tried to document this number, and it is not
    without significant effort on the part of the rider.

3.  Many trips denied early in the scheduling period can be scheduled
    later in the scheduling period as a result of trip cancellations
    and/or route modifications made by proofers. Denial of such trip
    requests precludes them being served unless the customer calls again
    at a later time to request the trip.

4.  The Metro scheduling software does not include a function to
    schedule trips to meet appointment times. Reservationists record
    appointment times requested by callers in the software system and
    can attempt to place the trip on the run they feel is most
    appropriate. However, Metro has not set up PASS to schedule by
    appointment time.

**E.1 Service Performance**

1.  Metro's policy standard for service denials does not appear to
    consider all denials. Metro's policy standard is zero denials for
    requests made the previous day. Metro accepts service requests seven
    days in advance of the service day, and "Metro Call-A-Ride Easy
    Trips" brochure encourages customers to call early to make trip
    reservations. Denying a trip more than one day in advance of the
    service day, thereby requiring multiple calls to schedule a trip,
    appears to limit access to the service and constitute a capacity
    constraint.

2.  The review team's analysis of a one-day sample indicates that 42 (2
    percent) of trip requests for service on February 9, 2005 were
    denied. During the period June through December 2004 Metro reported
    next day denials of 0.6 percent. Metro indicated that some customers
    who are denied service more than one day in advance of the service
    day call back and eventually reserve their requested trip.

3.  Metro appears to have no policy for missed trips.

4.  Based upon a review of Call-A-Ride data reports for February 9,
    2005, it appears that Metro does not record missed trips as a
    category for performance monitoring purposes. Missed trips appear to
    be grouped with customer no-shows and late cancellations.

5.  Analysis of data for the sample day indicated that for 10 trips (0.6
    percent of the 1,752 ADA trips dispatched on the service day) that
    were not completed, the vehicle arrived at the pickup address more
    than 15 minutes after the scheduled time. For 47 trips (2.7 percent)
    that were not completed, there was no vehicle arrival time. All of
    these trips could be missed trips---resulting in as many as 57 (3.3
    percent) missed trips. Some of these trips could also be late
    cancellations.

6.  Metro has two standards for on-time performance. For the customer,
    the standard for on-time is a vehicle arrival between 15 minutes
    before and 15 minutes after (-15/+15) the scheduled time. For
    performance measurement and reporting the standard is 15 minutes
    before and 20 minutes after (-15/+20) the scheduled time. Use of one
    standard for the customer and a more generous standard for
    performance measurement overstates the level of service being
    provided to the customer.

7.  Based on an on-time window of 15 minutes before to 15 minutes after
    (-15/+15), 93.7 percent of customers were picked up either early or
    on-time, and 6.3 percent of customers were picked up late on the
    sample day. Of the late trips, 19 (1.2 percent of completed trips)
    were more than 15 minutes late and, of those, 3 (0.2 percent) were
    more than 30 minutes late. Based on this sample there do not appear
    to be a significant number of substantially late pickups.

8.  On the sample day, there were 260 passengers (15.9 percent of
    completed trips) picked up early. Of that number, 28 (1.7 percent of
    completed trips) were picked up more than 16 minutes early; of those
    trips, 10 (0.6 percent of completed trips) were picked up more than
    30 minutes early. Very early pickups could indicate that customers
    are being pressured to accept early departures.

9.  Of 739 trips with scheduled drop-off or appointment times, 617 (83.5
    percent) were early or on-time and 122 (16.5 percent) were late. Of
    these late drop-offs, 34 (4.6 percent) were more than 15 minutes
    late; of this number, 18 (2.4 percent) were more than 30 minutes
    late. These late drop-offs, potentially resulting in late arrivals
    for work, school, or medical appointments, could be considered a
    constraint to use of the service by paratransit eligible
    individuals.

10. From a sample of 26 long trips on February 9, 2005, 14 (0.9 percent
    of the completed trips) exceeded Metro's standard of 90 minutes for
    intra-zonal trips. 15 (0.9 percent) of the 29 long trips sampled
    were more than 30 minutes longer than a comparable fixed route trip
    and 7 (0.4 percent) were more than 46 minutes longer. Five of the
    trips that were more than 30 minutes longer than a comparable fixed
    route trip were to or from the same location. This appears to be a
    pattern of significantly long trips.

**E.2 Transportation Operations**

1.  Dispatchers appear to monitor and control service so as to avoid
    missed trips and maintain a high level of on-time performance.

2.  Dispatchers appear to have effective procedures in place to minimize
    customer no-shows. Dispatchers attempt to contact passengers if
    drivers are unable to find them at the pickup location.

3.  Metro has a "no strand" policy for riders with return trips. If a
    rider calls after the vehicle has left, Metro will not record this
    as a passenger no-show, but will re-classify the trip as a will-call
    for later pickup.

4.  Metro appears to have the capacity to accommodate some trips that
    could not be scheduled before the service day by assigning those
    trips to "Route 0," as well as using capacity made available from
    cancellations and available on the "clean up" runs. This capacity
    could be used to reduce or eliminate trip denials.

5.  Call-A-Ride appears to have sufficient dispatch coverage to
    effectively monitor and control service.

6.  Drivers appear to be well trained and have the resources including
    vehicles and dispatch support to perform their job.

7.  Drivers cited illogical routing and tight schedules as a concern.

[]{.mark}

**F. Resources**

1.  Staffing of the Call-A-Ride call center appears to limit access by
    customers to reserve trips. New reservations software and procedural
    changes to reduce call volume should increase efficiency of the
    reservations process, but additional staffing will likely be
    required to reduce hold times to a level that does not significantly
    impeded access to service.

2.  Equipment and staffing of scheduling, dispatch, and transportation
    service appear to be adequate to provide effective service at
    current levels of demand.

3.  Increased demand for service may require an increase in the number
    of runs and associated increases in the number of drivers and
    vehicles.

4.  Budget increases in recent years appear to be responsive to the need
    to meet unserved demand for service (trip denials).

# ADA Complementary Paratransit Service Criteria

The review team compared Metro's ADA complementary paratransit service
with its fixed route service to determine whether it is comparable, with
respect to the DOT ADA regulations as cited, in the following areas:

-   Service area (49 CFR 37.131(a))

-   Days and hours of service (49 CFR 37.131(e))

-   Fares (49 CFR 37.131(c))

The review team analyzed consumer complaints; assessed information
distributed to riders; reviewed Metro policies regarding service area,
days and hours, and fares; and interviewed Metro staff.

The two complaints filed with FTA did not mention service criteria as an
issue.

Several consumers contacted during the pre-assessment expressed concerns
with transfer locations and the voucher fare program. Several
interviewees complained that the locations being used as transfer points
between vehicles were not appropriate places for ADA complementary
paratransit customers. They felt that locating the transfer stations at
busy, noisy locations was uncomfortable and disorienting for customers
who have certain disabilities, such as blindness. In addition, several
interviewees complained about the discontinuation of the voucher program
that let passengers pay with a voucher rather than cash. Several of the
interviewees have trouble handling cash, a problem that vouchers
addressed. However, neither of these complaints addressed the service
area or the fare rates, only the methods used to provide service
throughout the area and collect fares.

In addition, of 69 complaints on file with Metro during the nine month
period from July 1, 2004, through March 31, 2005, none specifically
addressed service area, hours, or fares.

[]{.mark}

**Description of Fixed Route Service**

[]{.mark}

MetroLink is a 28-station light rail system that operates between
Lambert Airport Main Station, northwest of the city center, and
Shiloh-Scott Station, east of St. Louis in Shiloh, Illinois, by way of
downtown St. Louis and East St. Louis. Service frequency ranges from six
minutes during peak weekday time periods up to 30 minutes during
off-peak weekday and early and late weekend time periods. Some trains in
Illinois do not continue to the eastern terminus station (Shiloh-Scott)
at Southwestern Illinois College. Service on holidays is operated on a
modified schedule. Weekday service begins with an eastbound train
departing Metro Park Station at 3:24 a.m., and ends with an eastbound
train terminating at Shiloh Clark Station at 1:02 a.m.

MetroBus operates on 68 routes. Thirteen of these 68 routes provide
express service and all 68 routes operate in Missouri. Each route begins
and ends service at different times of the day with service beginning as
early as 4:10 a.m. and ending after 1:30 a.m.

Metro's fare schedule displayed on its web site at the time of the
review was as follows:

  ----------------------------------------------- ------------ ------------
  []{.mark}                                       **Full       **Reduced
                                                  Fare**       Fare**

  **Local and Express MetroBuses or MetroLink**   **\$1.50**   **\$0.75**

  **Single-Use Transfers**                        **\$0.25**   **\$0.10**
  ----------------------------------------------- ------------ ------------

 

  ---------------------------------------------- -------------------------------- -------------
  **Passes/Multiple Tickets**                    **Full Fare**                    **Reduced
                                                                                  Fare**

  **Lambert Airport Ticket Vending Machines      **\$3.00**                       **\$1.50**
  \[TVMs\] (includes single-user transfers)**                                     

  **10-Ride Ticket Books or 10 TVM Tickets       **\$15.00**                      **\$7.50**
  (includes one single-use transfer per                                           
  ticket)**                                                                       

  **One-Day Pass**                               **\$4.00**                       **\$4.00**

  **Weekly Pass**                                **\$15.50**                      **n/a**

  **Monthly Pass**                               **\$50.00**                      **\$25.00**

  **10-Ride Student Tickets (includes one        **\$10.00**                      **n/a**
  single-use transfer per ticket)**                                               

  **Student Semester Pass**                      **\$110.00**                     **n/a**

  **College Universal Pass**                     **Free from                      
                                                 [SWIC](http://www.swic.edu/),    
                                                 [UM-St.                          
                                                 Louis](http://www.umsl.edu/)**   
  ---------------------------------------------- -------------------------------- -------------

  -----------------------------------------------------------------------
  Full fares apply to customers over the age of 13.

  Reduced fares apply to children between the ages of 5 and 12. Customers
  over the age of 65 (Seniors) and customers with disabilities must also
  present their Metro Reduced Fare ID Card, Medicare Card, or Metro ADA
  Paratransit card.

  Children under the age of 5 ride free.

  **The single-use transfer** is valid for two hours and only one
  transfer between MetroBuses, or to transfer from a MetroBus to
  MetroLink to a second MetroBus. (Examples of the transfer use would be
  to travel on a Grand bus to MetroLink to a Dorsett-Lackland bus or to
  use the Grand bus and transfer to a Martin Luther King bus.) The
  transfer should be retained for the entire trip as proof of payment.

  **A One-Day Pass** is good from midnight to midnight on the date of
  issuance

  **Weekly Passes** are good for a fixed period beginning on Monday and
  ending on Sunday.

  **Student 10-ride ticket** books are sold at elementary, junior and
  high schools. Students up to age 19 can use them on MetroTransit until
  10 p.m. Monday through Friday.

  **Student Semester Passes** are available at participating colleges and
  universities
  -----------------------------------------------------------------------

The adult full fare for Metro service is \$1.50 with a transfer charge
of \$0.25. The full adult fare from the two Lambert Airport Stations is
\$3.00 including transfers.

Metro offers pass and ticket sales through its web site as follows:

-   Monthly Pass: \$50

-   Monthly Reduced Pass Reduced fares (apply to seniors age 65 and
    over) and disabled persons with proper identification, including
    Medicare or Bi-State identification cards: \$25

-   One Day Pass: Valid for unlimited riding for date revealed on
    regular MetroBus and MetroLink service. Not valid on seasonal
    services, Call-A-Ride or Call-A-Ride Plus: \$4

-   Ten-Ride Ticket Booklet: Valid for 10 rides before expiration date
    on all regular MetroBus, MetroLink and Illinois service: \$15

[]{.mark}

MetroLink is a proof of payment system. Tickets can be purchased at
vending machines on MetroLink station platforms. Pre-purchased tickets
must be time and date stamped using validation machines located at the
station platforms. Metro security personnel randomly check passenger
tickets at station platforms and on trains. Anyone riding without such a
proof is subject to a citation and fine.

[]{.mark}

**Description of the ADA Complementary Paratransit Service**

[]{.mark}

Metro provides Call-A-Ride Paratransit Services. Call-A-Ride operates as
a division of a regional Transportation Management Association (TMA).
Call-A-Ride serves a number of different clients, including: ADA
complementary paratransit eligible customers, the general public, and
Medicaid eligible customers. Service for ADA eligible customers is
referred to as Call-A-Ride Plus. Metro estimates that approximately 90
percent of Call-A-Ride customers are ADA eligible. Among the TMA clients
are the Department of Mental Health and other social service agencies.
Call-A-Ride also operates Job Access Reverse Commute service.

The Metro Call-A-Ride Brochure dated June 28, 2004, (Attachment C)
includes a map of the service area for both Call-A-Ride and Call-A-Ride
Plus service. Together, the two services cover all of St. Louis City and
St. Louis County. The six zones are broken out as follows:

-   Zones 4 and 5 are comprised of all of St. Louis City and the close
    in portions of St. Louis County. Service in St. Louis City is always
    limited to Call-A-Ride Plus service. Service in the St. Louis County
    portions of zones 4 and 5 is limited to Call-A-Ride Plus service
    weekdays, but is open to the general public on weekends.

-   Zone 1 (North County), Zone 2 (West County), and Zone 3 (South
    County), make up the outlying areas where there is both Call-A-Ride
    Plus service as well as dial-a-ride service available to the general
    public.

-   Zone 6, Far West County, offers additional limited service,
    available weekends only, and open to the general public.

Service hours are from 4:00 a.m. to 1:30 a.m. on Monday through Friday
and from 5:00 a.m. to 1:30 a.m. on Saturday and Sunday in Zones 4 and 5.
In Zones 1, 2, and 3 service hours are 6:00 a.m. to 12:00 Midnight on
Monday through Friday. On Saturday and Sunday service in Zones 1, 2, 3,
and 6 operates from 6:00 a.m. to 10:00 p.m.

ADA complementary paratransit fares are \$3.00 within one zone and
\$3.50 between zones.

Metro staff provides all Metro Call-A-Ride services, including
reservations, scheduling, dispatching, and operation of services.
Reservations, customer information, scheduling, and dispatching are
provided by Metro staff at a centralized call center located at the
Metro Main Repair Facility at 3300 Spruce Street in St. Louis.

[]{.mark}

Call center hours are 7:30 a.m. to 4:30 p.m. seven days a week. Calls
are received through a central ACD phone system. Paratransit Reservation
Clerks and Dispatchers take customer calls to reserve trips and answer
service questions. Trips are scheduled using the Trapeze Paratransit
Automated Scheduling System (PASS).

Call-A-Ride vehicle dispatching is performed from a dispatch center also
located at the Metro Main Repair Facility. Each Call-A-Ride vehicle is
equipped with a two-way radio and a mobile data terminal (MDT). Metro
has a dedicated channel for voice communication and two channels for the
MDTs.

[]{.mark}

**Service Criteria Observations**

[]{.mark}

**Service Area**

The DOT ADA regulations require that ADA complementary paratransit
service be available within 3/4-mile of all bus routes, and within
3/4-mile of all rail stations (49 CFR §37.131(a)).

The review team compared the map of the Call-A-Ride Plus service area
contained in the Metro Call-A-Ride brochure (Attachment C) to a map of
St. Louis Metro's fixed route service, with an overlay of a 3/4-mile
corridor on either side of all routes. This map was provided by the
Metro Planning Department. The six Call-A-Ride Plus zones cover all bus
routes and surrounding 3/4-mile area. However, Metro provides fixed
route service in Illinois, via MetroLink. This service is operated by
Metro but is outside the Call-A-Ride Plus service area. As the MetroLink
operator, Metro has the responsibility of providing ADA complementary
paratransit service within 3/4-miles of MetroLink stations in Illinois
during the same days and hours that MetroLink service operates to those
stations. Illinois MetroLink ADA complementary paratransit service can
be provided by Metro Call-A-Ride or by St. Clair County and/or Madison
County Transit Districts on behalf of Metro.

[]{.mark}

Regarding interregional trip requests between St. Louis and East St.
Louis, served by ATS of St. Clair County, Illinois, the review team
noted that Metro and ATS coordinate service between the service areas.
It is a seamless process for riders, including reservation and fare
payment.

[]{.mark}

**Days and Hours of Service**

The DOT ADA regulations require that ADA complementary paratransit
service be available during the same hours and days as fixed route
service (49 CFR §37.131(e)).

[]{.mark}

Table V.1 shows the hours of operation of Call-A-Ride Plus, as
communicated to the public in the Metro Call-A-Ride brochure.

A reviewer examined the time of the first and last bus pull-in and
pull-out for fixed route passenger service for Brentwood and DeBaliviere
Garages. The data, which was provided by Metro's Planning Department,
was reviewed to determine whether Call-A-Ride service hours are cover
those of fixed route service.

**Table V.1** Call-A-Ride Plus Hours of Operation

+-----------------------------+----------------------------------------+
| Zone 4 & 5                  | Mon -- Fri: 4 a.m. -- 1:30 a.m.        |
|                             |                                        |
|                             | Sat -- Sun: 5 a.m. -- 1:30 a.m.        |
+-----------------------------+----------------------------------------+
| Zone 1, 2, & 3              | Mon -- Fri: 4 a.m. -- 12 Midnight      |
|                             |                                        |
|                             | Sat -- Sun: 6 a.m. -- 10 p.m.          |
+-----------------------------+----------------------------------------+
| Zone 6                      | Sat -- Sun (only): 6 a.m. -- 10 p.m.   |
+-----------------------------+----------------------------------------+

[]{.mark}

Several Metro bus routes are in operation before or after Call-A-Ride
Plus service is available, as defined in Table V.1 above. In the central
Zones 4 and 5, this includes, but is not necessarily limited to:

-   The weekday service of the 4, 70, 93, and 97 routes all have
    scheduled stops listed as later than 1:30 a.m., while Call-A-Ride
    Plus service hours end at 1:30 AM.

-   On Saturday mornings, 13 routes begin revenue service (4, 10, 11,
    30, 32, 52, 70, 74, 80, 93, 94, 95 and 97) before 5 a.m. The Route
    40 Broadway, for example, makes its first pickup at the Riverview
    Shopping Center at 4:10 a.m. Call-A-Ride Plus weekend service begins
    at 5 a.m.

-   On Saturday evenings, service on both the 93 and 97 routes is
    provided later than 1:30 a.m., when Call-A-Ride Plus service ends

[]{.mark}

Next the review team checked the schedules of sample bus routes that run
through the outer Zones 1, 2, 3, and 6, where Call-A-Ride, and thus
Call-A-Ride Plus, service hours are more restricted. Again, the team
found additional instances of fixed route bus service scheduled outside
Call-A-Ride service hours, including, but not necessarily limited to:

-   The 32 Wellston-M.L. King Route has scheduled stops in Zone 1
    earlier than 5 a.m., and later than 12 Midnight on weekends.
    Call-A-Ride Zone 1 service hours are 6 a.m. to 10 p.m.

-   Similarly, route 52 Clayton South County has nine runs on Saturday
    and Sunday through Zone 3 outside the hours that Call-A-Ride is
    offered.

In addition, in Zone 6, where Metro has only weekend Call-A-Ride
service, the Chesterfield Connector II operates during weekdays to the
Spirit of St. Louis airport, while Call-A-Ride, according to the
brochure, does not.

**Fares**

DOT ADA regulations allow operators to charge a fare for ADA
complementary paratransit service that is up to twice that charged on
fixed route service for the same origin and destination at the same day
and time (49 CFR §37.131(c)). According the brochure, Call-A-Ride Plus
has a zone-based fare structure, as outlined in Table V.2. Attendants
ride for free. Companions pay under the same fee structure as
ADA-eligible riders.

[]{.mark}

**Table V.2 Call-A-Ride Plus Fares**

  ----------------------------------- -----------------------------------
  **Trip Distance**                   **One-way Fare**

  1 Zone                              \$3.00

  2 Zones                             \$3.50

  3 Zones                             \$3.50
  ----------------------------------- -----------------------------------

[]{.mark}

The base fare for Metro Bus or Metro Link is \$1.50, with an additional
25 cents for a transfer within two hours. A transfer to Metro Bus or
Metro Link from Call-A-Ride Plus is a 10-cent transfer fee. A transfer
from a Metro Bus or Metro Link to Call-A-Ride Plus is 10 cents, plus an
additional \$4.25 or \$2.25 "depending on paratransit trip eligibility."

[]{.mark}

For trips of two or three zones, it appears that the Call-A-Ride Plus
fare of \$3.50 can be more than two times the fare of a comparable fixed
route trip on Metro by a typical user, if the fixed route user is
traveling without a transfer on Metro Link or one of the many buses that
cross between zones. The fixed route fare for such trips would be
\$1.50.

[]{.mark}

For trips involving a transfer between the fixed route and Call-A-Ride
Plus, it appears that in some circumstances the fare paid by an ADA
customer for the entire trip can be more than two times the fare of a
comparable fixed route trip on MetroBus or MetroLink. This would be the
case when Call-A-Ride Plus van serves as a feeder service to a rider who
has an origin or destination on a multi-zone MetroBus route or on
MetroLink. The Call-A-Ride Plus fare would be \$3.60, while the
multi-zone MetroBus or MetroLink fare for the comparable trip could be
\$1.50.

[]{.mark}

**Findings**

1.  The Metro ADA complementary paratransit service area includes all
    locations in St. Louis City and St. Louis County, within 3/4-miles
    of all Metro fixed route services.

2.  Metro does not provide Call-A-Ride Plus service to service areas
    within 3/4-miles of Metro Link Stations that it serves in Illinois.

3.  Metro and ATS effectively coordinate interregional service for ADA
    complementary paratransit eligible customers. It is a seamless
    process for riders, including reservation and fare payment.

4.  Metro Call-A-Ride Plus service schedule does not include service for
    all days and hours of scheduled service for several Metro Bus
    routes.

5.  For trips of two or three zones, it appears that the Call-A-Ride
    Plus fare of \$3.50 can be more than two times the fare of a
    comparable fixed route trip on Metro by a typical user, if that user
    is traveling without a transfer on Metro Link one of the many Metro
    Bus routes that serve multiple Call-A-Ride zones.

6.  The transfer charge for Call-A-Ride Plus trips that include
    transfers to fixed route service can further increase the difference
    between Call-A-Ride Plus fares and fixed route fares for trips with
    the same trip origin and destination.

[]{.mark}

**Recommendations**

1.  Metro should provide ADA complementary paratransit service to areas
    within 3/4-miles of the Metro Link stations that it serves in
    Illinois. This might be done by St. Clair County Transit District on
    behalf of Metro, by extending Call-A-Ride Plus service, or by other
    means.

2.  Metro should revise its service hours to provide Call-A-Ride Plus
    service during the same days and hours that Metro Bus service is
    scheduled. Call-A-Ride Plus information materials should be revised
    to communicate the revised Call-A-Ride Plus service periods.

3.  Metro should revise its fare structure such that Call-A-Ride Plus
    fares are no more than double the regular fare for fixed route
    service for a comparable linked trip from trip origin to
    destination. This could be accomplished by reducing the Call-A-Ride
    Plus fare to \$3.00 per trip, which equals twice the regular fixed
    route fare. This could also be accomplished by limiting the \$3.50
    Call-A-Ride fares to only zones that coincide with fixed route
    service areas that require a transfer and a 25-cent transfer charge.

4.  Similarly the transfer charge for Call-A-Ride Plus trips that
    include transfers to fixed route service should be reviewed and
    revised as necessary in order to insure that Call-A-Ride Plus fares
    do not exceed twice the regular fare for fixed route service.

# ADA Complementary Paratransit Eligibility

[]{.mark}

The purpose of the review of the eligibility process was to identify any
policies, procedures, or practices that prevent individuals with
disabilities from gaining timely access to ADA complementary paratransit
service. Review team members:

-   Interviewed consumers regarding issues about the eligibility process

-   Interviewed Metro's director of ADA services

-   Visited the Transit Assessment Center, where Metro conducts
    in-person assessments;

-   Collected and reviewed materials used in the certification process

-   Reviewed a sample of 34 completed applications and their respective
    eligibility determinations

-   Reviewed recent statistics related to eligibility processing time
    and determinations

[]{.mark}

**Consumer Comments**

[]{.mark}

The review team gathered information about the concerns of riders who
use Metro's Call-A-Ride service through telephone interviews with riders
or professionals who work with riders and through review of written and
telephone complaints to Metro and FTA.

In telephone interviews, review team members asked the riders if they
had any problems in obtaining eligibility for ADA complementary
paratransit service, or if the determination took more than 21 days.
Several interviewees said that their eligibility was not determined
within 21 days of submitting a completed application, and that they were
not apprised of their rights to use the service after 21 days until a
determination of eligibility is made. One rider said that because she
was not assigned an ID number, reservationists were not able to schedule
a ride for her.

In early 2005, participants at a meeting sponsored by the Starkloff
Disability Institute provided comments on Call-A-Ride. The Starkloff
Disability Institute is an organization based in St. Louis that conducts
research and advocacy related to disability issues. The concerns about
the Call-A-Ride eligibility cited by participants at the meeting
included the following:

-   Eligibility determinations do not properly account for weather and
    environmental factors

-   Eligibility determinations often take longer than 21 days,
    especially for recertifications

-   Applicants who request information in alternative formats do not
    always receive it

-   The appeals process is "intimidating and biased"

-   Metro should consider "grandfathering" eligibility of Call-A-Ride
    users

There were two formal complaints on file with FTA relating to Metro's
ADA complementary paratransit service. Both of the complaints addressing
eligibility issues focused on the length of time before a determination
of eligibility was received by the applicant. FTA had closed both of
these formal complaints.

Eligibility Determination Procedures and Practices

The director of ADA services oversees Metro's eligibility determination
process for ADA complementary paratransit service. She has a staff of
five, each of whom spends part or all of their time on Call-A-Ride
eligibility. In addition, since January 2004, Metro has contracted with
Washington University to conduct in-person assessments of Call-A-Ride
applicants.

As of April 2005, the director of ADA services estimated that 10,000
individuals had some level of Call-A-Ride eligibility. For the 15-month
period of January 2004 to March 2005, Metro had made 2,210 eligibility
determinations: about 1,000 of these were for new applicants, 1,200 were
for recertification.

[]{.mark}

**Application Process**

Individuals who wish to apply for Call-A-Ride Plus, Metro's ADA
complementary paratransit service call Metro's ADA Services Offices to
get a copy of the ADA Paratransit Application (Attachment D). The
application is also available in large type and Braille for individuals
with vision disabilities. The applications also ask if "you need future
written information provided to you in an accessible format," with
choices of computer disc, audio cassette, Braille, and large print. This
application (regular type version) includes instructions (two pages),
questions for the applicant to answer (seven pages), and a professional
verification (three pages).

The form requests that the applicant return the completed application
together with the written professional verification. The form also has
specific requirements for verification of certain medical conditions,
e.g.:

-   Applicants with a seizure disorder must have verification from a
    neurologist

-   Applicants with a cardiac condition should include their "American
    Heart Association Classification"

-   Applicants who had a stroke should include their "American Heart
    Association Stroke Outcome Classification"

The first page of the professional verification is a cover letter to the
professional from the director of the Transit Access Center (TAC). In
part, the letter states, "The ADA mandates that each person who applies
for the paratransit service to complete a functional assessment of
transit-related skills." While the DOT ADA regulations require transit
systems to limit eligibility to individuals who have disabilities that
prevent their use of fixed route service, there is no requirement for a
"functional assessment of transit-related skills."

When Metro receives an application form, an ADA Services staff member
date stamps the form and logs it in the TAC database. A staff member
then reviews the form. If the form is missing information and/or the
professional verification, the ADA Services office contacts the
applicant (by mail or phone) to try to obtain the missing information.
If the form is complete (or can be completed during the phone call), the
staff member tries to schedule the in-person assessment for the
applicant. Nearly all applicants, both new and renewals, have in-person
assessments. The general exceptions are individuals with severe
cognitive disabilities or with Alzheimer's disease.

[]{.mark}

The in-person assessments take place at the TAC's office in St. Louis.
Metro leases the office, but contracts with Washington University to
perform and manage the assessments. Washington University has a two-year
contract, with three option years. The TAC staff includes a director,
three assessors, and one clerical staff. The director and assessors are
members of Washington University's Occupational Therapy Program. They
have the following specialties:

-   Cognitive disabilities

-   Orientation and mobility

-   Visual disabilities

-   Psychological issues

The TAC office has equipment and devices that simulate the transit
environment, e.g., steps into a bus or van, curb ramps, and street and
bus signs. The staff assesses an applicant's ability to use fixed-route
services. Part of the assessment may include the applicant going outside
the building to walk on the sidewalk and cross a street. On average, one
assessment lasts one hour, including 15 minutes to prepare a written
report.

TAC staff submits each assessment report to the director of ADA
services. Each report includes a recommendation for eligibility status.
The director reviews a sample of the recommendations, but generally
accepts TAC's recommendations. Metro can make the following types of
eligibility determinations:

-   Unconditional

-   Conditional

-   Temporary

-   Visitor

-   Not eligible

Applicants who receive unconditional eligibility generally receive
eligibility for up to five years, after which they must recertify.

Table VI.1 shows the distribution of eligibility determination outcomes
from January 2004 to March 2005, during which period TAC made most of
the recommendations. During this period, 97.2 percent of applicants
received some level of eligibility for Call-A-Ride services.

Attachment E presents the form letter that Metro sends to applicants who
receive unconditional eligibility.

[]{.mark}

Attachment F presents the form letter that Metro send to applicants who
receive conditional eligibility. This letter includes an explanation of
Metro's appeals process. At the time of the review team's on-site visit,
Metro was making determinations of conditional eligibility for
Call-A-Ride service. However, Metro was scheduling service to people
with conditional eligibility as if they had unconditional eligibility.
The managers said that they planned to enforce conditional eligibility
as one of the new features of the upgraded Trapeze paratransit software,
planned for later in 2005.

**Table VI.1 -- Call- A-Ride Eligibility Determinations, January 2004 to
March 2005**

  ------------------------------- ------------------- -------------------
  **Determination**               **Number**          **Percent of
                                                      Total**

  Full eligibility, new applicant 354                 16.0

  Full eligibility,               996                 45.1
  recertification                                     

  Conditional, new applicant      534                 24.2

  Conditional, recertification    31                  1.4

  Temporary                       231                 10.5

  Visitor                         2                   0.1

  **Total with Some Eligibility** 2,148               97.2

  **Not Eligible**                62                  2.8

  **TOTAL**                       **2,210**           **100.0%**
  ------------------------------- ------------------- -------------------

Attachment G presents the template for the letter that Metro sends to
applicants who are determined ineligible. This letter includes an
explanation of Metro's appeals process. This letter provides the
following reasons for the determination:

1)  *You are able to navigate the system;*

2)  *You are able to board an accessible vehicle;*

3)  *You are not prevented from getting to or from a MetroBus or
    MetroLink stop by environmental factors.*

[]{.mark}

Metro should specify the reasons for the determination based on the
applicants information as it relates to the eligibility criteria, not
simply state that the person is able to use fixed route service (49 CFR
§37.123(d)). Metro should have this information readily available in the
reports prepared for each applicant by TAC.

[]{.mark}

Attachment H presents the form letter that Metro sends to applicants who
receive temporary eligibility. This letter should refer to or include
the appeals process, but does not.

[]{.mark}

Attachment I in the form letter that Metro sends to applicants who were
determined not eligible because the mobility aid that they use did not
meet the DOT ADA regulations (49 CFR §37.3) definition of a "common
wheelchair." This letter also should refer to or include the appeals
process, but does not. This determination fails to make the distinction
between the eligibility of the applicant and the applicant's mobility
aid. The determination of eligibility should be made solely based on the
applicant's ability to use fixed route service and not on the mobility
aid that the applicant uses. If the applicant is determined eligible and
uses a mobility aid that does not meet the definition of a "common
wheelchair," the applicant should be advised that their trip requests
cannot be accommodated when using such a mobility aid. This letter does
state that "you are encouraged to reapply for ADA eligibility with a
different mobility aid in the future."

All applicants who receive some level of eligibility receive an ID card
(sample card shown in Attachment J) and a flyer about Metro's ADA
complementary paratransit service and accessible fixed route services
(Attachment K). For individuals who are conditionally eligible, the ID
lists the condition codes. However, there is no explanation for these
codes on the card -- which can be a problem if the individual wants to
use the ID card in another jurisdiction.

Approximately two months prior to the end of the expiration of an
individual's eligibility term, Metro sends a renewal notice to the
individual. All riders must submit a full application to renew their
eligibility, though Metro does not require an in-person assessment for
all renewals.

[]{.mark}

**Appeals Process**

Accompanying the letters for conditional eligibility and denial is
Metro's appeals process for ADA complementary paratransit eligibility
(Attachment L). In part, the appeals process states, "The written appeal
should state the reason or reasons you believe the determination to be
incorrect." Metro should not require the written request for appeal to
include a reason for the appeal.

The Appeal Committee consists of three members: one person from Metro's
legal department and two members from Metro's Advisory Accessibility
Group. According to Metro appeals process, the committee will first
review any information provided with the initial written appeal. If the
committee can determine that the individual should be unconditionally
eligible based on the information provided, the committee will make that
decision without holding a hearing. Otherwise, the committee will hold a
hearing during which the applicant (or his/her representative) may
present information and arguments supporting his/her case. Based on this
hearing, the committee will make a decision. If the committee takes more
than 30 days to make a decision, the applicant will be permitted to use
Call-A-Ride Plus service (presumptive eligibility) until the decision is
made.

As of the time of the review team's on-site visit, there had not been a
formal appeal for more than three years. The director of ADA services
said when someone has called or written to appeal an eligibility
determination, she has reviewed the application file and any additional
information on her own. Based on her review, she has made adjustments to
the initial determinations. She said that this process has been
acceptable to those applicants. While perhaps not intentional, given the
lack of any formal appeals for more than three years, this practice of
"informal" appeals gives the appearance that Metro is avoiding the
process that it has developed. Furthermore, while the director of ADA
services does not review most eligibility decisions made by TAC, she has
formal responsibility for approving all determinations. Her role in
these informal appeals is contrary to 49 §CFR 37.125(g)(2): "the process
shall include an opportunity to be heard and to present information and
arguments, separation of functions (i.e., a decision by a person not
involved with the initial decision to deny eligibility)..."

**Suspension Policy**

Metro has a policy to suspend Call-A-Ride service to riders who exceed a
threshold of no-shows or late cancellations. A rider accumulates one
"point" for a same-day cancellation. A rider accumulates eight points
for a no-show or a cancellation less than two hours before the scheduled
pickup time.

-   A rider gets a warning letter from Metro after accumulating eight
    points

-   A rider gets a second warning letter from Metro after accumulating
    16 points

-   A rider is subject to a 14-day suspension, after a 14-day grace
    period, after accumulating 24 points within a 60-day period

The tracking and decisions on service suspensions due to no-shows is
handled by Call-A-Ride operations rather than ADA services. ADA
services, however, is responsible for managing the appeals process.

**Observations**

[]{.mark}

The review team reviewed a sample of 34 completed applications for ADA
complementary paratransit service. The purpose of the reviews was to:

-   Assess the timeliness of Metro's eligibility determination process

-   Assess the reasonableness of these determinations

**Processing Time**

The review team looked at 34 applications: 12 submitted from March 2004
to December 2004, and 22 submitted in February 2005, the most recent
month available at the time of the review. To analyze Metro's timeliness
in making determinations, the team analyzed up to five milestones, as
appropriate, for each application:

-   Date that Metro received a written application

-   Date that Metro contacted applicant to set in-person assessment --
    if information is available

-   Date of initially scheduled in-person assessment -- if different
    from actual date of in-person assessment

-   Date of in-person assessment

-   Date of eligibility determination

Table VI.2 provides a summary of the review team's analysis. As stated
earlier in this section of the report, Metro has defined its eligibility
process such that the application is complete after the in-person
assessment. This makes the third column of Table VI.2 the determination
time by Metro's standards. In the 2004 sample, Metro made determinations
within 21 days for only 4 of the 12 applications, with four applications
requiring at least 90 days and two applications requiring up to 170
days. In the 2005 sample, Metro greatly improved the timeliness of its
application processing, making determinations for 20 of 22 completed
applications within 21 days; the other two applications required 22
days.

**Table VI.2** Processing Time for Sample of Eligibility Applications

+----------------+-----------------+-----------------+-----------------+
|                | **Days from     | **Days from     | **Total Days:   |
|                | Written         | In-Person       | Receipt of      |
|                | Application**   | Assessment to   | Written         |
|                |                 | D               | Application to  |
|                | **to 1st        | etermination:** | Determination** |
|                | Scheduled       |                 |                 |
|                | In-Person       | **(BOLD         |                 |
|                | Assessment**    | indicates**     |                 |
|                |                 |                 |                 |
|                |                 | **\> 21 days)** |                 |
+----------------+-----------------+-----------------+-----------------+
| **March to     | *Average        | *Average        | *Average        |
| December 2004  | (mean):*        | (mean):*        | (mean):*        |
| (12            |                 |                 |                 |
| a              | *63 days*       | *60 days*       | ***129 days***  |
| pplications)** |                 |                 |                 |
+----------------+-----------------+-----------------+-----------------+
| Unconditional  | 43              | 20              | 63              |
| (1)            |                 |                 |                 |
+----------------+-----------------+-----------------+-----------------+
| Conditional    | 22              | **170**         | 192             |
| (1)            |                 |                 |                 |
+----------------+-----------------+-----------------+-----------------+
| Not Eligible   | 18, 23, 24, 32, | 8, 15, 15,      | 38, 65, 76, 76, |
| (10)           | 34, 42, 43, 64, | **23, 23, 46,   | 87, 118, 128,   |
|                | 109, 299        | 89, 94, 96,     | 167, 198, 345   |
|                |                 | 170**           |                 |
+----------------+-----------------+-----------------+-----------------+
| **February     | *Average        | *Average        | Average (mean): |
| 2005 (22       | (mean):*        | (mean):*        |                 |
| a              |                 |                 | **49 days**     |
| pplications)** | *33 days*       | *14 days*       |                 |
+----------------+-----------------+-----------------+-----------------+
| Unconditional  | 23, 26, 27, 28, | 1, 7, 13, 13,   | **36, 42, 42,   |
| (10)           | 29, 30, 35, 35, | 19, 20, 20, 21, | 44, 46, 47, 48, |
|                | 37, 39          | 21, **22**      | 56, 57, 59**    |
+----------------+-----------------+-----------------+-----------------+
| Conditional    | 23, 24, 26, 30, | 0, 7, 8, 9, 12, | 40, 41, 42, 42, |
| (11)           | 34, 35, 36, 37, | 12, 15, 17, 17, | 46, 48, 52, 55, |
|                | 43, 44, 48      | 18, 20          | 57, 62, 65      |
+----------------+-----------------+-----------------+-----------------+
| Temporary (1)  | 36              | **22**          | 58              |
+----------------+-----------------+-----------------+-----------------+

[]{.mark}

However, when one looks at the elapsed number of days between Metro's
receiving a written application and the date of the in-person
assessment, there seems to be a significant time between application
submittal and appointment. The average period in the 2004 sample was 63
days from receipt of written application to the scheduled in-person
assessment. This decreased to 33 days in the 2005 sample. But there
still appears to be a sizable period of time that an applicant must
wait: the *shortest wait was 23 days* in the 2005 sample. Metro did not
have any documentation to show the reason for these delays: whether it
was the choice or delay on the part of the applicants, or whether it was
Metro's lack of flexibility in scheduling in-person assessments.

These delays compound the total number of days for an applicant to
receive a determination. As shown in the right-hand column of Table
VI.2, the total number of days---from receipt of the written application
to determination---tended to take six to nine weeks (42 to 63 days) for
most applications in 2005. Even if Metro is meeting its own standard,
the public may perceive the eligibility process as being unacceptably
slow.

**Determination Outcomes**

Of the 34 applications that the team reviewed, Metro made the following
determinations:

-   Unconditional eligibility: 11

-   Conditional eligibility: 12

-   Temporary eligibility: 1

-   Not eligible: 10

All of these determinations appear to be reasonable. One of the people
determined to be conditionally eligible was initially determined not
eligible, but changed after the applicant submitted new documentation.
As mentioned earlier in this section of the report, Metro was not
enforcing conditional eligibility at the time of the review team's
on-site visit. As a result, any rider with conditional eligibility
could, in practice, make any trip requested.

**Findings**

1.  Metro's policy is to make determinations of ADA complementary
    paratransit eligibility based on whether the applicant's mobility
    aid meets the definition of a "common wheelchair." This
    determination fails to make the distinction between the eligibility
    of the applicant and the applicant's mobility aid. The determination
    of eligibility should be made solely based on the applicant's
    ability to use fixed route service as addressed in 49 CFR §37.123,
    and not on the mobility aid that the applicant uses. The decision to
    limit service to mobility aids that meet the definition of a common
    wheelchair should be addressed by Metro as a separate issue from
    eligibility.

2.  Based on review of a sample of 34 applications for Metro's
    Call-A-Ride service submitted during 2004 and 2005, the
    determinations made by Metro seem reasonable. Other than the policy
    regarding common wheelchairs, Metro's eligibility determination
    process does not appear to deny or restrict ADA complementary
    paratransit service to eligible individuals.

3.  Approximately 25 percent of applicants receive conditional
    eligibility. At the time of the on-site review Metro provided
    service to individuals who have conditional eligibility as if they
    had unconditional eligibility. As a result, any rider with
    conditional eligibility could be scheduled for any trip requested.

4.  Metro has defined its eligibility process such that the application
    is complete after the in-person assessment. Based on this standard,
    Metro made determinations within 21 days for only 4 of the 12
    applications in the review team's sample of applications filed
    between March and December of 2004. Four applications took at least
    90 days and two applications took up to 170 days. In a February 2005
    sample, Metro greatly improved the timeliness of its application
    processing, making determinations for 20 of 22 completed
    applications within 21 days.

5.  The time from submittal of a written application and an in-person
    interview is significant and could be an impediment to ADA
    complementary paratransit eligible individuals obtaining access to
    service. The average number of days in the 2004 sample was 63 days
    between receipt of written application and the in-person assessment.
    This decreased to 33 days in the 2005 sample. Metro did not have any
    documentation to identify the reason for the extended period between
    application submission and in-person assessment.

6.  The DOT ADA regulations (49 CFR §37.125 (c)) requires that
    applicants be treated as eligible for service if a determination of
    eligibility has not been made within 21 days following the
    submission of a complete application. The application and other
    public information provided by Metro do not inform applicants of
    their right to service if they have not received a determination on
    their completed application within 21 days.

7.  Metro has a process in place for appealing eligibility
    determinations. However, as of the time of the review team's site
    visit, there had not been a formal appeal for more than three years.
    As a result it was not possible to review determinations made on
    requests for appeal.

8.  In its letter to applicants who are determined ineligible for ADA
    complementary paratransit service, Metro does not provide specific
    reasons for why the applicant is determined ineligible for service.
    Absence of such information could impede applicant's decision on
    whether or not to appeal the determination.

9.  In its letter to applicants who receive temporary eligibility for
    ADA complementary paratransit service and in its letter to
    applicants who are denied eligibility for ADA complementary
    paratransit service because the mobility aid that they use, Metro
    does not refer to or include information on its appeals process. As
    a result, applicants who are determined ineligible may not be aware
    of their right to appeal the decision.

10. Metro's appeals process description states, "Appeals must be made in
    writing" and "The written appeal should state the reason or reasons
    you believe the determination to be incorrect." To require the
    appeal be made in writing and state the reason for the appeal could
    deprive the appellant of an opportunity to be heard and present
    information and arguments that the appellant would otherwise have if
    the appeal were made orally and without advance written reasons.

11. Metro's Director of ADA services handles request for appeals on an
    informal basis. The Director of ADA services has the formal
    responsibility for approving all initial eligibility determinations.
    This practice is at variance with the requirements of the DOT ADA
    regulations that decisions on appeals be made by a person not
    involved in the initial decision to deny eligibility, or "separation
    of functions."

12. Finding withdrawn (see Reporting Chart accompanying the Final
    Report).

13. Metro considers same day cancellations in its procedure for service
    suspensions. The DOT ADA regulations allow transit systems to
    suspend service for a reasonable period for riders who abuse the
    system by regularly "no-showing" for scheduled trips. While transit
    agencies have in recent years also considered "late cancellations"
    to be an abuse of the system and have considered this in their
    suspension policies, the effects of a late cancellation should be
    operationally equivalent to a no-show in terms of the negative
    impact on the service. Cancellations made several hours in advance
    of the scheduled pick-up time would still seem to allow the system's
    dispatchers to use the open vehicle time to respond to same-day
    operating issues. Accordingly, same day customer cancellations made
    several hours before the scheduled time should not be considered as
    a basis for suspending customer service.

14. Metro's ID card for ADA complementary paratransit service includes
    condition codes for individuals who are conditionally eligible.
    However, the card does not provide an explanation for these codes.

[]{.mark}

**Recommendations**

1.  Metro should revise or eliminate the policy of determining ADA
    complementary paratransit eligibility based upon the mobility aid
    used by the applicant. If Metro chooses to limit service to
    customers who use "common wheelchairs," it should so advise the
    customer in the application process and in the letter notifying the
    applicant of his or her eligibility for service.

2.  Metro should take action to reduce the time from receipt of a
    written application to conducting an in-person assessment. As one
    means of doing this, Metro could set the date for the in-person
    assessment before the written application and professional
    verification has been submitted. Another means of reducing the time
    span is to have the applicant bring the written application form and
    professional verification to the in-person assessment. Yet another
    possibility is to schedule the in-person assessment within one or
    two weeks of receipt of the application.

3.  Metro should revise its application and associated public
    information materials to advise applicants of their right to service
    if they have not received a determination on their completed
    application within 21 days. Metro should inform applicants of this
    right when 21 days from the filing of a completed application lapses
    if a determination of eligibility has not yet been made.

4.  Metro should provide specific reasons for why the applicant is
    determined ineligible for service in its letter to applicants who
    are determined ineligible for ADA complementary paratransit service.

5.  Metro should revise its letters for applicants who are receiving
    conditional eligibility to include information on the appeals
    process.

6.  Metro should revise its appeals process to avoid the implication of
    negative consequence if the reason for the appeal is not provided
    with the appeal. This might be done by using phrasing such as "the
    appellant is requested to provide reasons you believe the
    determination is incorrect. This information will assist in
    processing the appeal."

7.  Metro should revise its appeals process to provide "separation of
    functions" and eliminate the practice of the Director of ADA
    services handling request for appeals on an informal basis.

8.  Metro should revise its procedures for suspensions to consider only
    late cancellations that are operationally equivalent to a no-show in
    terms of the negative impact on the service. Same day customer
    cancellations made several hours before the scheduled time should
    not be considered as a basis for suspending customer service.

9.  Metro should revise its ID cards so that the conditions for ADA
    complementary paratransit service are clearly presented on the card.

# Telephone Access

[]{.mark}

The review team collected information about telephone access to Metro's
Call-A-Ride service for this part of the review. Telephone access for
placing or changing trip reservations or checking on the status of a
ride is an important part of ADA complementary paratransit operations.
The inability to get through on the phone to place trip requests without
significant delays could discourage people from using the service and
could therefore be considered a form of capacity constraint.

The review team conducted the following activities:

-   Reviewed consumer input

-   Reviewed performance standards

-   Reviewed the design of the phone system

-   Reviewed phone system monitoring (Automatic Call Distribution)
    reports

-   Reviewed call center staffing

-   Observed call center personnel handling of calls

**Consumer Comments**

[]{.mark}

Several respondents interviewed by the review team before the site visit
reported that there were significant hold times when calling to make a
reservation. Long waits were especially bad when calling during the
first hour of the call center opening in the morning (7:30 to 8:30
a.m.).

Several interviewees were unclear on the timing of the 30-minute window.
They believed that the window began 30 minutes before the pickup time,
not the 15 minutes before and 15 minutes after the pickup time. The
reservation agents did not appear to consistently explain the 30-minute
window to customers.

**Phone Service Standards and Performance Monitoring**

[]{.mark}

Metro has established a goal for hold times, or "wait time in queue" of
an average of 4.18 minutes. Average hold times of 4.18 minutes could be
achieved with a large proportion of the calls having hold times well in
excess of 4.18 minutes. Metro does not have a standard for number or
percent of calls by increments of time in queue. Metro's call monitoring
system is not equipped to compile records of individual calls by time in
queue.

At the time of the review, Metro was preparing to install a new computer
reservation system. This may present the transit agency with additional
options for the types of reports and performance monitoring systems it
uses.

[]{.mark}

**Phone Service Design**

[]{.mark}

The Metro Call-A-Ride call center is at its Call-A-Ride office. All
aspects of Call-A-Ride are located within this single
complex\--reservations, scheduling, dispatch, administrative offices,
maintenance, vehicles, and drivers. The Call-A-Ride reservations center
operates from 7:30 a.m. to 4:30 p.m., seven days a week.

[]{.mark}

Six advertised telephone numbers were served by the Call-A-Ride Center
at the time of the review. These included four lines for regular
reservations, one line for TTY service, and one line for customer
assistance and cancellations. The numbers are:

> North County 314-534-4144
>
> West County 314-534-1544
>
> South County 314-534-2255
>
> Call-A-Ride Plus 314-652-6200
>
> TTY line 314-534-5055
>
> Customer Assistance/Cancellations 314-289-5230

[]{.mark}

The reservations numbers are for customers to use to schedule new
reservations or to make modifications to existing reservations. The
Customer Assistance/Cancellations line is a separate line that allows
someone to cancel a ride and not have to go through the regular call
center.

[]{.mark}

At the time of the review, Metro was using a DOS-based computer system
for reservations. This system appears to be antiquated and slow. Because
of the slowness of the system, the average time to complete a
reservation was quite lengthy. Metro was in the process of upgrading its
computer reservations system. The new system was undergoing quality
control testing and was expected to be implemented during the summer of
2005.

The reservation system has a total of 18 computers at 16 work stations.
Two of the work stations, which are used by staff to proof the
schedules, have two computers at the work station.

Call-A-Ride has different standards for how far in advance a customer
may request a reservation. A customer covered under Medicaid may request
a trip up to 14 days in advance. A Call-A-Ride Plus customer may make a
reservation up to seven days in advance.

[]{.mark}

**Telephone Service Performance Monitoring**

[]{.mark}

Metro's call monitoring system does not have the capacity to compile
records of individual calls by time in queue. The reporting system
appears geared more towards assessing worker productivity rather than
customer service. Call-A-Ride tracks an average hold time for customers
by 30-minute periods. It does not track the time of the longest hold
time. Information on reservation line hold times by half hour was
available for Sunday, April 11, 2005. Additionally, information on daily
average hold times was available for weekdays during the week of
February 7 to 11, 2005. Information from Metro reports for these dates
is summarized in Table VII.1.

A review of the Metro reports indicates that the Sunday sample day
appears to be comparable to an average weekday with respect to average
hold times. Average hold times on April 10 ranged from 1.28 to 1.48
minutes by phone line. For the week of February 7 through 11, weekly
averages ranged from 1.11 to 1.69 minutes. The highest daily average for
a phone line was 2.45 minutes on Tuesday, February 8. An average of 2.45
minutes indicates a potentially large number of calls with long hold
times on these days. Sundays may not represent the same pattern of
distribution of calls throughout the day as weekdays. To the extent that
April 10 is representative of call distribution it appears that long
hold times appears to be limited to a few half-hour periods in the
course of the day. Of the 72 half-hour increments on the four lines, 9
or 12.5 percent, had average hold times of more than one minute.

**Table VII.1 -- Call-A-Ride Reservation Line Hold Times Reported by
Metro**

  --------------- ----------- ------------ --------- ------------- ---------- ---------- ----------
  **Date**        **Day**     **Period**             **Average                           
                                                     Hold Time                           
                                                     (minutes)**                         

  *Reservations                                      *#4230*       *#4240*    *#4250*    *#4260*
  Line \#*                                                                               

  2/7/2005        Monday      7:30 AM      4:30 PM   0.97          0.82       1.32       0.90

  2/8/2005        Tuesday     7:30         4:30      1.63          1.52       **2.45**   1.75

  2/9/2005        Wednesday   7:30         4:30      0.70          0.67       1.10       0.65

  2/10/2005       Thursday    7:30         4:30      1.65          1.50       2.02       1.37

  2/11/2005       Friday      7:30         4:30      1.13          1.03       1.58       1.10

  2/7-2/11/2005               7:30         4:30      **1.22**      **1.11**   **1.69**   **1.15**

  4/10/2005       Sunday      7:30         4:30      **1.33**      **1.48**   **1.28**   **1.38**

                              7:30         8:00 AM   **4.50**      **1.98**   0.47       **1.53**

                              8:00         8:30      0.32          0.00       0.03       0.40

                              8:30         9:00      0.10          0.00       0.12       0.13

                              9:00         9:30      0.05          0.28       0.08       0.15

                              9:30         10:00     0.03          0.43       **3.43**   0.32

                              10:00        10:30     0.37          0.13       0.00       0.08

                              10:30        11:00     0.18          0.13       0.10       0.08

                              11:00        11:30     0.08          0.08       0.07       0.07

                              11:30        12:00 N   0.33          0.35       0.20       0.30

                              12:00 N      12:30 PM  **2.92**      0.17       0.33       0.22

                              12:30 PM     1:00      1.43          0.07       0.20       0.32

                              1:00         1:30      0.20          0.07       **1.53**   **3.22**

                              1:30         2:00      0.42          0.43       0.03       0.33

                              2:00         2:30      0.13          0.00       0.08       0.05

                              2:30         3:00      1.73          **6.73**   1.53       0.47

                              3:00         3:30      0.08          0.05       1.27       0.13

                              3:30         4:00      0.10          0.18       0.73       0.12

                              4:00         4:30      0.00          0.00       0.00       0.00
  --------------- ----------- ------------ --------- ------------- ---------- ---------- ----------

Although operating hours for the reservation lines ends at 4:30 PM, the
Metro reports identify zero calls between 4:00 and 4:30 pm.

Because of the long time for each call, Metro experiences a high number
of abandoned calls. During the week of February 7 to 11, Metro received
a total of 4,053 calls to the reservation center. Of those, 737 calls
were abandoned by the caller: an abandonment rate of 18 percent.

In the week before the site visit, the review team placed calls to the
reservation line at different times of the day and made hold time
observations on five calls. Call answering times ranged from as little
as one minute and as long as eight minutes, with an average of four
minutes for the five calls. Table VII.2 documents these calls.

**Table VII.2 -- Hold Time Observations**

  ---------- ----------- ----------- ---------------------------------------
  **Date**   **Time**    **Minutes   **Notes**
                         on hold**   

  4/5/2005   09:08 AM    6:19        

  4/4/2005   09:38 AM    3:20        On hold for 3:00 then rings for 20
                                     seconds, then answered

  4/5/2005   10:08 AM    1:00        

  4/1/2005   10:50 AM    8:03        

  4/4/2005   3:53 PM     1:30        On hold for 1:00 minute, rings, then
                                     answered after 30 seconds
  ---------- ----------- ----------- ---------------------------------------

During the two-day period of April 12 and 13, 2005, the team observed
the reservation process over 9-1/4 hours. During this time, team members
observed a total of 76 calls during which reservationists handled a
total of 119 trip requests. Each call averaged over seven minutes. Metro
has a policy of limiting a client to book four reservations per call
(the equivalent of two round-trips) during peak calling hours. This
policy can result in more calls for each customer to make all of their
trip reservations. The added calls can consume more of the
reservationists' time, by exchanging introductory information and
calling up customer records for each call, as well as the time of
customers both waiting in queue and reserving trips.

[]{.mark}

**Call Center Staffing**

The call center has one call center supervisor and 12 full-time
reservation clerks. Clerks are on duty from 7:30 a.m. to 4:30 p.m. each
day of the week. In addition to taking calls, reservation clerks rotate
as customer service agents within the dispatch office. In dispatch they
handle ride cancellations and "Where's my ride?" calls. Call-A-Ride
maintains a separate phone line for these types of calls, which helps to
reduce the call load on the reservations line and allows people to
inquire about their ride without having to endure the long hold times
experienced in reservations. With days off, customer service
assignments, and breaks there are typically eight or fewer reservation
clerks available to accept trip requests during the day.

[]{.mark}

During the on-site observation of the call center, review team members
noted that the office clock was approximately nine minutes fast. Because
the staff members use this clock, service at the end of the day was
stopped before 4:30 p.m.. Conversely, call takers would begin taking
calls before the stated 7:30 a.m. beginning time.

[]{.mark}

It was also noted that if a call was placed before 4:30 p.m. and put on
hold, the call would receive a message at 4:30 p.m., stating that the
reservation center was closed for the day and then the call would be
dropped. As a result, no calls were answered after 4:21 p.m., because
the clock was incorrect, and calls in queue at 4:17 p.m. (Based on an
average queue of over four minutes) would not be answered.

[]{.mark}

**Findings**

1.  Metro's policy goal of average times in queue of 4.18 minutes likely
    results in many calls in queue for periods of time well in excess of
    4.18 minutes and would appear to significantly limit ADA
    complementary paratransit customers' ability to use Call-A-Ride
    service.

2.  During the week of February 7 to 11, 2005, Metro received a total of
    4,053 calls to the reservation center. Daily average hold times for
    the four phone lines ranged from 0.65 minutes to 2.45 minutes. Of
    the 4,053 calls, 737 were abandoned by the caller for an abandonment
    rate of 18 percent. This high abandonment rate is an indicator of
    difficulty in getting through on the phone lines to make
    reservations. Call Center staffing and equipment limits may be
    contributing to long hold times and high abandonment rates.

3.  The review team observed 76 calls during the two-day period of April
    12 and 13, 2005. These calls averaged over seven minutes to
    complete. The reservations system being used at the time of the
    review appeared to be antiquated and slow, contributing to the long
    call times. Metro was in the process of upgrading its computer
    reservations system with a scheduled implementation during the
    summer of 2005.

4.  Metro's advertised Call-A-Ride reservations hours are 7:30 a.m. to
    4:30 p.m. During the review, the Reservations Center closed at 4:21
    p.m., based on a wall clock that was nine minutes fast.

5.  Any calls left in the queue at the end of the day were abandoned. As
    a result, some customers calling before 4:30 p.m. are not being
    served.

6.  Metro accepts only four one-way trip requests per call during peak
    call times. This policy can increase the length of telephone queues
    by requiring reservationists to handle multiple calls rather than
    one to serve one customer and placing multiple calls rather than one
    in the phone queue.

7.  Metro tracks performance by measuring the callers' average time in
    the telephone queue. This performance measure does not capture the
    number of callers that have significantly long hold times, which
    provides a better index of customer service and telephone access.

8.  It is Metro's practice for reservation clerks to rotate into the
    dispatch center and handle customer assistance calls. This appears
    to be very beneficial because it allows the reservation clerk to
    understand additional aspects of the reservation process and gives
    the clerk a greater sensitivity to the customer's needs.

**Recommendations**

1.  Metro should review and revise its policy goal for telephone access
    by adopting performance standards of percent of calls by time in
    queue, that is: "X %" calls answered within one minute, "Y %" in two
    minutes, etc. The upper bound should be set to avoid any
    significantly long hold times.

2.  Metro should expand staffing and capacity of the telephone
    reservations system as needed to achieve telephone service levels
    that do not impede access to service.

3.  Metro should continue with modifications to its computer
    reservations system to reduce the time required to complete trip
    reservations.

4.  Metro should maintain the correct time on its clocks in the
    reservation area and in the reservations and scheduling software
    system.

5.  Reservations Center staffing schedules should be revised to assure
    that all customer calls initiated between 7:30 a.m. and 4:30 p.m.
    are answered. This can be accomplished by scheduling staff to work
    after 4:30 p.m. until all calls in the phone queue at 4:30 p.m. are
    answered.

6.  Metro should consider removing the limit to the number of trip
    requests made with each call as a means of reducing both call volume
    and time spent on calls.

7.  Metro should track telephone system performance by measuring the
    number and percent of calls by the length of time that they are in
    the phone queue by hour of day.

# Trip Reservations and Scheduling

The team reviewed scheduling of Call-A-Ride trip requests. Information
reviewed and observations on scheduling included:

-   Consumer interviews and review of complaints filed with Metro

-   Metro policies and procedures

-   Scheduling software

-   Interviews with Call-A-Ride managers, schedulers, reservationists,
    and dispatchers

**Consumer Comments**

[]{.mark}

There were two closed complaints relating to Metro's ADA complementary
paratransit service on file with FTA. Neither cited trip reservations or
scheduling issues.

[]{.mark}

Of nine consumer interviews, the only concern at all related to
scheduling addressed the location of transfer locations. Several
interviewees complained that the locations being used as transfer points
between vehicles were not appropriate places for ADA complementary
paratransit customers. They felt that locating the transfer stations at
busy, noisy locations was uncomfortable and disorienting for customers
who have certain disabilities, such as blindness.

Of 69 Call-A-Ride complaints filed with Metro between July 2004 and
March 2005, 32 (46 percent) related to service. These complaints
included:

-   Late vehicles

-   Vehicles not arriving

-   Proposed schedule changes

-   Customer appealing of a penalty

-   Miscellaneous service issues

**Polices and Procedures**

[]{.mark}

At the time of the on-site review, Call-A-Ride had 2,800 to 2,900 trips
requested on an average weekday. The number of trips ultimately served
generally ranged from 2,200 to 2,300 on an average weekday. The
ridership on Saturdays averaged 900 and on Sundays averaged 550. The
difference between the requested trips and served trips was cancelled
trips (both early and late), customer no-shows, and carrier missed
trips.

[]{.mark}

Call-A-Ride trip scheduling involves three sets of Metro staff:
reservationists, "proofers," and the PM dispatchers. The technique
Call-A-Ride uses is real-time scheduling. As discussed earlier in this
report, the Call-A-Ride reservationists accept trip requests from
callers. While on the phone, the reservationists seek to fit the trip
requests into the available set of vehicle routes. Call-A-Ride uses PASS
software, which is a predecessor to Trapeze, for trip requests and trip
scheduling. Metro accepts Call-A-Ride Plus trip requests from one to
seven days before the date of the trip, seven days a week from 7:30 a.m.
to 4:30 p.m.

[]{.mark}

Call-A-Ride divides its service area into six zones:

1.  North County

2.  West County

3.  South County

4.  County/City-North

5.  County/City-South

6.  Far West County

[]{.mark}

Attachment M presents a map of the Metro Call-A-Ride service area and
the six zones. Call-A-Ride assigns vehicle routes by service zone. Table
VIII.1 lists the assignment of vehicles by zone and by day of the week
at the time of the review team's visit. In Table VIII.1, the
"Call-A-Ride (CAR) Plus" vehicles either stay within the City of St.
Louis or travel between the city and other zones. "Expansion" vehicles
are not pre-assigned to any zone, so they may be assigned on a
day-to-day basis during the reservation process to wherever the demand
for service indicates. "Relief Tour" vehicles are called "clean-up"
vehicles by Call-A-Ride staff. They do not have trips assigned to them
during scheduling, but are available during the day of service to be
assigned as directed by the dispatcher.

**Table VIII.1 -- Call-A-Ride Vehicle Assignments**

  ----------------------------- --------- --------- --------- --------- --------- --------- ---------
  **Zone**                      **Mon**   **Tue**   **Wed**   **Thu**   **Fri**   **Sat**   **Sun**

  **North**                     12        13        13        13        13        5         4

  **West/Far West**             15        14        14        14        15        15        14

  **South**                     7         7         7         7         7         4         2

  **City & Cross-County ("CAR   16        16        16        16        16        6         5
  Plus")**                                                                                  

  **"Expansion"**               40        40        40        40        40        17        7

  **"Relief"**                  5         5         5         5         5         5         5

  **TOTAL**                     95        95        95        95        96        52        37
  ----------------------------- --------- --------- --------- --------- --------- --------- ---------

The vehicles listed in this table do not include vehicles assigned to
Call-A-Ride's Chesterfield Connector. The connector provides fixed route
service between Ballas Metro Center and Chesterfield Mall. The vehicles
for this service generally operate independently from the rest of
Call-A-Ride.

[]{.mark}

Of the total set of requested trips, the chief of paratransit operations
estimated that 45 percent are standing order (subscription) and 55
percent are demand. Standing order trips are trips that have the same
schedule from day to day and week to week and are permanently scheduled
until changed by the customer. Demand trips are scheduled by the
customer individually. For a sample day prior to the on-site review
(Wednesday, February 9, 2005), the split of trip requests was 43.8
percent subscription and 56.2 percent demand responsive. The
subscription trip requests are pre-assigned to Call-A-Ride vehicle runs
and are not handled by the reservationists.

Metro's web site and the Metro Call-A-Ride brochure dated June 28, 2004,
advise Call-A-Ride customers to "phone at least 24 hours in advance to
schedule your trips." The DOT ADA regulations (49 CFR §37.131(b))
require the transit entity (Metro) to schedule and provide trips in
response to a request for service made the previous day. Accordingly
Metro must accept any trip requests made on the day before the requested
service even if the time of the request is less than 24 hours in advance
of the time of travel.

When a rider calls to request a trip, the reservationist enters the
date, pickup and drop-off addresses, and requested pickup and drop-off
time (if provided) into PASS. PASS searches for a vehicle assigned to
the service zone of the rider's pickup address and places the trip on
that vehicle. When more than one vehicle run can accommodate a
particular trip request (i.e., estimated pickup time within the 15
minute pick-up window, drop-off time not later than any requested
appointment time, travel time does not violate Call-A-Ride policy), PASS
tries to group trips onto runs that already have trips rather than to
spread the trips among all available runs. This is PASS's way to try to
create efficient schedules. Reservationists, however, try to assign a
trip request to a run that will make the estimated pickup and drop-off
times as close as possible to the requested times. To accomplish this, a
reservationist can bypass the vehicle run suggested by PASS and search
through the other runs to place the trip request.

When a reservationist places the trip request onto a run, if there is no
resulting policy violation, PASS codes the trip green on the screen. A
trip with a travel time 45 to 75 minutes and/or with an arrival time up
to two minutes after a specified appointment time is coded yellow by
PASS. A trip longer than 75 minutes and/or arriving more than two
minutes after an appointment time is coded red. PASS schedules all trips
relative to the pickup time. When a trip request includes an appointment
time, PASS tries not to have a late drop-off, but may do so.

A reservationist may get a trip request that cannot fit on any run
within the allowable negotiation window of +/-60 minutes. A
reservationist does not have the authority to move other trips already
placed on runs. If there is no available run, the reservationist records
this request as a trip denial. If the reservationist offers a trip that
is within the negotiation window, but the caller turns down the offer,
the reservationist records this request as a trip refusal (or
"adversarial denial"). At the time of the review team's on-site visit,
the proportion of recorded denials for ADA complementary paratransit
trips was approximately 2.0 percent of the total demand each weekday.
Metro data for the period June through December 2004 presented in Table
IX.1 indicates that approximately 20 percent of denials are for next day
service and 80 percent are for service requests made two or more days in
advance of the service day.

Call-A-Ride has adjusted the vehicle speeds in PASS to match its
operating environment. The standard road speed is 22 miles per hour.
This speed is reduced as follows during peak travel periods and for new
drivers:

-   70 percent: morning peak

-   80 percent: afternoon peak

-   70 percent: weeks 1 and 2 for a new driver

-   80 percent: weeks 3 and 4 for a new driver

-   90 percent: weeks 5 and 6 for a new driver

If a vehicle run both takes place during the peak and uses a new driver,
then PASS applies two speed reduction factors (e.g., during the morning
peak for week 1 of a new driver, effective road speed = 22 miles per
hour x 70% x 70% = 10.8 miles per hour).

[]{.mark}

Proofers are Call-A-Ride reservationists who have been trained to be
schedulers. During a given month, there are seven proofers; each proofer
is assigned a day of the week and is responsible for finalizing the
schedule for that day for the month (e.g., the "Monday proofer"
finalizes the schedule for all Mondays in a month). A proofer starts to
review vehicle runs up to seven days in advance, as new demand trip
requests are placed on vehicle runs with the subscription trips already
inserted. According to the supervisor for CAR reservationists, a proofer
focuses on:

-   Eliminating trips with long travel times

-   Reducing and eliminating inefficient routes

-   Creating slack time within routes to allow for additional trips

[]{.mark}

A proofer has the authority to shift the pickup times of trips within
the full +/-15 minute pickup window. However, a proofer will not shift
pickup times for certain clients, particularly workshop riders with
subscription service. Also, a proofer may call a rider to ask approval
for moving a pickup time outside of the previously agreed upon pickup
window. This happens for a "handful" of trips each week, according to
the reservationist supervisor. A proofer continues to work on the
schedule until 4:30 p.m. of the day before service, when reservations
stop accepting requests for next-day trips. The proofer then uses PASS
to generate all the runs for the service day.

[]{.mark}

After the proofer generates the runs, the night dispatcher reviews the
runs during the evening. The dispatcher has the authority to move trips
within the +/-15minute pick-up window and move trips from run to run.
The night dispatcher usually gains some flexibility to adjust runs
because calls come in after 4:30 p.m. from riders cancelling trips.
These cancellations open up room on the schedules prepared by the
proofer.

At the time of the review team's on-site visit, Metro managers were
planning to upgrade the paratransit software to the Windows-based
Trapeze (PASS is DOS--based) by summer 2005. Trapeze was already being
used by Metro for other functions including the fixed route buses, fixed
route customer information, and the complaints. Call-A-Ride had tried to
change the software in 2003, but continued to use PASS after
encountering problems in the transition.

[]{.mark}

For the rider, the benefit of real-time scheduling is that he or she
receives an immediate confirmation of the pickup/drop-off times and
windows. There is no need for further communication between Metro and
the rider prior to the trip. However, there are major drawbacks to the
technique for Metro. Since the selection of which run to place a trip
depends on the placement of all previously requested trips (including
the subscription trips), the overall vehicle runs are not optimal in
terms of productivity or service quality. And once a reservationist
concludes that a trip request cannot fit onto any run, the request
becomes a denial. Neither the proofers nor dispatchers go back to the
list of denials to see if they can be placed on a run.

Metro managers said that many of the riders who have their trip requests
denied call back on a subsequent day and get a trip. There are three
ways for this to occur:

-   Metro opens up additional Call-A-Ride vehicle runs

-   Space becomes available, either through adjustments by the proofer
    or by early cancellations

-   The rider requests a different pickup time

It is likely that some denials are eventually served in practice.
However, Metro has not tried to document this number, and it is not
without significant effort on the part of the rider.

[]{.mark}

**Findings**

1.  Metro's web site and the Metro Call-A-Ride brochure dated June 28,
    2004, advise Call-A-Ride customers to "phone at least 24 hours in
    advance to schedule your trips." The DOT ADA regulations (49 CFR
    §37.131(b)) requires the transit entity (Metro) to schedule and
    provide trips in response to a request for service made the previous
    day.

2.  At the time of the review team's on-site visit, Metro regularly
    denied trip requests for ADA complementary paratransit service due
    to capacity constraints. The proportion of denials was generally two
    percent of total demand on weekdays. Of these denials approximately
    20 percent were for next day service requests and 80 percent were
    for service requests two or more days in advance of the service day.
    Metro managers said that many of the riders who have their trip
    requests denied call back on a subsequent day and get a trip.
    However, Metro has not tried to document this number, and it is not
    without significant effort on the part of the rider.

3.  Many trips denied early in the scheduling period can be scheduled
    later in the scheduling period as a result of trip cancellations
    and/or route modifications made by proofers. Denial of such trip
    requests precludes them being served unless the customer calls again
    at a later time to request the trip.

4.  The Metro scheduling software does not include a function to
    schedule trips to meet appointment times. Reservationists record
    appointment times requested by callers in the software system and
    can attempt to place the trip on the run they feel is most
    appropriate. However, Metro has not set up PASS to schedule by
    appointment time.

**Recommendations**

[]{.mark}

1.  Metro's should revise its policy to accept all trip requests made on
    the day before the requested service day, regardless of whether or
    not the request is made 24 hours in advance of the requested trip
    time. Metro should revise its public information materials
    accordingly, including its web site and Call-A-Ride brochure.

2.  Metro should discontinue the practice of denying trips by providing
    sufficient run capacity to accommodate all trip requests. This can
    be accomplished several ways, most easily by increasing the total
    number of runs. In addition to eliminating denials, this will
    eliminate multiple calls by customers attempting to schedule the
    same trip.

3.  Metro should consider allowing reservationists to accept trip
    requests that they cannot schedule and place them on open runs to be
    scheduled to available covered runs at a later time by proofers. If,
    during the scheduling period, the number of trips on the open runs
    exceeds that which can be reliably served by same day dispatch,
    reservationists can be instructed to discontinue acceptance of trip
    requests that can't be scheduled.

4.  Metro should modify its scheduling procedures to allow the
    scheduling and tracking of trips by appointment time.

# Service Performance

# []{.mark} {#section .unnumbered}

The DOT ADA regulations for ADA complementary paratransit service
indicate that capacity constraints can result from poor service quality.
Specifically, they note that denials of trip requests, missed trips, or
the provision of untimely trips or significantly long rides can
constitute capacity constraints. Therefore, the review team examined the
ultimate disposition of trip requests, on-time performance, and on-board
travel times. These aspects of service provision were assessed as
follows:

[]{.mark}

-   Consumer input was obtained on each issue through telephone
    interviews and through a review of complaints filed with FTA and
    with Metro.

-   Metro's service policies, procedures, and standards related to
    missed late and long trips were reviewed.

-   Metro's on-time performance and travel time reports were reviewed.

-   Actual pickup and drop-off times reported on a randomly selected day
    were used to tabulate on-time performance to compare to reported
    performance.

-   The review team analyzed trip length, including a comparison of
    travel times between ADA complementary paratransit trips and
    comparable fixed route trips.

[]{.mark}

**Consumer Input**

[]{.mark}

Consumer input is summarized in Section III of this report. Complaints
relating to service performance are described below.

[]{.mark}

There were no service issues in two closed complaints on file with FTA.

[]{.mark}

Nine Metro Call-A-Ride users who were interviewed prior to the site
visit cited two issues that could affect service performance. Several
customers indicated an understanding of the pickup window different from
that used by Metro. This could result in missed trips and customer
no-shows as well as customer dissatisfaction with service performance.
Some customers believed that they were expected to be ready to board
vehicles 30 minutes before the schedule time they were given, not the 15
minutes before or 15 minutes after the scheduled time as used by Metro.
As a result, customers might find alternate transportation after the
scheduled travel time and be categorized as a "no-show" if the vehicle
arrived within 15 minutes after the scheduled pickup time.

A second concern raised by interviewed customers was that drivers would
wait less than three minutes for customers to board the vehicle and then
classify the customer as a no-show. This could also result in
overstating the number of customer no-shows.

Of the Call-A-Ride complaints filed with Metro from July 1, 2004,
through March 31, 2005, 32 (46 percent) related to service. Service
complaints included:

-   Late vehicles

```{=html}
<!-- -->
```
-   Vehicles not arriving

-   Proposed schedule changes

-   Customer appealing of a penalty

-   Miscellaneous service issues

**Metro Policies**

**Trip Denials.** Metro's policy standard is zero denials for requests
made the previous day. Metro accepts service requests seven days in
advance of the service day. However, Metro's standard only applies to
trips denied on the day before the service day. If a customer is denied
service more than one day before the service day Metro does not consider
this a trip denial. The discussion on trip denial in the Appendix to the
regulations discusses practices that prevent people from gaining access
to the service, such as limiting access to trip reservations, a capacity
constraint or denial of service. "Metro Call-A-Ride Easy Tips" brochure
encourages customers to call early to make trip reservations. Denying a
trip more than one day in advance of the service day, thereby requiring
multiple calls to schedule a trip, appears to limit access to the
service and constitute a capacity constraint, that is not measured by
Metro's policy for service denials.

**Missed Trips.** Metro appears to have no policy for missed trips**.**

[]{.mark}

**No-Shows.** According to "Metro Call-A-Ride Easy Tips," if a customer
fails to cancel a trip more than two hours before the scheduled trip
time, the trip is categorized as a no-show.

[]{.mark}

**On-Time Performance.** According to "Metro Call-A-Ride Easy Tips,"
customers are advised that the vehicle may arrive up to 15 minutes
before or after the scheduled pickup time (-15/+15) and that the
customer must be prepared to leave within this period.

Metro's computation of on-time performance includes trips with customers
picked up more than 15 minutes early, as on time. It is Metro's policy
to pick up customers early only if the customers wish to board early.
Additionally, Metro does not count a trip as late unless it is more than
five minutes later than the on-time window---or more than 20 minutes
after the scheduled pickup time. Accordingly, for performance
measurement, trips are considered on time if they are less than 20
minutes late (+20). Metro's goal for on-time performance is 94.6
percent. Metro has no on-time policy for dropping passengers off to meet
appointments.

[]{.mark}

**Trip Duration.** Metro's travel time standards are maximum travel time
of 45 minutes for intra-zonal trips, and 90 minutes for inter-zonal
trips, with a goal of completing inter-zonal trips in 60 minutes or
less.

## Performance

**Trip Disposition**

Table IX.1 presents Metro information on monthly Call-A-Ride trip
requests and denials for the period June through December 2004.

> Table IX.1 -- Metro Reported Capacity Denials: June through December
> 2004

  ------------ ------------- ------------- ------------ ----------- -----------------
  **Month**    **Trip        **Denials**                            
               Requests**                                           

                             **Next Day**  **2 or More  **Total     **% of Requests
                                           Days**       Denials**   Denied**

  June         71,869        127           376          503         0.7%

  July         67,509        50            211          261         0.4%

  August       70,125        76            246          322         0.5%

  September    69,993        77            366          443         0.6%

  October      70,069        109           390          499         0.7%

  November     71,241        119           493          612         0.9%

  December     71,436        121           385          506         0.7%

  **Totals**   **492,242**   **679**       **2,467**    **3,146**   **0.6%**
  ------------ ------------- ------------- ------------ ----------- -----------------

[]{.mark}

According to Table IX.1, 0.6 percent of trip requests during the period
were denied. Of the trips denied, 78.4 percent were for trips requested
two or more days in advance and 21.6 percent were for requests for next
day service.

Metro staff indicated that many customers who are denied service two or
more days in advance will call again until their trip schedule request
is honored.

The review team used Call-A-Ride trip data for February 9, 2005,
supplied by Metro in a spreadsheet to perform an independent analysis of
trip disposition and service performance. The spreadsheet contains 5,597
rows representing records of trip information and 77 columns
representing characteristics of each trip. Since most trips are coded in
pairs in the spreadsheet, the 5,597 rows represent 2,515 unique trip
requests. Since Call-A-Ride serves non-ADA trips as well as ADA trips
the records were screened to eliminate non-ADA trips from the analysis.
There are 2,116 resultant ADA trip requests. Refer to Attachment N for a
detailed discussion of the review team's methodology and analysis of the
Call-A-Ride data for the sample day.

[]{.mark}

The Table IX.2 shows the breakdown by trip disposition as coded in the
spreadsheet.

[]{.mark}

**Refused and Denied Trips**

[]{.mark}

The spreadsheet had 43 trip requests that were coded for some type of
denial. This represents 2.0 percent of all 2,116 trips requested on
February 9, 2005. Of these 43 denials, 42 were classified as "capacity
denials" and 1 was an "adversarial denial."

[]{.mark}

Since the spreadsheet contained no data on pickup time requested, it was
not possible to determine the responsiveness of the offered pickup time
with respect to pickup time requests.

**Table IX.2 -- Recorded Trip Disposition**

  ----------------------- --------------- --------------- ----------------
  **Trip Disposition      **Number of     **Number of ADA **% of Total ADA
  Codes**                 Rows or         Trip Pick-up    Trip Pick-up
                          Records**       Requests**      Requests**

  P = Performed           1,634           1,634           77.2%

  C = Early Cancel        358             348^1^          16.4%

  W = No Show             0               0^2^            

  N = Late Cancel &       91              91^2^           4.3%
  Missed Trips                                            

  Blank = Refused and     86              43^3^           2.0%
  Denied                                                  

  **TOTAL**               **2,169**       **2,116**       **100.0%**
  ----------------------- --------------- --------------- ----------------

NOTES:

-   ^1^Although most drop-off records coded with trip disposition code C
    have a non-ADA fare of blank, there are 10 drop-offs with an ADA
    fare of N. Therefore the 358 records of early cancel ADA trips
    actually represent 348 unique trip pick-up requests.

-   ^2^Records coded with trip disposition codes W and N were found to
    represent drop-offs and pick-ups respectively for the same scheduled
    set of trips, and so count as one set of 91 trips. Although no
    disposition code W records appear in this analysis because they have
    a non-ADA fare of blank, they are nevertheless represented by their
    pick-up counterparts with disposition code N having valid ADA fare
    codes as listed in Table N.1a. For further discussion, see section
    *Late Cancel, Missed Trips, and No Shows* below.

-   ^3^Records coded with a blank trip disposition code were found to
    have both a pick-up record and a corresponding drop-off record with
    the same fare. Hence the 86 records of refused and denied ADA trips
    actually represent a set of 43 unique trip requests.

[]{.mark}

[]{.mark}

The review team's analysis also noted that 13 of the capacity denial
requests did have an appointment time request. Since there was no
corresponding column in the spreadsheet that provided an estimated or
promised drop-off time, there was no way to calculate whether the offer
was responsive with respect to drop off time.

[]{.mark}

Based on the foregoing review, on the sample day of 2,116 trips
requested, 42 or 2.0 percent were denied. This exceeds the 0.6 percent
of next-day denials reported by Metro. As indicated by Metro, some of
the customers whose trips are denied more than one day before the
service day may successfully schedule their trip at another time. Others
may opt not to make the trip or travel by other means.

[]{.mark}

**Scheduled Trip Requests -- Not Completed**

[]{.mark}

Deducting the 43 denied trips from the total 2,515 trips requested
results in 2,073 scheduled trips for the sample day.

Trips that have been scheduled are either completed (performed) or not
completed. Trips that are not completed can result from the action of
the customer or the operator. Trips not completed because of the
customer's action are cancellations and no-shows. Customer cancellations
are typically categorized as early or late. Early cancellations permit
the operator to reallocate manpower and equipment with some
inconvenience. This inconvenience is often offset by making available
service capacity on the service day to address unforeseeable needs. Late
cancellations (an hour or two before the scheduled time) severely limit
the operator in reusing scheduled resources to serve other customers. As
with customer no-shows, late cancellations are usually discouraged by
the operator.

[]{.mark}

Trips not completed because of the operator's failure are missed trips.
DOT ADA regulations (49 CFR §37.131(f)(3)(B)) prohibit transit entities
from limiting service availability through patterns or practices that
result in substantial number of missed trips. For purposes of measuring
performance against the regulatory criteria, missed trips are defined as
trips that were not served when the customer was available for the trip
throughout the pickup window (-15/+15). That is, the vehicle did not
arrive in the pickup window and the trip was not completed.

[]{.mark}

**Early Trip Cancellations.** The data in the spreadsheet show 348 trip
requests that were cancelled early. This represents 16.4 percent of all
2,116 ADA trips requested on February 9, 2005. Because the spreadsheet
contained no column for cancellation time, it was not possible to verify
that these trips were indeed early cancellations. In fact, 9 of the 348
early canceled trips have a vehicle arrival time, suggesting that the
cancellation may not have been "early enough" to avoid an attempted
pickup trip or the cancellation was not communicated to the driver in
timely manner. However, 6 of these 9 cancelled trips with a vehicle
arrival time do not have a valid vehicle number, thereby calling some of
the recorded information further into question.

[]{.mark}

**Late Cancel, Missed Trips, and No Shows.** Deducting the 348 early
cancellations from the 2,073 scheduled trips leaves 1,725 trips
dispatched. Of these, 91 trips requests were coded as late
cancellations, missed trips, or passenger no-shows. This comprises 4.3
percent of the total 2,116 trips requested for the sample day.

[]{.mark}

To distinguish among the three categories, the team examined the data
for actual vehicle arrival time and promised arrival time for each of
these 91 trip requests.

-   If the trip contained a vehicle arrival time within +/-15 minutes of
    the promised arrival time, the trip was assumed to be a "customer
    no-show."

-   If the trip contained a vehicle arrival time outside the
    +/-15-minute window of the promised arrival time, the trip was
    assumed to be a "missed trip."

-   If no vehicle arrival time was recorded for the trip, it was assumed
    that either the trip was cancelled in time to avoid the vehicle
    traveling to the pickup location or the vehicle simply never arrived
    at the pickup location. These trips could be either late
    cancellations or missed trips.

[]{.mark}

The results of the analysis of late cancellations, missed trips, and
customer no-shows appear in Table IX.3.

[]{.mark}

**Table IX.3 -- No-shows and Missed Trips**

+---------------------+--------------+--------------+-----------+-----+
|                     | **No-shows** | **Missed     | **Late    | **T |
|                     |              | trips**      | Cancel    | ota |
|                     | (Arrival     | (Arrival     | /Missed   | l** |
|                     |              | outside      | Trip**    |     |
|                     | +/-15 min.   | +/-15 min.   |           |     |
|                     | of           | of           | (No       |     |
|                     | Negotiated   | Negotiated   | arrival   |     |
|                     | ETA)         | ETA)         | data)     |     |
+---------------------+--------------+--------------+-----------+-----+
| Number of trips     | 34           | 10           | 47        | 91  |
+---------------------+--------------+--------------+-----------+-----+
| \% of trips with    | 77%          | 23%          | 0%        | 1   |
| arrival data        |              |              |           | 00% |
+---------------------+--------------+--------------+-----------+-----+
| \% of all late      | 37%          | 11%          | 52%       | 1   |
| cancels, missed     |              |              |           | 00% |
| trips, and no-shows |              |              |           |     |
+---------------------+--------------+--------------+-----------+-----+

[]{.mark}

Of the 1,725 trips dispatched 34, or 2.0 percent of the trips were
customer no-shows, 0 to 47 (0 to 2.7 percent) of the trips were late
cancellations, and 10 to 57 (0.6 to 3.3 percent) were missed trips.

[]{.mark}

**On-Time Performance**

[]{.mark}

On-time performance reported by Metro for the period July 2004 through
January 2005 appears in Table IX.4. For on-time performance measurement,
Metro considers trips on time if they are picked up between 15 minutes
before until 20 minutes after the scheduled time (-15/+20). This period
exceeds that told to customers (-15/+15). Metro also includes any trips
that are picked up before the beginning of the window as on time.

**Table IX.4 -- Metro On-Time Performance**

+------------------+----------------------+---------------+----------+
| **Month**        | **Total Trips**      | **On-Time     | **%**    |
|                  |                      | Trips**       |          |
|                  |                      |               | **O      |
|                  |                      |               | n-Time** |
+------------------+----------------------+---------------+----------+
| July 2004        | 56,319               | 55,193        | 98%      |
+------------------+----------------------+---------------+----------+
| August 2004      | 56,429               | 55,300        | 98%      |
+------------------+----------------------+---------------+----------+
| September 2004   | 56,749               | 55,614        | 98%      |
+------------------+----------------------+---------------+----------+
| October 2004     | 60,825               | 59,000        | 97%      |
+------------------+----------------------+---------------+----------+
| November 2004    | 52,635               | 50,530        | 96%      |
+------------------+----------------------+---------------+----------+
| December 2004    | 54,921               | 53,273        | 97%      |
+------------------+----------------------+---------------+----------+
| January 2005     | 54,492               | 52,312        | 96%      |
+------------------+----------------------+---------------+----------+
| **Total**        | **392,370**          | **81,223**    | **97%**  |
+------------------+----------------------+---------------+----------+

Metro does not compute Call-A-Ride performance for on-time drop-offs.

[]{.mark}

The review team analyzed Call-A-Ride's ADA on-time performance for the
February 9, 2005, sample data. Deducting the 91 trips that were not
completed from the 1,725 trips dispatched results in 1,634 completed ADA
trips on the sampled day.

[]{.mark}

For the 1,634 completed, or performed, passenger trips on the sample
day, to identify on-time, early, and late pickups, the promised pickup
was compared to the actual pickup time. Depending on the data available
for each trip, the on-time status was calculated in the following way:

-   For completed trips with no vehicle arrival time listed, the
    difference between promised pickup time and the actual "collect
    time" (the time when the passenger boards the vehicle) was
    calculated.

-   For completed trips with both arrival time and actual collect time
    data, the difference between promised pickup time and the earlier of
    arrival time or actual collect time was calculated.

As indicated in Table IX.5, for the sample day, 77.8 percent of trips
were picked up within 15 minutes of the scheduled time or on-time. 93.7
percent of trips were picked up either early or on-time, while 6.3
percent of trips were picked up late.

[]{.mark}

Table IX.5 -- Calculated On-Time Performance: February 9, 2005

  ----------------------- ----------- ------------ ------------ ------------
                          **On Time** **Early**    **Late**     **Total**

  **Number of Completed   1,271       260          103          1,634
  Trips**                                                       

  **% of Completed        77.8%       15.9%        6.3%         100%
  Trips**                                                       
  ----------------------- ----------- ------------ ------------ ------------

[]{.mark}

For early pickups, the concern is whether customers are pressured to
accept early pickups by drivers or dispatchers. To the extent that
customers find the early pickups convenient and have no objection, early
pickups do not represent a constraint to use of the service. Table IX.6
presents the distribution of early pickups from the beginning of the
pickup window. For example, "1-5 minutes early" is 16 to 20 minutes
before the scheduled time and one to five minutes before the beginning
of the -15/+15 pickup window. As indicated in the table, 88.6 percent of
the early pickups were within 15 minutes of the window. Pickups more
than 15 minutes early could be considered untimely pickups if the time
were not convenient for the customer.

[]{.mark}

Table IX.6 -- Early Pickups

  --------------------- ----------- ----------- ----------- ----------- -----------
                        **1-5       **6-15      **16-30     **\>30      **Total**
                        minutes**   minutes**   minutes**   minutes**   

  **Number of early     147         85          18          10          260
  trips**                                                               

  **% of early trips**  56.5%       32.7%       6.9%        3.9%        

  **Cumulative % of     56.5%       89.2%       96.1%       100.0%      
  early trips**                                                         
  --------------------- ----------- ----------- ----------- ----------- -----------

[]{.mark}

With late pickups, the service and regulatory concern is whether or not
there are a substantial number of significantly late pickups.
Accordingly, late trips were reviewed to identify how late the pickup
was relative to the -15/+15 pickup window.

[]{.mark}

As shown in Table IX.7, 81.6 percent of late pickups on the sample day
are within 30 minutes of the scheduled time and 15 minutes of the end of
the -15/+15 pickup window. Three pickups, or 0.2 percent of all trips,
were more than 30 minutes late. These trips could be considered
significantly late, but 3 trips of 1,634 trips do not appear to be a
substantial number of significantly late trips.

Table IX.7 -- Late Pickups

  -------------------------- ----------- ----------- ----------- ----------- ------------
                             **1-5       **6-15      **16-30     **\>30      **Totals**
                             minutes**   minutes**   minutes**   minutes**   

  **Number of Late Trips**   45          39          16          3           103

  **% of Late Trips**        43.7%       37.9%       15.5%       2.9%        

  **Cumulative % of Late     43.7%       81.6%       97.1%       100.00%     
  Trips**                                                                    

  **% of Completed Trips**   2.8%        2.4%        1.0%        0.2%        6.4%
  -------------------------- ----------- ----------- ----------- ----------- ------------

[]{.mark}

For the sample day, 93.7 percent of trips were performed early or
on-time. Including trips with arrival times no more than five minutes
after the pickup window---as Metro does in its performance
measurement---would result in early or on-time performance of 96.5
percent for the sample day. This is comparable to Metro's reported
on-time performance of 97 percent. An on-time performance rate of 95
percent equates to one late trip every two weeks for a traveler who
makes one round trip 5 days a week. This is a relatively high level of
on-time performance for an urban ADA complementary paratransit service.

**Drop-off Performance.** Of the 1,634 completed trips, 739 had
appointment times. To determine the number of on-time, early, and late
drop-offs, the appointment time was compared to the arrival time.
Depending on the on the data available for each of these trips, the
on-time status was calculated in the following way:

-   For completed trips with no arrival time listed, the difference
    between appointment time and the actual collect time (time when the
    passenger gets out of the vehicle) was calculated.

-   For completed trips with both arrival time and actual collect time
    data, the difference between appointment time requested and the
    earlier of arrival time or actual collect time was calculated.

[]{.mark}

Based on this analysis, of the 739 drop-offs, 617 (83.5 percent) were
early or on-time, while 122 (15 percent) were late. Both early and late
drop-offs were analyzed to identify the number of significantly early
and significantly late drop-offs.

[]{.mark}

Table IX.8 shows the distribution of early (before the appointment time)
drop-offs. Of the 617 early drop-offs, 59.4 percent were on-time or less
than 30 minutes early. Another 21.5 percent were 31 to 60 minutes early,
and 2.6 percent were more than an hour early. The 23 trips more than an
hour early are potentially a substantial number of trips that are
significantly untimely. Drop-offs more than one hour early can result in
customers left waiting on the sidewalk for the facility at their
destination to open. Drop-offs more than an hour before appointments can
be a constraint to use of the service by individuals who have
disabilities.

[]{.mark}

**[Table IX.8 -- Distribution of Early Drop-offs]{.mark}**

  ----------------- ----------- ----------- ----------- ----------- -----------
                    **0-15      **16-30     **31-60     **\>60      **Total**
                    minutes**   minutes**   minutes**   minutes**   

  **Early           233         206         159         19          617
  Drop-Offs**                                                       

  **% of Completed  31.5%       27.9%       21.5%       2.6%        83.5%
  appointments**                                                    

  **Cumulative % of 37.8%       71.2%       96.9%       100%        
  early drop-offs**                                                 
  ----------------- ----------- ----------- ----------- ----------- -----------

[]{.mark}

Late drop-offs for appointments can cause the customer to miss medical
appointments, classes, or cause late arrivals for work. As shown in
Table IX.9, for all trips with appointments, 16.5 percent of the
drop-offs were late; 4.6 percent were more than 15 minutes late and 2.4
percent were more than 30 minutes late.

[]{.mark}

Table IX.9 -- Distribution of Late Drop-offs

  ------------------ ----------- ----------- ----------- ----------- -----------
                     **1-15      **16-30     **31-60     **\>60      **Total**
                     minutes**   minutes**   minutes**   minutes**   

  **Late drop-offs** 88          16          17          1           122

  **% of Completed   11.9%       2.2%        2.3%        0.1%        16.5%
  appointments**                                                     

  **Cumulative % of  72.1%       85.2%       99.2%       100%        
  late drop-offs**                                                   
  ------------------ ----------- ----------- ----------- ----------- -----------

[]{.mark}

**Trip Duration**

[]{.mark}

The review team analyzed trip duration, or length, of Metro Call-A-Ride
trips to identify the number of long trips on the sample day. The
duration of long trips were compared to trips made between the same
origin and destination at the same time of day using fixed route
service. The purpose of the analysis was to identify the number of
potentially significantly long trips.

[]{.mark}

To conduct this analysis, the review team chose a sample of the longest
32 Call-A-Ride ADA trips completed on February 9, 2005. This sample
consists of trips that exceeded 80 minutes in travel time and represents
two percent of the completed trips.

[]{.mark}

The review team identified equivalent fixed route trips by calling the
Transit Information Line in Missouri (314-231-2345) listed on Metro's
website and speaking with a customer service representative. The Metro
representative was able to select the path with the shortest travel time
using the fixed route system at the same approximate time as the
negotiated pickup for each Call-A-Ride trip. In seven cases, the
customer service representative indicated that there was no equivalent
fixed route service available between trip origin and destination
points.

[]{.mark}

The total fixed route travel time includes the actual stop-to-stop
travel time, including time spent transferring. Twenty minutes were
added to the stop-to-stop time to account for walking to and from the
stops at either end of the trip and the initial wait for the bus. Of the
32 long trips sampled (including 6 for which there is no comparable
fixed route service), 21 trips (65.6 percent) had a travel time that
exceeded the equivalent fixed route travel time. These longer
paratransit trips are indicated with shaded rows in Table IX.10.

[]{.mark}

The results of the review for the 26 trips for which a fixed route
option was available are summarized in Table IX.11.

[]{.mark}

Table IX.11 -- Distribution of Long Trips

  --------------------------------------------------- ------------ ----------
                                                      **Number**   **% of
                                                                   Sample**

  **Equal to or faster than equivalent fixed route    5            19.2%
  service**                                                        

  **Slower than equivalent fixed route service by 1   2            7.7%
  to 15 min.**                                                     

  **Slower than equivalent fixed route service by 16  4            15.4%
  to 30 min.**                                                     

  **Slower than equivalent fixed route service by 31  8            30.8%
  to 45 min.**                                                     

  **Slower than equivalent fixed route service by 46+ 7            26.9%
  min.**                                                           

  **Total**                                           26           100.0%
  --------------------------------------------------- ------------ ----------

Of the sampled 26 long trips, 14 trips exceeded Metro's standard of 90
minutes for intra-zonal trips. This represents 0.9 percent of the
completed trips on the sample day. Of the sampled 26 trips for which a
fixed route option was available, fifteen trips were more than 30
minutes longer than a comparable fixed route trip; seven of these trips
were more than 46 minutes longer. These potentially significantly long
trips represent 0.9 percent and 0.4 percent of completed trips,
respectively.

**Table IX.10 -- Analysis of Trip Duration for Long Trips**

+---+--------------+--------------+---+---+----+---+---+-----------------+
|   | **Origin**   | **D          |   | * | *  |   |   | ####  a) (      |
|   |              | estination** |   | * | *F |   |   | Paratransit Tim |
|   |              |              |   | P | ix |   |   | e) -- (Fixed Ro |
|   |              |              |   | a | ed |   |   | ute Time) {#a-p |
|   |              |              |   | r | R  |   |   | aratransit-time |
|   |              |              |   | a | ou |   |   | -fixed-route-ti |
|   |              |              |   | - | te |   |   | me .unnumbered} |
|   |              |              |   | t | ** |   |   |                 |
|   |              |              |   | r | ** |   |   |                 |
|   |              |              |   | a | Ti |   |   |                 |
|   |              |              |   | n | me |   |   |                 |
|   |              |              |   | s | ** |   |   |                 |
|   |              |              |   | i |    |   |   |                 |
|   |              |              |   | t |    |   |   |                 |
|   |              |              |   | T |    |   |   |                 |
|   |              |              |   | r |    |   |   |                 |
|   |              |              |   | i |    |   |   |                 |
|   |              |              |   | p |    |   |   |                 |
|   |              |              |   | D |    |   |   |                 |
|   |              |              |   | u |    |   |   |                 |
|   |              |              |   | r |    |   |   |                 |
|   |              |              |   | a |    |   |   |                 |
|   |              |              |   | t |    |   |   |                 |
|   |              |              |   | i |    |   |   |                 |
|   |              |              |   | o |    |   |   |                 |
|   |              |              |   | n |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
+===+==============+==============+===+===+====+===+===+=================+
| * |              |              | * |   | ## | * | * |                 |
| * |              |              | * |   | ## | * | * |                 |
| T |              |              | F |   |    | W | T |                 |
| r |              |              | i |   | b) | a | o |                 |
| i |              |              | x |   |  T | l | t |                 |
| p |              |              | e |   | ra | k | a |                 |
| I |              |              | d |   | ns | * | l |                 |
| D |              |              | R |   | it | * | * |                 |
| * |              |              | o |   |    |   | * |                 |
| * |              |              | u |   | {# |   |   |                 |
|   |              |              | t |   | b- |   |   |                 |
|   |              |              | e |   | tr |   |   |                 |
|   |              |              | # |   | an |   |   |                 |
|   |              |              | ' |   | si |   |   |                 |
|   |              |              | s |   | t  |   |   |                 |
|   |              |              | * |   | .u |   |   |                 |
|   |              |              | * |   | nn |   |   |                 |
|   |              |              |   |   | um |   |   |                 |
|   |              |              |   |   | be |   |   |                 |
|   |              |              |   |   | re |   |   |                 |
|   |              |              |   |   | d} |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 1 | 5700 Pamplin | 10200 W      | 7 | 1 | 0: | 0 | 0 | **+0:48**       |
| 9 | Pl, St Louis | Florissant   | 4 | : | 14 | : | : |                 |
| 4 |              | Ave,         |   | 2 |    | 2 | 3 |                 |
|   |              | Dellwood     |   | 2 |    | 0 | 4 |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 3 | **8500       | 4200         | 1 | * | 0: | 0 | 0 | **+0:57**       |
| 0 | Mackenzie    | Tholozan Av, | 0 | * | 15 | : | : |                 |
| 4 | Rd, County** | St. Louis    |   | 1 |    | 2 | 3 |                 |
|   |              |              |   | : |    | 0 | 5 |                 |
|   |              |              |   | 3 |    |   |   |                 |
|   |              |              |   | 2 |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 7 | 1500 Gene    | 9400 Dielman | 3 | * | 1: | 0 | 1 | +0:40           |
| 7 | Crayton Ave, | Industrial   | 6 | * | 18 | : | : |                 |
| 2 | County       | Dr, Olivette | , | 2 |    | 2 | 3 |                 |
|   |              |              | 1 | : |    | 0 | 8 |                 |
|   |              |              | 6 | 1 |    |   |   |                 |
|   |              |              | , | 8 |    |   |   |                 |
|   |              |              | 9 | * |    |   |   |                 |
|   |              |              | 1 | * |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 1 | 8800         | 200 Hewlett  | 4 | * | 0: | 0 | 1 | **+0:57**       |
| 0 | Fleischer    | Ct, Creve    | 7 | * | 47 | : | : |                 |
| 0 | Pl, Berkeley | Coeur        | , | 2 |    | 2 | 0 |                 |
| 1 |              |              | 9 | : |    | 0 | 7 |                 |
|   |              |              | 3 | 0 |    |   |   |                 |
|   |              |              |   | 4 |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 1 | 5700 Delmar  | 400          | 9 | 1 | 1: | 0 | 1 | -0:02           |
| 1 | Av, St Louis | Limestone    | 7 | : | 04 | : | : |                 |
| 0 |              | Pl, Kirkwood | , | 2 |    | 2 | 2 |                 |
| 6 |              |              | 4 | 2 |    | 0 | 4 |                 |
|   |              |              | 7 |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 1 | 6300         | 200 Afshari  | N | * | \- | \ | \ | \-              |
| 2 | Howdershell  | Dr, County   | o | * |    | - | - |                 |
| 1 | Rd, County   |              | s | 1 |    |   |   |                 |
| 3 |              |              | e | : |    |   |   |                 |
|   |              |              | r | 4 |    |   |   |                 |
|   |              |              | v | 9 |    |   |   |                 |
|   |              |              | i | * |    |   |   |                 |
|   |              |              | c | * |    |   |   |                 |
|   |              |              | e |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 1 | 2600 Clark   | 3200         | N | * | \- | \ | \ | \-              |
| 5 | Av, St Louis | Parkwood Ln, | o | * |    | - | - |                 |
| 9 |              | Maryland     | s | 1 |    |   |   |                 |
| 5 |              | Height       | e | : |    |   |   |                 |
|   |              |              | r | 3 |    |   |   |                 |
|   |              |              | v | 8 |    |   |   |                 |
|   |              |              | i | * |    |   |   |                 |
|   |              |              | c | * |    |   |   |                 |
|   |              |              | e |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 1 | 4200 Forest  | 1300         | 4 | * | 0: | 0 | 1 | +0:20           |
| 7 | Park Av, St  | Partridge    | 2 | * | 54 | : | : |                 |
| 8 | Louis        | Av,          | , | 1 |    | 2 | 1 |                 |
| 5 |              | University   | 9 | : |    | 0 | 4 |                 |
|   |              | City         | 4 | 3 |    |   |   |                 |
|   |              |              |   | 4 |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 2 | 11200        | 10200 W      | 2 | 1 | 0: | 0 | 0 | +0:37           |
| 4 | Estrada Dr,  | Florissant   | 4 | : | 29 | : | : |                 |
| 8 | County       | Av, Dellwood | 1 | 2 |    | 2 | 4 |                 |
| 3 |              |              | X | 6 |    | 0 | 9 |                 |
|   |              |              | , |   |    |   |   |                 |
|   |              |              | 6 |   |    |   |   |                 |
|   |              |              | 1 |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 2 | 1200 Spruce, | 100 Taney    | 2 | 1 | 0: | 0 | 1 | +0:15           |
| 5 | St Louis     | Dr,          | 7 | : | 50 | : | : |                 |
| 7 |              | Florissant   | 4 | 2 |    | 2 | 1 |                 |
| 0 |              |              | X | 5 |    | 0 | 0 |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 3 | **8500       | 2700 Meramec | 1 | * | 0: | 0 | 0 | **+1:03**       |
| 3 | Mackenzie    | St, St.      | 0 | * | 29 | : | : |                 |
| 9 | Rd, County** | Louis        | , | 1 |    | 2 | 4 |                 |
| 6 |              |              | 7 | : |    | 0 | 9 |                 |
|   |              |              | 0 | 5 |    |   |   |                 |
|   |              |              |   | 2 |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 3 | 1000         | 2700 Thomas  | 9 | * | 1: | 0 | 1 | +0:17           |
| 4 | Executive    | St, St Louis | 1 | * | 27 | : | : |                 |
| 6 | Parkway Dr,  |              | , | 2 |    | 2 | 4 |                 |
| 6 | County       |              | 1 | : |    | 0 | 7 |                 |
|   |              |              | 6 | 0 |    |   |   |                 |
|   |              |              | , | 4 |    |   |   |                 |
|   |              |              | 3 | * |    |   |   |                 |
|   |              |              | 2 | * |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 3 | 3200         | 9200 Harold  | M | * | 0: | 0 | 1 | +0:43           |
| 6 | DeBaliviere  | Dr, Woodson  | e | * | 49 | : | : |                 |
| 8 | Ave, St      | Terrace      | t | 1 |    | 2 | 0 |                 |
| 2 | Louis        |              | r | : |    | 0 | 9 |                 |
|   |              |              | o | 5 |    |   |   |                 |
|   |              |              | L | 2 |    |   |   |                 |
|   |              |              | i | * |    |   |   |                 |
|   |              |              | n | * |    |   |   |                 |
|   |              |              | k |   |    |   |   |                 |
|   |              |              | , |   |    |   |   |                 |
|   |              |              | 6 |   |    |   |   |                 |
|   |              |              | 6 |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 4 | 3200 January | 9700 Page    | 9 | * | 0: | 0 | 1 | +0:42           |
| 2 | Av, St Louis | Ave,         | 0 | * | 46 | : | : |                 |
| 6 |              | Overland     | , | 1 |    | 2 | 0 |                 |
| 6 |              |              | 9 | : |    | 0 | 6 |                 |
|   |              |              | 4 | 4 |    |   |   |                 |
|   |              |              |   | 8 |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 4 | 9700 Calumet | 4200 Forest  | 3 | * | 0: | 0 | 1 | +0:32           |
| 4 | Drive,       | Park Av, St  | 6 | * | 54 | : | : |                 |
| 6 | B            | Louis        | , | 1 |    | 2 | 1 |                 |
| 6 | ellefontaine |              | 4 | : |    | 0 | 4 |                 |
|   |              |              | 0 | 4 |    |   |   |                 |
|   |              |              | , | 6 |    |   |   |                 |
|   |              |              | 4 | * |    |   |   |                 |
|   |              |              | 2 | * |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 4 | 8800         | 2400 Wengler | 4 | 1 | 0: | 0 | 0 | +0:30           |
| 6 | Fleischer    | Av, Overland | 7 | : | 39 | : | : |                 |
| 7 | Pl, Berkeley |              | , | 2 |    | 2 | 5 |                 |
| 6 |              |              | 3 | 9 |    | 0 | 9 |                 |
|   |              |              | 3 |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 4 | 800 N New    | 2600         | 9 | 1 | 2: | 0 | 2 | -1:17           |
| 9 | Ballas Rd,   | Whittier St, | 1 | : | 26 | : | : |                 |
| 6 | Creve Coeur  | St Louis     | , | 2 |    | 2 | 4 |                 |
| 7 |              |              | M | 9 |    | 0 | 6 |                 |
|   |              |              | e |   |    |   |   |                 |
|   |              |              | t |   |    |   |   |                 |
|   |              |              | r |   |    |   |   |                 |
|   |              |              | o |   |    |   |   |                 |
|   |              |              | L |   |    |   |   |                 |
|   |              |              | i |   |    |   |   |                 |
|   |              |              | n |   |    |   |   |                 |
|   |              |              | k |   |    |   |   |                 |
|   |              |              | , |   |    |   |   |                 |
|   |              |              | 4 |   |    |   |   |                 |
|   |              |              | 2 |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 5 | 3100 Autumn  | 6300 Olive   | N | 1 | \- | \ | \ | \-              |
| 0 | Shores Dr,   | Blvd,        | o | : |    | - | - |                 |
| 7 | Maryland     | University   | s | 2 |    |   |   |                 |
| 1 | Height       | City         | e | 5 |    |   |   |                 |
|   |              |              | r |   |    |   |   |                 |
|   |              |              | v |   |    |   |   |                 |
|   |              |              | i |   |    |   |   |                 |
|   |              |              | c |   |    |   |   |                 |
|   |              |              | e |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 5 | 2100 Arsenal | **8500       | 3 | 1 | 0: | 0 | 0 | +0:33           |
| 2 | St, St.      | Mackenzie    | 0 | : | 37 | : | : |                 |
| 0 | Louis        | Rd, County** | , | 3 |    | 2 | 5 |                 |
| 3 |              |              | 1 | 0 |    | 0 | 7 |                 |
|   |              |              | 0 |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 5 | **8500       | 2100 Arsenal | 1 | * | 0: | 0 | 0 | **+0:49**       |
| 2 | Mackenzie    | St, St.      | 0 | * | 37 | : | : |                 |
| 0 | Rd, County** | Louis        | , | 1 |    | 2 | 5 |                 |
| 4 |              |              | 3 | : |    | 0 | 7 |                 |
|   |              |              | 0 | 4 |    |   |   |                 |
|   |              |              |   | 6 |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 5 | 11300 Big    | 2800         | N | * | \- | \ | \ | \-              |
| 2 | Bend Blvd,   | Woodbridge   | o | * |    | - | - |                 |
| 6 | Kirkwood     | Estates Dr,  | s | 1 |    |   |   |                 |
| 9 |              | County       | e | : |    |   |   |                 |
|   |              |              | r | 3 |    |   |   |                 |
|   |              |              | v | 3 |    |   |   |                 |
|   |              |              | i | * |    |   |   |                 |
|   |              |              | c | * |    |   |   |                 |
|   |              |              | e |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 5 | 3100 Market  | 1900         | N | * | \- | \ | \ | \-              |
| 5 | St, St Louis | Schoettler   | o | * |    | - | - |                 |
| 6 |              | Valley Dr,   | s | 2 |    |   |   |                 |
| 0 |              | Chesterfield | e | : |    |   |   |                 |
|   |              |              | r | 3 |    |   |   |                 |
|   |              |              | v | 9 |    |   |   |                 |
|   |              |              | i | * |    |   |   |                 |
|   |              |              | c | * |    |   |   |                 |
|   |              |              | e |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 5 | 700 Teson    | 9600         | 6 | * | 0: | 0 | 0 | +0:41           |
| 6 | Road,        | Lackland Rd, | 6 | * | 34 | : | : |                 |
| 5 | Hazelwood    | Overland     |   | 1 |    | 2 | 5 |                 |
| 7 |              |              |   | : |    | 0 | 4 |                 |
|   |              |              |   | 3 |    |   |   |                 |
|   |              |              |   | 5 |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 5 | 10400        | 7300         | 9 | 1 | 0: | 0 | 0 | +0:27           |
| 9 | Trenton,     | Esterbrook   | 4 | : | 35 | : | : |                 |
| 7 | Creve Coeur  | Dr, Jennings | , | 2 |    | 2 | 5 |                 |
| 8 |              |              | 6 | 2 |    | 0 | 5 |                 |
|   |              |              | 4 |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 7 | 5800         | 500 Ruthland | 9 | 1 | 1: | 0 | 1 | -0:14           |
| 4 | Manchester   | Dr, County   | 0 | : | 17 | : | : |                 |
| 0 | Av, St Louis |              | , | 2 |    | 2 | 3 |                 |
| 3 |              |              | 4 | 3 |    | 0 | 7 |                 |
|   |              |              | 0 |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 8 | 3100 Arsenal | 2000 Kratky  | 3 | * | 1: | 0 | 1 | +0:43           |
| 0 | St, St Louis | Rd, Creve    | 0 | * | 20 | : | : |                 |
| 1 |              | Couer        | , | 2 |    | 2 | 4 |                 |
| 6 |              |              | M | : |    | 0 | 0 |                 |
|   |              |              | e | 2 |    |   |   |                 |
|   |              |              | t | 3 |    |   |   |                 |
|   |              |              | r | * |    |   |   |                 |
|   |              |              | o | * |    |   |   |                 |
|   |              |              | L |   |    |   |   |                 |
|   |              |              | i |   |    |   |   |                 |
|   |              |              | n |   |    |   |   |                 |
|   |              |              | k |   |    |   |   |                 |
|   |              |              | , |   |    |   |   |                 |
|   |              |              | 9 |   |    |   |   |                 |
|   |              |              | 4 |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 8 | 8400         | 2000 Walton  | 9 | * | 0: | 0 | 0 | **+1:26**       |
| 1 | Crixdale Av, | Rd, Overland | 1 | * | 27 | : | : |                 |
| 7 | University   |              | , | 2 |    | 2 | 4 |                 |
| 7 | City         |              | 9 | : |    | 0 | 7 |                 |
|   |              |              | 4 | 1 |    |   |   |                 |
|   |              |              |   | 3 |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 8 | 300 Dunn Rd, | 1100 Maple   | 4 | 1 | 1: | 0 | 1 | 0:00            |
| 5 | Florissant   | Ave, County  | 7 | : | 09 | : | : |                 |
| 6 |              |              | , | 2 |    | 2 | 2 |                 |
| 4 |              |              | 3 | 9 |    | 0 | 9 |                 |
|   |              |              | 6 |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 8 | 4600 World   | 4300 Cote    | 4 | 1 | 0: | 0 | 1 | +0:14           |
| 9 | Parkway      | Brilliante,  | 9 | : | 55 | : | : |                 |
| 9 | Circle,      | St Louis     | , | 2 |    | 2 | 1 |                 |
| 3 | Berkeley     |              | M | 9 |    | 0 | 5 |                 |
|   |              |              | e |   |    |   |   |                 |
|   |              |              | t |   |    |   |   |                 |
|   |              |              | r |   |    |   |   |                 |
|   |              |              | o |   |    |   |   |                 |
|   |              |              | L |   |    |   |   |                 |
|   |              |              | i |   |    |   |   |                 |
|   |              |              | n |   |    |   |   |                 |
|   |              |              | k |   |    |   |   |                 |
|   |              |              | , |   |    |   |   |                 |
|   |              |              | 1 |   |    |   |   |                 |
|   |              |              | 8 |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 9 | 7200 Weil    | 14800        | N | 1 | \- | \ | \ | \-              |
| 0 | Ave,         | Chesterfield | o | : |    | - | - |                 |
| 4 | Shrewsbury   | Trails Dr,   | s | 2 |    |   |   |                 |
| 5 |              | Chesterfield | e | 2 |    |   |   |                 |
|   |              |              | r |   |    |   |   |                 |
|   |              |              | v |   |    |   |   |                 |
|   |              |              | i |   |    |   |   |                 |
|   |              |              | c |   |    |   |   |                 |
|   |              |              | e |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 9 | 4200 Forest  | 11000 Sugar  | 5 | 1 | 1: | 0 | 1 | -0:03           |
| 6 | Park Av, St  | Pine Ct,     | 2 | : | 12 | : | : |                 |
| 7 | Louis        | Florissant   | , | 2 |    | 2 | 3 |                 |
| 7 |              |              | M | 9 |    | 0 | 2 |                 |
|   |              |              | e |   |    |   |   |                 |
|   |              |              | t |   |    |   |   |                 |
|   |              |              | r |   |    |   |   |                 |
|   |              |              | o |   |    |   |   |                 |
|   |              |              | L |   |    |   |   |                 |
|   |              |              | i |   |    |   |   |                 |
|   |              |              | n |   |    |   |   |                 |
|   |              |              | k |   |    |   |   |                 |
|   |              |              | , |   |    |   |   |                 |
|   |              |              | 2 |   |    |   |   |                 |
|   |              |              | 7 |   |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+
| 9 | **8500       | 3800         | 1 | * | 0: | 0 | 1 | **+0:49**       |
| 9 | Mackenzie    | Missouri Av, | 0 | * | 47 | : | : |                 |
| 9 | Rd, County** | St Louis     | , | 1 |    | 2 | 0 |                 |
| 6 |              |              | 7 | : |    | 0 | 7 |                 |
|   |              |              | 0 | 5 |    |   |   |                 |
|   |              |              |   | 6 |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
|   |              |              |   | * |    |   |   |                 |
+---+--------------+--------------+---+---+----+---+---+-----------------+

Note: street addresses rounded to nearest 100 block

As indicated in Table IX.10, five of the trips that were more than 30
minutes longer than a comparable fixed route trip were to or from the
same location (address listed in **BOLD**). Of these five trips, four
were more than 45 minutes longer than the comparable fixed route
trip---creating what appears to be a pattern of significantly long
trips. This pattern may result from transporting a large number of
passengers on a trip to and or from an activity center. Transporting
large numbers of people on one vehicle can result in long travel times
for the first to board on the going trip or last to alight on the return
trip. Trip lengths can be shortened by splitting large groups into
smaller groups to provide a more direct trip for the first to board or
last to alight on the going and return trips, respectively.

[]{.mark}

**Findings**

1.  Metro's policy standard for service denials does not appear to
    consider all denials. Metro's policy standard is zero denials for
    requests made the previous day. Metro accepts service requests seven
    days in advance of the service day, and "Metro Call-A-Ride Easy
    Trips" brochure encourages customers to call early to make trip
    reservations. Denying a trip more than one day in advance of the
    service day, thereby requiring multiple calls to schedule a trip,
    appears to limit access to the service and constitute a capacity
    constraint.

2.  The review team's analysis of a one-day sample indicates that 42 (2
    percent) of trip requests for service on February 9, 2005 were
    denied. During the period June through December 2004 Metro reported
    next day denials of 0.6 percent. Metro indicated that some customers
    who are denied service more than one day in advance of the service
    day call back and eventually reserve their requested trip.

3.  Metro appears to have no policy for missed trips.

4.  Based upon a review of Call-A-Ride data reports for February 9,
    2005, it appears that Metro does not record missed trips as a
    category for performance monitoring purposes. Missed trips appear to
    be grouped with customer no-shows and late cancellations.

5.  Analysis of data for the sample day indicated that for 10 trips (0.6
    percent of the 1,752 ADA trips dispatched on the service day) that
    were not completed; the vehicle arrived at the pickup address more
    than 15 minutes after the scheduled time. For 47 trips (2.7 percent)
    that were not completed, there was no vehicle arrival time. All of
    these trips could be missed trips---resulting in as many as 57 (3.3
    percent) missed trips. Some of these trips could also be late
    cancellations.

6.  Metro has two standards for on-time performance. For the customer,
    the standard for on-time is a vehicle arrival between 15 minutes
    before and 15 minutes after (-15/+15) the scheduled time. For
    performance measurement and reporting the standard is 15 minutes
    before and 20 minutes after (-15/+20) the scheduled time. Use of one
    standard for the customer and a more generous standard for
    performance measurement overstates the level of service being
    provided to the customer.

7.  Based on an on-time window of 15 minutes before to 15 minutes after
    (-15/+15), 93.7 percent of customers were picked up either early or
    on-time, and 6.3 percent of customers were picked up late on the
    sample day. Of the late trips, 19 (1.2 percent of completed trips)
    were more than 15 minutes late and, of those, 3 (0.2 percent) were
    more than 30 minutes late. Based on this sample there do not appear
    to be a significant number of substantially late pickups.

8.  On the sample day, there were 260 passengers (15.9 percent of
    completed trips) picked up early. Of that number, 28 (1.7 percent of
    completed trips) were picked up more than 16 minutes early; of those
    trips, 10 (0.6 percent of completed trips) were picked up more than
    30 minutes early. Very early pickups could indicate that customers
    are being pressured to accept early departures.

9.  Of 739 trips with scheduled drop-off or appointment times, 617 (83.5
    percent) were early or on-time and 122 (16.5 percent) were late. Of
    these late drop-offs, 34 (4.6 percent) were more than 15 minutes
    late; of this number, 18 (2.4 percent) were more than 30 minutes
    late. These late drop-offs, potentially resulting in late arrivals
    for work, school, or medical appointments, could be considered a
    constraint to use of the service by paratransit eligible
    individuals.

10. From a sample of 26 long trips on February 9, 2005, 14 (0.9 percent
    of the completed trips) exceeded Metro's standard of 90 minutes for
    intra-zonal trips. 15 (0.9 percent) of the 29 long trips sampled
    were more than 30 minutes longer than a comparable fixed route trip
    and 7 (0.4 percent) were more than 46 minutes longer. Five of the
    trips that were more than 30 minutes longer than a comparable fixed
    route trip were to or from the same location. This appears to be a
    pattern of significantly long trips.

[]{.mark}

**Recommendations**

1.  Metro should adopt a policy goal of zero denials for all trip
    requests regardless of how far in advance they are made before the
    close of business on the day before service.

2.  Metro should review its procedure for measuring trip denials to
    assure that it is identifying and counting all denials in its
    performance measurement and reporting.

3.  Metro should adopt a performance standard for missed trips.

4.  Metro should modify its procedures for performance measurement to
    include identification and measurement of missed trips.

5.  Metro should monitor missed trips and take action as necessary to
    minimize the number of missed trips such that there are not a
    substantial number of missed trips.

6.  Metro should use the on-time performance window that it communicates
    to customers as the standard for measuring and reporting on-time
    performance.

7.  Metro should monitor the number and time of early pickups to assure
    that customers are not being pressured to accept trips before the
    agreed upon pickup window.

8.  Metro should monitor late drop-offs and take action to minimize the
    number and extent of late drop-offs in order to assure that
    availability of service is not limited by untimely service.

9.  Metro should monitor trip duration to identify significantly long
    trips and take corrective actions as necessary, such as limiting the
    size of large groups traveling together on one vehicle.

## Transportation Operations

[]{.mark}

**Dispatching**

Metro performs all dispatching for Call-A-Ride services at its
operations center at 3300 Spruce Street, where all other Call-A-Ride
operations activities take place. The Call-A-Ride dispatchers oversee
vehicles for demand-responsive service as well as other Call-A-Ride
service, such as the Chesterfield Connector, though they devote most of
their attention to the demand-responsive services. At all times, there
is a lead dispatcher. At peak times, Call-A-Ride has a total of three
dispatchers. Other times, Call-A-Ride may have either one or two
dispatchers.

When there are two or three dispatchers working, there is no explicit
allocation of work among the dispatchers, i.e., no particular runs or
geographic areas assigned to each dispatcher. Overall, they are looking
at whether vehicles are running on or ahead of schedule. Each vehicle is
equipped with both a two-way radio and a mobile data terminal (MDT)
which is used to provide drivers with schedule information, track
performance, and communicate between drivers and dispatchers. The
dispatchers noted that most drivers are diligent in entering or
"performing" their pickups and drop-offs on MDTs. Drivers are
continually updating their schedule manifests via MDTs, so the
dispatchers can see updated estimated times of arrival (ETAs) on the
PASS dispatch screens. Drivers use both the MDTs and radios to
communicate with the dispatchers. The MDTs can transmit limited
messages. As a result, drivers often respond via radio to dispatcher
questions (e.g., location, time to next pickup or drop-off) sent over
the MDT.

[]{.mark}

While Call-A-Ride has about 95 vehicle runs or routes on weekdays,
during the morning and afternoon peaks, there may be 60 vehicles on the
road. Based on the number of vehicles out during the peak, it appears
that Metro has sufficient dispatcher coverage for Call-A-Ride
operations.

[]{.mark}

Metro maintenance staff makes the actual assignment of vehicles to run
each day. They account for the availability of vehicles due to repairs
or other maintenance issues. To some extent, they also try to balance
the mileages of vehicles. Metro does not regularly assign the same
vehicle to a driver.

[]{.mark}

The dispatchers perform the typical activities of a paratransit
operation. They take customer calls on ride status ("Where's My Ride?")
and contact drivers to obtain the ETA. When a driver radios that he or
she cannot locate a rider, a dispatcher tries to call the rider.
Call-A-Ride has home telephone numbers for most riders, plus some cell
phone numbers. They have a limited set of telephone numbers for trip
destinations. A dispatcher must approve a driver's request for a
passenger no-show. Even so, Metro has a "no strand" policy for riders
with return trips. If a rider calls after the vehicle has left, Metro
will not record this as a passenger no-show, but will re-classify the
trip as a will-call for later pickup. This practice, if not done
properly, can result in misclassification of trips. If the customer is
not ready for the pickup the trip should be classified as either a
no-show or a "no fault" no-show. A no fault no-show would occur due to
circumstances beyond the customer's control---such as medical status.
Metro should then schedule a new will-call trip for the customer.
Failure to schedule a new trip can result in a trip record that would
appear to be a late pickup or a missed trip.

[]{.mark}

On weekdays, Call-A-Ride has five clean-up runs that start in the early
morning and extend to early afternoon. These clean-up runs have assigned
drivers and vehicles but no pre-assigned passenger trips. There are an
additional five clean-up runs that start in early afternoon and continue
to the end of the service day. Table IX.12 lists the Call-A-Ride
clean-up runs.

[]{.mark}

**Table IX.12 -- Call-A-Ride "Clean-Up" Runs**

  --------------------------- ----------------------- --------------------
  **Run Number**              **Start Time**          **End Time**

  Morning Runs                                        

  601                         5:15 a.m.               11:00 a.m.

  603                         5:15 a.m.               1:45 p.m.

  605                         4:15 a.m.               1:45 p.m.

  607                         3:30 a.m.               2:00 p.m.

  609                         5:15 a.m.               1:45 p.m.

  Evening Runs                                        

  602                         11:00 a.m.              7:30 p.m.

  604                         1:45 p.m.               10:15 p.m.

  606                         1:45 p.m.               11:15 p.m.

  608                         2:00 p.m.               12:30 a.m.

  610                         1:45 p.m.               10:15 p.m.
  --------------------------- ----------------------- --------------------

[]{.mark}

The vehicles for these runs are stationed in the various Call-A-Ride
service zones. The lead morning and afternoon dispatchers prefer to have
one each in the south, west, north, and city zones, with one at the
operations center. They are used to cover trips of vehicles that are
running late or have a road call. The clean-up runs also handle
will-call trips. In addition, Call-A-Ride has spare or extra-board
drivers assigned for every shift that may also serve as clean-up
drivers. Dispatchers are conscious of pickup times and try to maintain a
high on-time performance for pickups.

[]{.mark}

Both the morning and afternoon lead dispatchers appreciate the
flexibility that the clean-up runs provide them. They sometimes have to
reduce the number of clean-up runs to cover for an otherwise uncovered
run (e.g., usually for a driver absence). They do not want to eliminate
the clean-up runs completely, even if that means having to close a
scheduled run and re-assign all of its trips to other runs (which they
said occurs several times per month). If needed, they can keep drivers
on the road beyond their scheduled shift times. The dispatchers did not
favor reducing the clean-up runs to create runs that have trips assigned
to them---which could create additional capacity for the denied trips.

Over the course of a weekday, Call-A-Ride may have 20 or more trips on
its "Route 0," the will-call route. These trips are medical will-calls,
the rescheduled trips of no-shows, and an occasional same-day trip
request (not officially allowed by Metro policy). Dispatchers are always
looking for available time on the existing runs to insert these trips.
Many of the open slots arise from late cancellations and no-shows. When
asked if the denied trips could be placed on Route 0 for same-day
scheduling, the dispatchers indicated that this was a potential
solution. However, its full effectiveness would depend on the number of
denials that would be added to Route 0.

[]{.mark}

The dispatchers closely monitor passenger trips that require transfers:
both transfers between Metro fixed route vehicles and transfers between
Metro and ATS or ACT paratransit services in Illinois. If the
destination is within two miles of the Metro service area (or Metro
service zone), then Metro will provide a direct trip and avoid a
transfer. When a passenger trip requires a transfer, Call-A-Ride
schedules the drop-off or pickup time for its vehicles without
necessarily ensuring that the rider has a direct vehicle-to-vehicle
transfer.

[]{.mark}

The lead afternoon dispatcher also has several other tasks that he works
on as the afternoon peak service demands diminish. He prepares the
"paddles" (printed route manifests, clip boards, vehicle assignments,
and keys) for the next morning's shifts.

**Driver Operations**

The review team interviewed 11 Call-A-Ride drivers over two days at the
Metro Call-A-Ride facility to get a sense of whether drivers have
adequate resources, training, and understanding of procedures to provide
effective service with respect to ADA complementary paratransit
performance criteria. Information gained from the interviews can be
helpful in identifying driver issues that could affect service
performance. The overall results of the interviews are summarized as
follows:

-   Drivers consistently understand Metro procedures, including the
    definition of the pickup window and no-show procedures.

-   Drivers believe the training is good.

-   Drivers report vehicle maintenance and repair to be excellent.

-   Dispatch provides support for late trips, often intervening before
    the driver identifies a problem.

Responses to specific elements of the interview are further described
below:

**Training.** The drivers have up to five weeks of training: two weeks
in class and three weeks on the road with an instructor. They receive
ADA training and sensitivity training, which includes having customers
with various disabilities come in to talk to the drivers. Some of the
drivers noted that this was very informative.

**Vehicles.** All drivers indicated that the vans were well maintained.
In-service breakdowns are rare: less than one breakdown per driver per
year. Maintenance is very responsive with both fixing small things noted
on the daily inspection sheet and dispatching a tow truck and spare
vehicle if a passenger is on a disabled van.

**Schedule.** Drivers indicated that sometimes the sequence of pickups
does not make sense or provide enough time between trips. Some drivers
indicated that schedules have become harder to maintain in the past
month because there is less slack time built into the schedule. Drivers
are expected to find their own way between pickups by using the map
book. More experienced drivers are able to get around better than newer
drivers, as would be expected.

**Operating Procedures.** Every driver knew the definition of the
15-minute early and late (‑15/+15) on-time pickup window. They also
understood the procedure to follow for a customer no-show. Drivers noted
that if they are running late, dispatch often reacts proactively and
will modify their route schedule. Dispatch is monitoring their on-time
performance through the MDTs.

**Other comments.** Overall, the drivers like their job and they hate
being late.

**Findings**

1.  Dispatchers appear to monitor and control service so as to avoid
    missed trips and maintain a high level of on-time performance.

2.  Dispatchers appear to have effective procedures in place to minimize
    customer no-shows. Dispatchers attempt to contact passengers if
    drivers are unable to find them at the pickup location.

3.  Metro has a "no strand" policy for riders with return trips. If a
    rider calls after the vehicle has left, Metro will not record this
    as a passenger no-show, but will re-classify the trip as a will-call
    for later pickup.

4.  Metro appears to have the capacity to accommodate some trips that
    could not be scheduled before the service day by assigning those
    trips to "Route 0," as well as using capacity made available from
    cancellations and available on the "clean up" runs. This capacity
    could be used to reduce or eliminate trip denials.

5.  Call-A-Ride appears to have sufficient dispatch coverage to
    effectively monitor and control service.

6.  Drivers appear to be well trained and have the resources including
    vehicles and dispatch support to perform their job.

7.  Drivers cited illogical routing and tight schedules as a concern.

[]{.mark}

**Recommendations**

[]{.mark}

1.  Dispatchers should modify their "no strand" policy by classifying
    the return trip missed by the customer as either a regular or
    no-fault no-show and initiate a new "will-call" trip for the
    customer. This will assure that the trips are not misclassified as
    operator missed trips or very late pickups.

2.  Metro should assign trips which are currently denied to the "0" run,
    which dispatchers can then schedule to capacity that becomes
    available by cancellations or no-shows. Metro should implement this
    practice in increments to avoid significant adverse impacts on
    missed or late trips. For example, initially 10 unscheduled trips
    could be scheduled to the "0" run at the beginning of the service
    day with the number increased by 10 per day depending on capacity to
    effectively serve these trips. If service is adversely impacted,
    Metro should increase capacity by adding runs until all denials are
    eliminated, while maintaining acceptable service performance.

3.  Metro should continue to monitor and refine schedules through
    scheduling parameters, proofing, and dispatching to minimize
    illogical routing and schedules that are too tight.

# Resources

As part of this review, team members collected and analyzed information
about the adequacy of resources available to provide the ADA
complementary paratransit service as required by the DOT ADA
regulations. The purpose of this analysis was to identify the potential
of resource limits to constrain service for ADA eligible customers. The
review included:

[]{.mark}

-   Input from consumers.

-   Review of adequacy of equipment, particularly the vehicle fleet and
    the availability of vehicles to cover scheduled routes.

-   Review of staffing, including availability of drivers to cover
    scheduled routes.

-   The operating budget for the service and the process used to
    estimate funding needs.

Following is a summary of observations in each of these areas.

**Consumer Input**

[]{.mark}

Input collected from the perspective of consumers to assist the
reviewers in identifying compliance issues of concern is summarized in
Section III of this report. Input was collected from review of
complaints on file with FTA, consumer interviews, and review of customer
complaints on file with Metro. Of the issues raised, three potentially
relate to overall service capacity:

[]{.mark}

-   **Delay in the eligibility process**: A more expedient eligibility
    process could result in some increase in trip requests.

-   **Telephone access**: reduced hold times could result in increased
    trip requests.

-   **Trip denials**: elimination of denials could result in the need
    for additional service capacity.

**Telephone Access**

As discussed in Section VII of this report, telephone access appears to
limit the availability of service to ADA complementary paratransit
eligible individuals. The new computer reservations system may help to
relieve this problem by reducing call times. Accepting all trip requests
by removing limits on the number of trip requests per call should also
help to reduce call volumes and call times. Even with these changes in
procedures, there may still be insufficient reservations staffing to
reduce hold times to levels that do not limit customer access to
service. Of 16 work stations, 14 are available to reservationists.
Currently there are usually eight or fewer reservationists actively
assigned to work at any one time. Accordingly, there appears to be
sufficient equipment and work area capacity available at present to
serve both existing and increased reservationist staff positions.

Scheduling and Dispatch

As discussed in Section VIII of this report, scheduling staffing and
equipment appear to be adequate. Computer upgrades planned at the time
of the review are expected to make the reservations and scheduling
process more efficient.

The dispatch staffing levels appear to be adequate to effectively
address service needs.

**Transportation**

Call-A-Ride managers indicated that they needed 204 drivers to cover
scheduled weekday runs. An additional 29 drivers are assigned to "extra
board" or backup to cover for scheduled and unscheduled driver absences
or unusual service needs. Managers indicated that approximately nine
extra board drivers are assigned to service on a typical day.
Absenteeism averages approximately 3.5 percent. Accordingly, average
daily needs for service are 213 drivers with 233 including extra board
drivers. There is also an allowance for driver overtime of approximately
seven percent built into schedules. The overtime reflects the efficiency
of extending driver shifts for an hour or two to meet service needs
rather than assigning a different driver for a whole shift. For budget
purposes, Call-A-Ride is authorized 236 driver positions, which allows
for some inactive drivers, or drivers who are unable to work for an
extended period. As seen in Table X.1, the monthly complement of
available drivers from September 2004 through February 2005 ranged from
221 to 230. The manpower roster has been sufficient to cover the
schedule need of 204 plus assigned extra board, 213, with additional
available extra board of 8 to 17 drivers.

**Table X.1 -- Call-A-Ride Operator Availability**

  -------------- ---------------- ---------------- ----------- --------------- -------------- ------------------
  **Period**     **Authorized**   **Inactive\***   **Total**   **Available**   **Variance**   **Trainees\*\***

  September 2004 236              0                236         227             -9             5

  October 2004   236              1                237         222             -14            14

  November 2004  236              1                237         230             -6             13

  December 2004  236              0                236         223             -13            7

  January 2005   236              1                237         221             -15            15

  February 2005  236              2                238         223             -13            13
  -------------- ---------------- ---------------- ----------- --------------- -------------- ------------------

\*Inactive Operators defined as those unable to work for 90 days or more
in regularly assigned position/facility due to absence.

\*\*Trainee count not included in total counts for assigned numbers.

Driver recruitment is done by the Metro Human Resources Department.
Recruitment includes a test to assess the applicant's suitability to
work as a Call-A-Ride driver and a personal interview with Call-A-Ride
Managers. Upon completion of testing and interviews, drivers enter a
training program. The attrition rate during training is approximately 20
percent. Metro requires each Call-A-Ride driver to have a chauffeur's
license.

[]{.mark}

Metro data on driver tenure was reviewed in order to assess Metro's
ability to maintain a sufficient number of drivers. As indicated in
Table X.2, as of April 12, 2005, 173 or 75 percent of Call-A-Ride
drivers had been driving for more than one year, with 54 (23 percent)
driving for more than five years. In addition, 10 recently hired drivers
were in training.

**Table X.2 -- Driver Tenure as of April 12, 2005**

  ---------------------------- --------------------- --------------------
  **Tenure**                   **\# of Drivers**     **% of Drivers**

  0-3 Months                   17                    8%

  3-6 Months                   10                    4%

  6-12 Months                  30                    13%

  1-2 Years                    44                    19%

  2-5 Years                    75                    33%

  More than 5 Years            54                    23%

  Total                        230                   100%
  ---------------------------- --------------------- --------------------

The review team also assessed recent driver terminations. As noted in
Table X.3, 58 drivers were separated from Call-A-Ride service between
July 1, 2004 and March 31, 2005. These drivers averaged 820 days (2.2
years) of employment. Approximately two-thirds of the drivers were
terminated or failed to complete probation. Approximately one-third
resigned. Drivers who transferred to Metro buses had been driving for
Call-A-Ride for at least four years. Most drivers who left Call-A-Ride
for non-Metro jobs had been working for Call-A-Ride for less than 6
months. According to Metro Managers, some drivers are attracted to
positions as bus operators by higher hourly rates and better benefits.

**Table X.3 -- Driver Separations, July 1, 2004 - March 31, 2005**

  --------------------------------- ------------------ ------------------
  []{.mark}                         **Number**         **%**

  Number of Drivers                 58                 

  Average Years Employed            2.2                

  Terminated                        39                 67.2%

  Resigned                          19                 32.8%
  --------------------------------- ------------------ ------------------

In summary, driver staffing appears to be adequate and not be a limit to
service.

The Metro van fleet appears to be adequate to accommodate current demand
for service. The 120 vehicle fleet appears sufficient to serve
Call-A-Ride's 95 runs plus the Chesterfield service with adequate
provision of spare vehicles.

**Planning, Budgeting, and Funding**

[]{.mark}

A reviewer met with Metro officials to review the process for developing
and adopting the annual budget for Metro's ADA complementary paratransit
services.

[]{.mark}

Metro's fiscal year is July 1 to June 30. The budget process begins in
November with development of initial manpower requirements for each
department. The manpower requirements for Call-A-Ride service are based
upon a service plan which includes the number of planned runs. The
planned runs are developed around four schedules, or operator assignment
"picks" for the year. Each department estimates need for by major
department functions such as Call Center and drivers for Call-A-Ride.
This forms the basis for estimating the expected costs for the
department. This process, initiated in November, results in a
preliminary budget. The budget is reviewed against the previous year's
costs, current year-to-date costs, and projected costs for the next
year, and targeted departmental cost reductions. In January, costs are
reviewed by senior staff against budget targets; reductions that do not
reduce service are made. The revised budgets are reviewed by all
departments in March, further revised, and submitted to the Metro Board
of Directors in April.

[]{.mark}

A review of Monthly Call-A-Ride status reports indicates that operating
capacity has been insufficient to serve expressed demand (trips served
plus capacity denials) in recent years. As indicated in Table IX.4, it
appears that Metro has made positive strides in addressing this capacity
shortfall by increasing the percentage of demand served from 93.8
percent in FY2003 to a projected 99.1 percent in FY2005.

[]{.mark}

**Table X.4 -- Call-A-Ride Passenger Demand**

  ------------------ ------------ ------------- ------------- -------------
  **Year**           **FY2002**   **FY2003**    **FY2004**    **FY2005**

  **Passenger        523,418      575,344       682,097       779,740
  Trips**                                                     

  **Capacity         25,723       37,762        11,914        7,196
  Denials**                                                   

  **Expressed        549,141      613,106       694,011       786,936
  Demand**                                                    

  **% of Demand      **95.3%**    **93.8%**     **98.3%**     **99.1%**
  Served**                                                    
  ------------------ ------------ ------------- ------------- -------------

[]{.mark}

Call-A-Ride budget increases appear to have provided for expansion of
service capacity, as can be seen in Table IX.5. Both demand for service
and operating budgets have increased significantly in recent years.

[]{.mark}

**Table X.5 -- Ridership and Budget Trends**

  ----------------- -------------- -------------- -------------- --------------
  **Year**          **FY2002**     **FY2003**     **FY2004**     **FY2005**

  **Passenger       523,418        575,344        682,097        779,740\*
  Trips**                                                        

  \% Change         []{.mark}      9.9%           18.6%          14.3%

  **Expressed       549,141        613,106        694,011        786,936\*
  Demand**                                                       

  \% Change                        11.6%          13.2%          13.4%

  **Operating       \$13,387,640   \$15,037,803   \$16,529,334   \$17,738,810
  Budget**                                                       

  \% Change         []{.mark}      12.3%          9.9%           7.3%
  ----------------- -------------- -------------- -------------- --------------

\* Projected based on actual boardings for the period July 1 through
December 31, 2004

[]{.mark}

According to Metro managers, influences on demand, capacity, and budget
have included:

-   An independent operator went bankrupt in 2004, leading to an
    increase in demand for Call-A-Ride service. Much of the demand
    increase was for group travel during off-peak service hours,
    resulting in increased productivity.

-   Managers anticipate an offset of demand increases in 2005 from a
    reduction in service hours to fixed route service hours.

-   A fleet increase from 63 passenger vehicles in 2000 to a current
    fleet of 120 passenger vehicles has helped increase service
    capacity.

**Findings**

1.  Staffing of the Call-A-Ride call center appears to limit access by
    customers to reserve trips. New reservations software and procedural
    changes to reduce call volume should increase efficiency of the
    reservations process, but additional staffing will likely be
    required to reduce hold times to a level that does not significantly
    impeded access to service.

2.  Equipment and staffing of scheduling, dispatch, and transportation
    service appear to be adequate to provide effective service at
    current levels of demand.

3.  Increased demand for service may require an increase in the number
    of runs and associated increases in the number of drivers and
    vehicles.

4.  Budget increases in recent years appear to be responsive to the need
    to serve unserved demand for service (trip denials).

**Recommendations**

[]{.mark}

1.  Hold times for incoming calls for reservations at the Call-A-Ride
    call center should be closely monitored and staffing increased as
    needed to reduce hold times to a level that does not impede access
    to service.

2.  The number of denials should be closely monitored and operating
    capacity should be increased as needed to eliminate denials without
    significant adverse impact on other service performance measures.

3.  Budget increases should continue as needed to finance the service
    capacity to eliminate denials without significant adverse impact on
    other service performance measures.

**Attachment A**

**St. Louis Metro Response**

![](media/image1.png){width="6.4847222222222225in"
height="8.429166666666667in"}

![](media/image2.png){width="6.534027777777778in" height="8.5in"}

**Summary of Findings from FTA Draft Report**

[]{.mark}

**A. ADA Complementary Service Criteria**

1.  The Metro ADA complementary paratransit service area includes all
    locations in St. Louis City and St. Louis County, within 3/4-miles
    of all Metro fixed route services.

2.  Metro does not provide Call-A-Ride Plus service-to-service areas
    within 3/4-miles of Metro Link Stations that it serves in Illinois.

3.  Metro and ATS effectively coordinate interregional service for ADA
    complementary paratransit eligible customers. It is a seamless
    process for riders, including reservation and fare payment.

4.  Metro Call-A-Ride Plus service schedule does not include service for
    all days and hours of scheduled service for several Metro Bus
    routes.

5.  For trips of two or three zones, it appears that the Call-A-Ride
    Plus fare of \$3.50 can be more than two times the fare of a
    comparable fixed route trip on Metro by a typical user, if that user
    is traveling without a transfer on Metro Link one of the many Metro
    Bus routes that serve multiple Call-A-Ride zones.

6.  The transfer charge for Call-A-Ride Plus trips that include
    transfers to fixed route service can further increase the difference
    between Call-A-Ride Plus fares and fixed route fares for trips with
    the same trip origin and destination.

**B. ADA Complementary Paratransit Eligibility**

1.  Metro's policy is to make determinations of ADA complementary
    paratransit eligibility based on whether the applicant's mobility
    aid meets the definition of a "common wheelchair." This
    determination fails to make the distinction between the eligibility
    of the applicant and the applicant's mobility aid. The determination
    of eligibility should be made solely based on the applicant's
    ability to use fixed route service as addressed in 49 CFR §37.123,
    and not on the mobility aid that the applicant uses. The decision to
    limit service to mobility aids that meet the definition of a common
    wheelchair should be addressed by Metro as a separate issue from
    eligibility.

2.  Based on review of a sample of 34 applications for Metro's
    Call-A-Ride service submitted during 2004 and 2005, the
    determinations made by Metro seem reasonable. Other than the policy
    regarding common wheelchairs, Metro's eligibility determination
    process does not appear to deny or restrict ADA complementary
    paratransit service to eligible individuals.

3.  Approximately 25 percent of applicants receive conditional
    eligibility. At the time of the on-site review Metro provided
    service to individuals who have conditional eligibility as if they
    had unconditional eligibility. As a result, any rider with
    conditional eligibility could be scheduled for any trip requested.

4.  Metro has defined its eligibility process such that the application
    is complete after the in-person assessment. Based on this standard,
    Metro made determinations within 21 days for only 4 of the 12
    applications in the review team's sample of applications filed
    between March and December of 2004. Four applications took at least
    90 days and two applications took up to 170 days. In a February 2005
    sample, Metro greatly improved the timeliness of its application
    processing, making determinations for 20 of 22 completed
    applications within 21 days.

5.  The time from submittal of a written application and an in-person
    interview is significant and could be an impediment to ADA
    complementary paratransit eligible individuals obtaining access to
    service. The average number of days in the 2004 sample was 63 days
    between receipt of written application and the in-person assessment.
    This decreased to 33 days in the 2005 sample. Metro did not have any
    documentation to identify the reason for the extended period between
    application submission and in-person assessment.

6.  The DOT ADA regulations (49 CFR §37.125 (c)) requires that
    applicants be treated as eligible for service if a determination of
    eligibility has not been made within 21 days following the
    submission of a complete application. The application and other
    public information provided by Metro do not inform applicants of
    their right to service if they have not received a determination on
    their completed application within 21 days.

7.  Metro has a process in place for appealing eligibility
    determinations. However, as of the time of the review team's site
    visit, there had not been a formal appeal for more than three years.
    As a result it was not possible to review determinations made on
    requests for appeal.

8.  In its letter to applicants who are determined ineligible for ADA
    complementary paratransit service, Metro does not provide specific
    reasons for why the applicant is determined ineligible for service.
    Absence of such information could impede applicant's decision on
    whether or not to appeal the determination.

9.  In its letter to applicants who receive temporary eligibility for
    ADA complementary paratransit service and in its letter to
    applicants who are denied eligibility for ADA complementary
    paratransit service because the mobility aid that they use, Metro
    does not refer to or include information on its appeals process. As
    a result, applicants who are determined ineligible may not be aware
    of their right to appeal the decision.

10. Metro's appeals process description states, "Appeals must be made in
    writing" and "The written appeal should state the reason or reasons
    you believe the determination to be incorrect." To require the
    appeal be made in writing and state the reason for the appeal could
    deprive the appellant of an opportunity to be heard and present
    information and arguments that the appellant would otherwise have if
    the appeal were made orally and without advance written reasons.

11. Metro's Director of ADA services handles request for appeals on an
    informal basis. The Director of ADA services has the formal
    responsibility for approving all initial eligibility determinations.
    This practice is at variance with the requirements of the DOT ADA
    regulations that decisions on appeals be made by a person not
    involved in the initial decision to deny eligibility, or "separation
    of functions."

12. Metro has a policy to suspend Call-A-Ride service to riders who
    exceed a threshold of no-shows or late cancellations. Under the
    current policy, a person traveling five days a week (10 one-way
    trips a week) could be suspended for having no-shows for only 3.5
    percent of his/her scheduled trips. This rate of no-shows does not
    appear to constitute a "pattern or practice" as intended by the
    regulations.

13. Metro considers same day cancellations in its procedure for service
    suspensions. The DOT ADA regulations allow transit systems to
    suspend service for a reasonable period for riders who abuse the
    system by regularly "no-showing" for scheduled trips. While transit
    agencies have in recent years also considered "late cancellations"
    to be an abuse of the system and have considered this in their
    suspension policies, the effects of a late cancellation should be
    operationally equivalent to a no-show in terms of the negative
    impact on the service. Cancellations made several hours in advance
    of the scheduled pick-up time would still seem to allow the system's
    dispatchers to use the open vehicle time to respond to same-day
    operating issues. Accordingly, same day customer cancellations made
    several hours before the scheduled time should not be considered as
    a basis for suspending customer service.

14. Metro's ID card for ADA complementary paratransit service includes
    condition codes for individuals who are conditionally eligible.
    However, the card does not provide an explanation for these codes.

[]{.mark}

**C. Telephone Access**

1.  Metro's policy goal of average times in queue of 4.18 minutes likely
    results in many calls in queue for periods of time well in excess of
    4.18 minutes and would appear to significantly limit ADA
    complementary paratransit customers' ability to use Call-A-Ride
    service.

2.  During the week of February 7 to 11, 2005, Metro received a total of
    4,053 calls to the reservation center. Daily average hold times for
    the four phone lines ranged from 0.65 minutes to 2.45 minutes. Of
    the 4,053 calls, 737 were abandoned by the caller for an abandonment
    rate of 18 percent. This high abandonment rate is an indicator of
    difficulty in getting through on the phone lines to make
    reservations. Call Center staffing and equipment limits may be
    contributing to long hold times and high abandonment rates.

3.  The review team observed 76 calls during the two-day period of April
    12 and 13, 2005. These calls averaged over seven minutes to
    complete. The reservations system being used at the time of the
    review appeared to be antiquated and slow, contributing to the long
    call times. Metro was in the process of upgrading its computer
    reservations system with a scheduled implementation during the
    summer of 2005.

4.  Metro's advertised Call-A-Ride reservations hours are 7:30 a.m. to
    4:30 p.m. During the review, the Reservations Center closed at 4:21
    p.m., based on a wall clock that was nine minutes fast.

5.  Any calls left in the queue at the end of the day were abandoned. As
    a result, some customers calling before 4:30 p.m. are not being
    served.

6.  Metro accepts only four one-way trip requests per call during peak
    call times. This policy can increase the length of telephone queues
    by requiring reservationists to handle multiple calls rather than
    one to serve one customer and placing multiple calls rather than one
    in the phone queue.

7.  Metro tracks performance by measuring the callers' average time in
    the telephone queue. This performance measure does not capture the
    number of callers that have significantly long hold times, which
    provides a better index of customer service and telephone access.

8.  It is Metro's practice for reservation clerks to rotate into the
    dispatch center and handle customer assistance calls. This appears
    to be very beneficial because it allows the reservation clerk to
    understand additional aspects of the reservation process and gives
    the clerk a greater sensitivity to the customer's needs.

**D. Trip Reservations and Scheduling**

1.  Metro's web site and the Metro Call-A-Ride brochure dated June 28,
    2004, advise Call-A-Ride customers to "phone at least 24 hours in
    advance to schedule your trips." The DOT ADA regulations (49 CFR
    §37.131(b)) requires the transit entity (Metro) to schedule and
    provide trips in response to a request for service made the previous
    day.

2.  At the time of the review team's on-site visit, Metro regularly
    denied trip requests for ADA complementary paratransit service due
    to capacity constraints. The proportion of denials was generally two
    percent of total demand on weekdays. Of these denials approximately
    20 percent were for next day service requests and 80 percent were
    for service requests two or more days in advance of the service day.
    Metro managers said that many of the riders who have their trip
    requests denied call back on a subsequent day and get a trip.
    However, Metro has not tried to document this number, and it is not
    without significant effort on the part of the rider.

3.  Many trips denied early in the scheduling period can be scheduled
    later in the scheduling period as a result of trip cancellations
    and/or route modifications made by proofers. Denial of such trip
    requests precludes them being served unless the customer calls again
    at a later time to request the trip.

4.  The Metro scheduling software does not include a function to
    schedule trips to meet appointment times. Reservationists record
    appointment times requested by callers in the software system and
    can attempt to place the trip on the run they feel is most
    appropriate. However, Metro has not set up PASS to schedule by
    appointment time.

**E.1 Service Performance**

1.  Metro's policy standard for service denials does not appear to
    consider all denials. Metro's policy standard is zero denials for
    requests made the previous day. Metro accepts service requests seven
    days in advance of the service day, and "Metro Call-A-Ride Easy
    Trips" brochure encourages customers to call early to make trip
    reservations. Denying a trip more than one day in advance of the
    service day, thereby requiring multiple calls to schedule a trip,
    appears to limit access to the service and constitute a capacity
    constraint.

2.  The review team's analysis of a one-day sample indicates that 64
    (2.5 percent) of trip requests for service on February 9, 2005 were
    denied. During the period June through December 2004 Metro reported
    next day denials of 0.6 percent. Metro indicated that some customers
    who are denied service more than one day in advance of the service
    day call back and eventually reserve their requested trip.

3.  Metro appears to have no policy for missed trips.

4.  Based upon a review of Call-A-Ride data reports for February 9,
    2005, it appears that Metro does not record missed trips as a
    category for performance monitoring purposes. Missed trips appear to
    be grouped with customer no-shows and late cancellations.

5.  Analysis of data for the sample day indicated that for 14 trips (0.7
    percent of the 2,019 trips dispatched on the service day) that were
    not completed, the vehicle arrived at the pickup address more than
    15 minutes after the scheduled time. For 57 trips (2.8 percent) that
    were not completed, there was no vehicle arrival time. All of these
    trips could be missed trips---resulting in as many as 71 (3.5
    percent) missed trips. Some of these trips could also be late
    cancellations.

6.  Metro has two standards for on-time performance. For the customer,
    the standard for on-time is a vehicle arrival between 15 minutes
    before and 15 minutes after (-15/+15) the scheduled time. For
    performance measurement and reporting the standard is 15 minutes
    before and 20 minutes after (-15/+20) the scheduled time. Use of one
    standard for the customer and a more generous standard for
    performance measurement overstates the level of service being
    provided to the customer.

7.  Based on an on-time window of 15 minutes before to 15 minutes after
    (-15/+15), 94.2 percent of trips were picked up either early or
    on-time, and 5.8 percent of trips were picked up late on the sample
    day. Of the late trips, 20 (1 percent of completed trips) were more
    than 15 minutes late and, of those, 4 (0.2 percent) were more than
    30 minutes late. Based on this sample there do not appear to be a
    significant number of substantially late pickups.

8.  On the sample day, there were 306 (16.1 percent of completed trips)
    picked up early. Of that number, 35 (1.8 percent of completed trips)
    were picked up more than 16 minutes early; of those trips, 11 (0.6
    percent of completed trips) were picked up more than 30 minutes
    early. Very early pickups could indicate that customers are being
    pressured to accept early departures.

9.  Of 833 trips with scheduled drop-off or appointment times, 710 (85
    percent) were early or on-time and 123 (15 percent) were late. Of
    these late drop-offs, 34 (4.0 percent) were more than 15 minutes
    late; of this number, 18 (2.1 percent) were more than 30 minutes
    late. These late drop-offs, potentially resulting in late arrivals
    for work, school, or medical appointments, could be considered a
    constraint to use of the service by paratransit eligible
    individuals.

10. From a sample of 29 long trips on February 9, 2005, 21 (1.1 percent
    of the completed trips) exceeded Metro's standard of 90 minutes for
    intra-zonal trips. 15 (0.8 percent) of the 29 long trips sampled
    were more than 30 minutes longer than a comparable fixed route trip
    and 7 (0.4 percent) were more than 46 minutes longer. Five of the
    trips that were more than 30 minutes longer than a comparable fixed
    route trip were to or from the same location. This appears to be a
    pattern of significantly long trips.

**E.2 Transportation Operations**

1.  Dispatchers appear to monitor and control service so as to avoid
    missed trips and maintain a high level of on-time performance.

2.  Dispatchers appear to have effective procedures in place to minimize
    customer no-shows. Dispatchers attempt to contact passengers if
    drivers are unable to find them at the pickup location.

3.  Metro has a "no strand" policy for riders with return trips. If a
    rider calls after the vehicle has left, Metro will not record this
    as a passenger no-show, but will re-classify the trip as a will-call
    for later pickup.

4.  Metro appears to have the capacity to accommodate some trips that
    could not be scheduled before the service day by assigning those
    trips to "Route 0," as well as using capacity made available from
    cancellations and available on the "clean up" runs. This capacity
    could be used to reduce or eliminate trip denials.

5.  Call-A-Ride appears to have sufficient dispatch coverage to
    effectively monitor and control service.

6.  Drivers appear to be well trained and have the resources including
    vehicles and dispatch support to perform their job.

7.  Drivers cited illogical routing and tight schedules as a concern.

[]{.mark}

**F. Resources**

1.  Staffing of the Call-A-Ride call center appears to limit access by
    customers to reserve trips. New reservations software and procedural
    changes to reduce call volume should increase efficiency of the
    reservations process, but additional staffing will likely be
    required to reduce hold times to a level that does not significantly
    impeded access to service.

2.  Equipment and staffing of scheduling, dispatch, and transportation
    service appear to be adequate to provide effective service at
    current levels of demand.

3.  Increased demand for service may require an increase in the number
    of runs and associated increases in the number of drivers and
    vehicles.

4.  Budget increases in recent years appear to be responsive to the need
    to serve unserved demand for service (trip denials).

**St. Louis Metro**

**ADA Complementary Paratransit Compliance Review**

**Quarterly Report -- Draft Findings**

  ---------------- ------------------------------------- ------------------
  **Finding \#**   **Corrective Action Identified**      **Planned
                                                         Completion Date**

  **A.                                                   
  Complementary                                          
  Paratransit                                            
  Service                                                
  Criteria**                                             

  **1**            No Response Required                  

                                                         

  **2**            Amend Contract with St. Clair County  12/31/06
                   Transit                               

                                                         

  **3**            No Response Required                  

                                                         

  **4**            Metro will analyze current fixed      7/1/07
                   route service and adjust paratransit  
                   as necessary                          

                                                         

  **5**            Metro will evaluate its fare policy   7/1/07
                   for ADA multi-zone trips              

                                                         

  **6**            Metro will include this issue in its  7/1/07
                   analysis of the paratransit fare      

  **B. ADA                                               
  Complementary                                          
  Paratransit                                            
  Eligibility**                                          

                                                         

  **1**            Reconsideration Requested             

                                                         

  **2**            No Response Required                  

                                                         

  **3**            No Response Required                  

                                                         

  **4**            No Response Required                  

                                                         

  **5**            Redesign Database used to allow       12/31/06
                   better documentation                  

                                                         

  **6**            Transit Access Program brochure will  7/1/07
                   be revised                            

                                                         

  **7**            No Response Required                  

                                                         

  **8**            General Ineligibility letter will be  12/31/06
                   revised                               

                                                         

  **9**            Revise Temporary Eligibility Letter   12/31/06
                   Only                                  

                                                         

  **10**           Appeals process and associated        12/31/06
                   written materials will be revised     

                                                         

  **11**           Appeals process will be revised       12/31/06

                                                         

  **12**           Reconsideration Requested             

                                                         

  **13**           Reconsideration Requested             

                                                         

  **14**           Reconsideration Requested             None

  **C. Telephone                                         
  Access**                                               

                                                         

  **1**            No Action Planned                     None

                                                         

  **2**            No Action Planned                     None

                                                         

  **3**            No Action Planned                     None

                                                         

  **4**            No Action Planned                     None

                                                         

  **5**            New ACD System is being studied       Unknown

                                                         

  **6**            No Action Planned                     None

                                                         

  **7**            New ACD System is being studied       Unknown

  **D. Trip                                              
  Reservations and                                       
  Scheduling**                                           

                                                         

  **1**            No Action Planned                     None

                                                         

  **2**            New software for paratransit          7/1/07
                   operations & analysis of true ADA     
                   trip denials                          

                                                         

  **3**            New software for paratransit          7/1/07
                   operations                            

                                                         

  **4**            No Action Planned                     None

  **E.1 Service                                          
  Performance**                                          

                                                         

  **1**            No Action Planned                     None

                                                         

  **2**            No Action Planned                     None

                                                         

  **3**            No Action Planned                     None

                                                         

  **4**            No Action Planned                     None

                                                         

  **5**            No Action Planned                     None

                                                         

  **6**            No Action Planned                     None

                                                         

  **7**            No Response Required                  

                                                         

  **8**            No Action Planned                     None

                                                         

  **9**            No Action Planned                     None

                                                         

  **10**           No Action Planned                     None

  **E2                                                   
  Transportation                                         
  Operations**                                           

                                                         

  **1**            No Response Required                  

                                                         

  **2**            No Response Required                  

                                                         

  **3**            No Action Planned                     None

                                                         

  **4**            No Action Planned                     None

                                                         

  **5**            No Response Required                  

                                                         

  **6**            No Response Required                  

                                                         

  **7**            No Action Planned                     None

  **F. Resources**                                       

                                                         

  **1**            No Action Planned                     None

                                                         

  **2**            No Response Required                  

                                                         

  **3**            Continued budgeting to meet           Ongoing
                   anticipated demand                    

                                                         

  **4**            No Response Required                  
  ---------------- ------------------------------------- ------------------

**Metro Draft Finding Comments and Requests for Reconsideration**

**A. ADA Complementary Service Criteria**

***2. Metro does not provide Call-A-Ride Plus service to service areas
within 3/4-miles of MetroLink Stations that it serves in Illinois.***

Metro has a contract with St. Clair County Transit County to provide
fixed route services in St. Clair County, Illinois. Metro will modify
the contract to specifically mention compliance with complementary
paratransit requirements and require quarterly reports from Alternative
Transportation System who provides ADA paratransit services in St. Clair
County.

***4. Metro Call-A-Ride Plus service schedule does not include service
for all days and hours of scheduled service for several Metro Bus
routes.***

Metro acknowledges that there were a very small number of bus routes in
selected areas that operated slightly earlier or later than the
Call-A-Ride service. When the new software system for paratransit
operations is implemented, we will be able to identify and correct any
discrepancies. It should be noted that Metro's fixed route system
changed dramatically on August 28, 2006 when the Shrewsbury I-44 branch
of the MetroLink opened for revenue service. Nearly every route in
Missouri has changed since the ADA paratransit review was conducted in
April 2005. There is also a very strong possibility that fixed route
service may be reduced significantly in FY 2007 to achieve a balanced
budget.

Metro will comply with the ADA requirement to provide complementary
paratransit service within ¾ mile of regular fixed route service during
the hours of operation of the applicable fixed route service. Metro will
analyze recent and potential fixed route changes that could occur
effective July 1, 2007. Any changes needed to comply with the service
area requirements would be implemented in July 2007.

***5. For Trips of two or three zones, it appears that the Call-A-Ride
Plus fare of \$3.50 can be more than two times the fare of a comparable
fixed route trip on Metro by a typical user, if the user is traveling
without a transfer on MetroLink or one of the many MetroBus that serve
multiple Call-A-Ride zones.***

Metro does not have the ability to analyze and apply ADA paratransit
fares on a trip-by-trip basis and the zonal system used has been
generally acceptable to the community. Metro understands that fares
charged for any ADA paratransit trip are not to exceed twice the
applicable full fixed route fare and will analyze alternate methods for
calculating ADA paratransit fares. Fare changes require community input
so it is unlikely that any fare changes will occur before July 2007.

***6. The transfer charge for Call-A-Ride for Call-A-Ride Plus trips
that include transfer to fixed rote service can further increase the
difference between Call-A-Ride Plus fares and fixed route fares for
trips with the same origin and destination.***

This is analogous to finding 5 above and will be considered as ADA
paratransit fares are analyzed. It should be noted that currently very
few customers transfer to bus and rail as conditional eligibility is not
currently enforced. In operational practice, customers who have spent a
considerable amount of time on a van traveling across zones are taken to
their final destination and not required to transfer to a fixed route
vehicle. Fare changes require community input so it is unlikely that any
fare changes will occur before July 2007.

**B. ADA Complementary Paratransit Eligibility**

***1. Metro's policy to make determinations of ADA complementary
paratransit eligibility based on whether the applicant's mobility aid
meets the definition of a "common wheelchair". This determination fails
to make the distinction between the eligibility of the applicant and the
applicant's mobility aid. The determination of eligibility should be
based solely on the applicant's ability to use fixed route service as
addressed in 49 CFR §37.123, and not on the mobility aid that the
applicant uses. The decision to limit service to mobility aids that meet
the definition of a common wheelchair should be addressed by Metro as a
separate issue from eligibility.***

Metro disagrees strongly and requests reconsideration of this finding.
ADA regulations **49 CFR §37.165(b)** requires transit providers to
transport all "common wheelchairs". Mobility devices that exceed the
dimensions or weight specified do not have to be transported. **49 CFR
§37.123 (2) (ii)** states "An individual using a common wheelchair is
eligible..." The ADA Paratransit Eligibility Manual (page 6) defines a
"common wheelchair" and states "An individual would [not]{.underline} be
eligible for paratransit services under category 1 if they could not use
an accessible bus because their mobility aid was too large or too heavy
for the lift". On page 58, it states, "It may also be helpful to request
detailed information about the type, size, and weight of wheelchairs to
determine if the applicant uses a "common wheelchair"". Clearly, the use
of a mobility aid and whether it is a "common wheelchair" must be
considered in conferring ADA paratransit eligibility, which is to be
based on the applicant's functional abilities as they relate to transit
and not simply the presence of a disability. The mobility aid used is an
essential element of an applicant's functional ability to use any
transit service.

It is important to note that "ADA Paratransit Certification" in one
jurisdiction requires that ADA paratransit services be provided to the
individual when he or she travels to other jurisdictions, nationwide. If
the standards regarding a common wheelchair are not considered by the
certifying agency, nationwide usability of ADA paratransit services
cannot be ensured. The individual's ADA paratransit eligibility cannot
be properly determined without consideration of the mobility device
used.

Metro will continue its current practice until otherwise directed. The
requirement for a common wheelchair is currently included in the
Call-A-Ride Plus section of Metro's "Public Transit Options for
Customers with Disabilities" brochure and will be clarified in the next
printing of the "Transit Access Program" brochure when current brochures
are depleted or by June 30, 2007.

***5. The time from submittal of a written application and an in-person
interview is significant and could be an impediment to ADA complementary
paratransit eligible individuals obtaining access to service. The
average number of days in the 2004 sample was 63 days between receipt of
written application and the in person assessment. This decreased to 33
days in the 2005 sample. Metro did not have any documentation to
identify the reason for the extended period of between application
submission and in-person assessment.***

This issue has largely been resolved. Metro staff now conducts ADA
paratransit assessments instead of the contracted staff from Washington
University. Most applicants are offered an appointment date that is
approximately 2 weeks after the application submission date and
eligibility decisions are generally rendered in 10 days or less
following the completion of the functional assessment. Metro does
recognize the need for improved documentation. Software for paratransit
operations that also has features for ADA paratransit certification has
been delayed. A new database is currently being developed for use until
the paratransit software is fully operational. It is anticipated that
this database will be operational by December 31, 2006.

***6. The Dot ADA regulations (49 CFR §37.125 9c00 requires that
applicants be treated as eligible for service if a determination of
eligibility has not been made within 21 days following the submission of
a complete application. The application and other public information do
not inform applicants of their right to service if they have not
received a determination on their completed application within 21
days.***

Metro concurs with this finding and as a matter of practice has granted
"presumptive eligibility" to applicants whose eligibility decisions took
more than 21 days. Applications and other public information will be
revised when supplies are depleted or by June 30, 2007 to ensure that
applicants are aware of their rights.

***8. In its letter to applicants who are determined ineligible for ADA
complementary paratransit service, Metro does not provide specific
reasons for why the applicant is determined ineligible for service.
Absence of such information could impede applicant's decision on whether
or not to appeal the determination.***

Metro will revise the general letter of ineligibility with the
implementation of the new ADA Services database that is currently in
development. This should occur no later than December 31, 2006.

***9. In its letter to applicants who receive temporary eligibility for
ADA complementary paratransit service and in its letter to applicants
who are denied eligibility for ADA complementary paratransit service
because the mobility Aid they use, Metro does not refer to or include
information on its appeals process. As a result applicants who are
determined ineligible may not be aware of their right to appeal the
decision.***

Metro will revise its letter to applicants who receive temporary
eligibility no later than December 31, 2006. However, the policy to
transport "common wheelchairs" is not subject to the appeals process.
Metro is not legally obligated to transport such devices and do not
believe that our current paratransit van design can consistently and
reliably handle oversized mobility devices. In daily operations, we have
experienced repeated lift failures on our bus and paratransit vehicles
while attempting to transport customers whose mobility aid exceed the
common wheelchair standards. Metro is in the early stages of exploring
other vehicle designs for bus and paratransit vehicles hat may allow us
to transport larger mobility devices in the future.

***10. Metro's appeals process description states, " Appeals process
must be made in writing" and the "The written appeal should state the
reasons you believe the determination to be incorrect." To require the
appeal be made in writing and state the reason the reason for the appeal
could deprive the appellant of an opportunity to be heard and present
information and arguments that the appellant would otherwise have if the
appeal were made orally and without advance written reason.***

Reconsideration of this finding is requested. Metro's appeals process
description as stated above is consistent with ADA regulations and
guidance provided by the FTA. According to the ADA Paratransit Manual
(page 94) " Transit providers can require that appeals be requested in
writing." Additionally, the policy does not "require" that reasons for
appeal be provided. As noted above, the wording is "should" not "must or
shall". However, Metro will add wording to the letter to say that
accommodations will be made for those who are unable to independently
communicate in written form. This will be completed no later than
December 31, 2006.

***11. Metro's Director of ADA Services handles request for appeal on an
informal basis. The Director of ADA Services has the formal
responsibility for approving all initial eligibility determinations.
This practice is at variance with the requirements of DOT ADA
regulations that decisions on appeals be made by a person not involved
in the initial decision to deny eligibility or "separation of
functions."***

Metro concurs with this finding. At the time of the review, the Director
of ADA Services was the technical representative / contract manager for
the ADA paratransit eligibility determination services that were
conducted by Washington University. In June 2006, Metro hired staff to
conduct ADA paratransit eligibility assessments. The Director of ADA
Services no longer involved in initial decision. She will now serve as
the initial reviewer for any appeals. A detailed description of the
revised appeals process will be provided to the FTA with Metro's first
quarterly report on the final findings of the ADA Paratransit Compliance
Review.

***12. Metro has a policy to suspend Call-A-Ride service to riders who
exceed a threshold of no shows or late cancellations. Under the current
policy, a person traveling five days a week (10 one-way trips a week)
could be suspended for having no-shows for only 3.5 percent of his/her
scheduled trips. This rate of no-shows does not appear to constitute a
"pattern or practice" as intended by the regulations.***

This is a statement of what "could" happen as opposed to what "actually"
happens in daily operational practice. .

In FY06 Call-A-Ride provided 668,000 trips to 12,680 unduplicated
customers and 4,090 of these customers are ADA paratransit eligible. We
also had 143,000 cancellations and no-shows. That represents 17.2% of
all requested trips that were scheduled and then cancelled or no-showed.
Over 65% of all cancellations occur the night before or on the day of
service so no other customers can be scheduled into those slots. It is a
waste of scarce community resources and our Cancellation and No-Show
Policy helps to keep this problem under control.

However, the policy is very lenient and it is applied in a very lenient
manner. It takes *[24 same-day cancellations in a 60-day period to get
suspended]{.underline}*. If you rode every single day for 60 days you
would have to cancel 40% of your rides on the day of service before you
were suspended. That is indeed a pattern. If you rode only on weekdays
(as in the Review Team's explanation) there are 44 average weekdays in a
60-day period. If you cancelled 12 days worth of trips on the day of
service, that would be a 27% same-day cancel rate. Again, that is a
considerable negative pattern.

A No-Show is when a customer does not even bother to call and cancel. We
may spend upwards of 30 minutes looking for a customer before we leave
-- especially if we took the customer on the go trip. It is a huge delay
for other customers on the van and we get many complaints from other
customers about no-shows on the part of these customers.

It takes 3 No-Shows in a 60-day period to get suspended. There really
are few excuses for not calling. If a customer does have a valid reason
why they could not call (being in the hospital, out of town and so
forth), the no-show is excused.

Here is what the actual operational data really looks like.

+---------------+---------+------+---+-----+--------+-----+--------+---+
| **FY2006      |         |      |   |     |        |     |        |   |
| No-Shows and  |         |      |   |     |        |     |        |   |
| Ca            |         |      |   |     |        |     |        |   |
| ncellations - |         |      |   |     |        |     |        |   |
| Disposition** |         |      |   |     |        |     |        |   |
+---------------+---------+------+---+-----+--------+-----+--------+---+
| **[NS_TYPE]{  | *       | **[% |   | **  | **[%   | **  | **[%   |   |
| .underline}** | *[Total | of   |   | [Tr | char   | [Tr | forgi  |   |
|               | Trips]  | Tota |   | ips | ged]{. | ips | ven]{. |   |
|               | {.under | l]{. |   | w   | underl | w   | underl |   |
|               | line}** | unde |   | ith | ine}** | ith | ine}** |   |
|               |         | rlin |   | Poi |        | ]{. |        |   |
|               |         | e}** |   | nts |        | und |        |   |
|               |         |      |   | C   |        | erl |        |   |
|               |         |      |   | har |        | ine |        |   |
|               |         |      |   | ged |        | }** |        |   |
|               |         |      |   | ]{. |        |     |        |   |
|               |         |      |   | und |        | **  |        |   |
|               |         |      |   | erl |        | [NO |        |   |
|               |         |      |   | ine |        | Poi |        |   |
|               |         |      |   | }** |        | nts |        |   |
|               |         |      |   |     |        | ]{. |        |   |
|               |         |      |   |     |        | und |        |   |
|               |         |      |   |     |        | erl |        |   |
|               |         |      |   |     |        | ine |        |   |
|               |         |      |   |     |        | }** |        |   |
+---------------+---------+------+---+-----+--------+-----+--------+---+
| CNS - Client  | 10,094  | 17%  |   | 8,  | 84%    | 1,  | 16%    |   |
| NoShow        |         |      |   | 491 |        | 603 |        |   |
+---------------+---------+------+---+-----+--------+-----+--------+---+
| LAT - Same    | 31,737  | 52%  |   | 28, | 89%    | 3,  | 11%    |   |
| Day Cancel    |         |      |   | 334 |        | 403 |        |   |
+---------------+---------+------+---+-----+--------+-----+--------+---+
| NNS - No      | 18,378  | **3  |   |     |        |     |        |   |
| Fault NoShow  |         | 0%** |   |     |        |     |        |   |
+---------------+---------+------+---+-----+--------+-----+--------+---+
| SNS - System  | 783     | 1%   |   |     |        |     |        |   |
| NoShow        |         |      |   |     |        |     |        |   |
+---------------+---------+------+---+-----+--------+-----+--------+---+
|               |         |      |   |     |        |     |        |   |
+---------------+---------+------+---+-----+--------+-----+--------+---+
| ** **         | **6     | **10 | * | *   | ** **  | **5 | ** **  |   |
|               | 0,992** | 0%** | * | *36 |        | ,00 |        |   |
|               |         |      |   | ,82 |        | 6** |        |   |
|               |         |      | * | 5** |        |     |        |   |
|               |         |      | * |     |        |     |        |   |
+---------------+---------+------+---+-----+--------+-----+--------+---+

NoFault no-shows have already been forgiven by the dispatcher or CSR
that handled the disposition so the customer would not be charged any
points. As shown, almost two thirds of the no-shows are forgiven at the
time of the no-show by the dispatcher on duty by marking it a no-fault
no-show. Forgiven no-shows are marked as such when a customer calls in
to discuss their letter with the CSR -- it means the no-show was
reversed or forgiven with no points.

***As shown, 57% of all Late Cancels and No-Shows were "forgiven".***
The staff is very understanding and applies the policy in a very lenient
manner.

As for suspensions, there were 520 client suspensions in FY2006
generated from these 60,992 late cancels and no-shows. Those 520 client
suspensions were imposed on 411 unduplicated customers and 167 of these
customers are ADA paratransit eligible. Most customers never get caught
up in the suspension policy. Those that do get suspended have
established a clear pattern of late cancellations and no shows.

As shown, the policy is absolutely necessary. Even though a
cancellation/no-show rate of 17.2% is poor, it would be much worse
without the policy. The policy is applied in an extremely lenient
fashion with only 3% of all customers have actually been suspended from
the service.

***13. Metro considers same day cancellations in its procedure for
service suspensions. The DOT ADA regulations allow transit systems to
suspend service for a reasonable period for riders who abuse the system
by regularly "no-showing" for scheduled trips. While transit agencies
have in recent years also considered "late cancellations" to be an abuse
of the system and have considered this in their suspension policies, the
effects of a late cancellation should be operationally equivalent to a
no-show in terms of the negative impact on the service. Cancellations
made several hours in advance of the scheduled pick-up time would still
seem to allow the system's dispatchers to use the open vehicle time to
respond to same-day operating issues. Accordingly, same day customer
cancellations made several hours before the scheduled time should not be
considered as a basis for suspending customer service.***

We disagree and request reconsideration of this finding. Same day
cancellations are a waste of scarce community resources and are very
costly. Same day cancellations have a very negative impact on service
capacity for other customers. They deprive other users of trips on the
system. Metro is still trying to fund enough service to reach a
zero-denial capacity level.

Additionally, it takes 24 same-day cancels in a 60-day period to get
suspended from the service. We understand that things do come up
occasionally and it may be necessary to cancel on the day of service
from time to time. But if a customer is canceling 40% of all rides on
the day of service, that has a considerable negative impact on the
system for other users.

***14. Metro's ID card for ADA complementary paratransit service
includes condition codes for individuals who are conditionally eligible.
However, the card does not provide an explanation for those codes.***

Reconsideration of this finding is requested. Metro's documentation of
eligibility is in compliance with DOT ADA regulations. 49 CFR §37.125
(e) states that "documentation shall include the name of the eligible
individual, the name of the transit provider, the telephone number of
the entity's paratransit coordinator, an expiration date for
eligibility, and any conditions or limitations on the individual's
eligibility including the use of a personal care attendant." The full
documentation of eligibility is contained in the eligibility
notification letter and the identification cards are supplemental.

The ADA Paratransit Eligibility manual (page 92) states, "Documentation
can be provided in the form of an identification card, as part of a
notification letter, on standard paper, or in other forms as long as the
information required is included. It is also possible to provide
detailed documentation in a letter or on standard paper and to
supplement this with an I.D. card that contains more cryptic
information."

**C. Telephone Access**

1\. Metro's policy goal of average times in queue of 4.18 minutes likely
results in many calls in queue for periods of time well in excess of
4.18 minutes and would appear to significantly limit ADA complementary
paratransit customers' ability to use Call-A-Ride service.

As stated by the Review Team, our minimum standard for average wait
times in the queue was 4.18 minutes. For a public agency, this is a
reasonable response time. Our actual performance during the review,
however, was actually much better than this as noted by the Review Team.
As shown in their table on page 37, average wait times were excellent
and well under two minutes as shown below.

  --------------- ----------- ------------ --------- ------------- --------- --------- ---------
  **Date**        **Day**     **Period**             **Average                         
                                                     Hold Time                         
                                                     (minutes)**                       

  *Reservations                                      *#4230*       *#4240*   *#4250*   *#4260*
  Line \#*                                                                             

  2/7/2005        Monday      7:30 AM      4:30 PM   0.97          0.82      1.32      0.90

  2/8/2005        Tuesday     7:30         4:30      1.63          1.52      2.45      1.75

  2/9/2005        Wednesday   7:30         4:30      0.70          0.67      1.10      0.65

  2/10/2005       Thursday    7:30         4:30      1.65          1.50      2.02      1.37

  2/11/2005       Friday      7:30         4:30      1.13          1.03      1.58      1.10

  2/7-2/11/2005               7:30         4:30      1.22          1.11      1.69      1.15

  4/10/2005       Sunday      7:30         4:30      1.33          1.48      1.28      1.38

                              7:30         8:00 AM   4.50          1.98      0.47      1.53

                              8:00         8:30      0.32          0.00      0.03      0.40

                              8:30         9:00      0.10          0.00      0.12      0.13

                              9:00         9:30      0.05          0.28      0.08      0.15

                              9:30         10:00     0.03          0.43      3.43      0.32

                              10:00        10:30     0.37          0.13      0.00      0.08

                              10:30        11:00     0.18          0.13      0.10      0.08

                              11:00        11:30     0.08          0.08      0.07      0.07

                              11:30        12:00 N   0.33          0.35      0.20      0.30

                              12:00 N      12:30 PM  2.92          0.17      0.33      0.22

                              12:30 PM     1:00      1.43          0.07      0.20      0.32

                              1:00         1:30      0.20          0.07      1.53      3.22

                              1:30         2:00      0.42          0.43      0.03      0.33

                              2:00         2:30      0.13          0.00      0.08      0.05

                              2:30         3:00      1.73          6.73      1.53      0.47

                              3:00         3:30      0.08          0.05      1.27      0.13

                              3:30         4:00      0.10          0.18      0.73      0.12

                              4:00         4:30      0.00          0.00      0.00      0.00
  --------------- ----------- ------------ --------- ------------- --------- --------- ---------

Even on Sundays when there are fewer agents on duty, with a few brief
exceptions during the day, wait times were generally under one minute
during the review

![](media/image3.wmf)The average wait times in the reservation line
queue for the last three fiscal years is shown in this table. Data for
FY07 is through September 06. During FY06 we did have some server and
equipment issues that negatively impacted performance averages for year.
But those have largely been corrected as shown in the FY07 data.

It is important to note that we do not have any complaints about long
wait times in the phone queue. In years past this was a problem -- and
customers did in fact call in complaints about their inability to get
through on the phone lines. But this is no longer an issue that comes up
a public hearings or monthly ADA meetings. We have significantly
improved the phone system staffing and dramatically reduced wait times
for customers. Our customers have experienced the improvement and no
longer complain about this particular aspect of our service.

For reasons cited above, Metro does not plan to take further action with
reference to this finding.

2.  ***During the week of February 7 to 11, 2005, Metro received a total
    of 4,053 calls to the reservation center. Daily average hold times
    for the four phone lines ranged from 0.65 minutes to 2.45 minutes.
    Of the 4,053 calls, 737 were abandoned by the caller for an
    abandonment rate of 18 percent. This high abandonment rate is an
    indicator of difficulty in getting through on the phone lines to
    make reservations. Call Center staffing and equipment limits may be
    contributing to long hold times and high abandonment rates.***

This is only a partial analysis of the data presented. Looking at just
the number of abandoned calls without analyzing the amount of time
waiting in the queue for that abandoned call is only telling part of the
story.

We do not have the data reports for February 05 as we gave those to the
Review Team. But we pulled a quick Abandoned Call Report for Tuesday
September 26, 2006. Here is the summary for just the Reservation Lines.

  ----------- --------- --------- --------- --------- --------- ---------- ----------- ----------- ----------- ---------
  ACD-DN                                                                                                       
  ABANDONED                                                                                                    
  CALLS                                                                                                        
  INTERVAL                                                                                                     
  AVERAGE                                                                                                      

                                                                                                               

  \# of       0-\< 12   12-\<24   24-\<36   36-\<48   48-\<60   60-\<120   120-\<180   180-\<240   240-\<300   300+
  Seconds                                                                                                      

  Res Line                                                                                                     

  4230        104       9         15        10        9         3          20          8           7           6

  4240        20        10        15        0         15        5          15          5           5           10

  4250        84        8         11        6         8         6          13          8           13          6

  4260        88        6         13        14        9         8          16          13          5           1

                                                                                                               

  **Total**   **276**   **33**    **54**    **30**    **41**    **22**     **64**      **34**      **30**      **23**

  **%**       **45%**   **5%**    **9%**    **5%**    **7%**    **4%**     **11%**     **6%**      **5%**      **4%**

                                                                                                               

  **% Less                                                                                                     **71%**
  than 1                                                                                                       
  minute wait                                                                                                  
  time**                                                                                                       
  ----------- --------- --------- --------- --------- --------- ---------- ----------- ----------- ----------- ---------

As shown, there were 607 abandoned calls on Tuesday. Of those, 45% hung
up almost immediately when they got the first announcement. They may be
wrong calls, customers who meant to call the Customer Assistance Line,
or customers who are used to getting straight through and will just call
back later.

Another 26% hung up in less than 60 seconds. These are callers that are
fairly confident they will be able to call back later with an even lower
wait time in the queue than 1 minute.

Callers that experience lots of busy signals or routinely have long wait
times in the queue do not give up and abandon the call after only 60
seconds. They hang on and on and on and are reluctant to abandon the
call for fear they will not get through the phone lines again. We know
-- in years past our phone service was severely constrained and this is
what we experienced at that time. Large numbers of busy signals, long
wait times in the queue before the call was abandoned and a large number
of complaints about the phone service.

But since we have significantly increased our staffing, doubled the
number of phone lines and added a new Customer Assistance Line and kept
it staffed with three people during peak daytime hours, the Reservation
Lines are moving quite well. And customers expect these lines to move
well -- their behavior tells the story. If they call and get put into
the queue, they are much more likely to hang up and call back later when
it is not so busy rather than wait in the queue, even if it is a short
wait now.

The abandoned call rate, combined with the very low "wait times to
abandonment", actually indicate that the phone system is not constrained
and is quite good. Customers are quite confident about their ability to
get through the phone lines and are willing to hang up with very little
wait time invested. And we have no customer complaints about the phone
service.

For reasons cited above, Metro does not plan to take further action with
reference to this finding.

***3. The review team observed 76 calls during the two-day period of
April 12 and 13, 2005. These calls averaged over seven minutes to
complete. The reservations system being used at the time of the review
appeared to be antiquated and slow, contributing to the long call times.
Metro was in the process of upgrading its computer reservations system
with a scheduled implementation during the summer of 2005.***

We agree with this comment. The system we are using is indeed slow and
antiquated and it is being replaced. We have made some server upgrades
since the review time was here. Our average talk time for weekday
Reservation calls is now averaging between 4.5 to 6 minutes. The new
system is still in the process of being implemented and we are not live
on the system as yet.

***4. Metro's advertised Call-A-Ride reservations hours are 7:30 a.m. to
4:30 p.m. During the review, the Reservations Center closed at 4:21
p.m., based on a wall clock that was nine minutes fast.***

This finding has been corrected. The clock in the reservation area has
been replaced with a digital clock that automatically maintains the
precisely correct time.

***5. Any calls left in the queue at the end of the day were abandoned.
As a result, some customers calling before 4:30 p.m. are not being
served.***

Actually, Reservation agents answer all calls until the end of their
shift at 4:30. If they are in the middle of a call at 4:30, they must
continue to handle the call through to completion, even if that takes
them past the end of their shift. At that hour of the afternoon on
weekdays we have 12-13 agents on the Reservation Lines. Customers
understand that the phone lines *close* at 4:30 and the staff goes home.
They understand that if they want to make a reservation, they cannot
wait until 4:30 to start the call process. We have very few calls coming
in after 4pm. We have no complaints about customers getting abandoned in
the queue at 4:30. However, we cannot say with certainty that this never
occurs. Our phone system is over 20 years old and a new phone system is
needed to allow us to ensure that the queue is empty before logging out
of the phone system. Metro does not plan to take any further action on
this finding until a new phone system is installed.

***6. Metro accepts only four one-way trip requests per call during peak
call times. This policy can increase the length of telephone queues by
requiring reservationists to handle multiple calls rather than one to
serve one customer and placing multiple calls rather than one in the
phone queue.***

Actually this policy has been instrumental in improving the phone
service for individual customers.

In years past, social service agencies would assign one of their
employees to call to book trips for their consumers. One agency would
consume an hour or more of phone service time booking trips for 20+
individuals, and all their trips for the following week, getting
confirmations on every trip, fare amounts and so forth. We had all the
individual workshops, individual dialysis centers, schools and so forth
calling like this. It created busy signals for other ordinary consumers
trying to get through the phone lines, long wait times in the queue and
myriad of other problems.

To solve this problem, we implemented the policy that only two round
trips could be booked on one phone call. It totally eliminated this
problem. It made each call much shorter, opened up phone capacity for
other callers, lessened the wait times in the queue and generally
improved phone service in a dramatic fashion. Individual consumers
generally don't need to book more than 4 one-way trips or 2 round trips
at a time anyway. Most just book one one-way or round trip at a time.

Social service agencies were spurred to enter into contractual
agreements to get the kind of specialized service they were looking for.
As such, these agencies are no longer taking any time from the
Reservation lines. They work with other staff dedicated to contract
service and never use the call center resources. The lines are now
completely used by individual consumers.

It is important to note that we have not had complaints about the phone
system in years. This is not an issue for the vast majority of
consumers. In general consumers are getting through the phone lines and
getting trips booked with little delay.

For reasons cited above, Metro does not plan to take further action with
reference to this finding.

***7. Metro tracks performance by measuring the callers' average time in
the telephone queue. This performance measure does not capture the
number of callers that have significantly long hold times, which
provides a better index of customer service and telephone access.***

Metro's Automatic Call Distribution (ACD) phone system is an older model
phone system. Reports generated from the ACD system are somewhat limited
but still provide a significant amount of data for performance
monitoring. While there is no ability to track each individual call made
into the system, data "averages" are still a good indicator of
performance. It is also important to note that we are able to look at
such averages in 30-minute time increments. This data combined with
customer feedback and complaint information give us a good indication of
how the phone system is functioning for customers.

Metro is in the process of investigating possible upgrades for our ACD
phone system. We are in the very early stages of exploring technology,
costs and funding availability. There are no specific plans at this time
to replace our current ACD system, but it is being explored for the
future.

**D. Trip Reservations and Scheduling**

***1. Metro's web site and the Metro Call-A-Ride brochure dated June 28,
2004, advise Call-A-Ride customers to "phone at least 24 hours in
advance to schedule your trips." The DOT ADA regulations (49 CFR
§37.131(b)) requires the transit entity (Metro) to schedule and provide
trips in response to a request for service made the previous day.***

As noted, the brochure "advises" customers to call at least 24 hours in
advance -- but does not state that it is a "requirement". We also
"advise" customers to call as early as possible for trips and let them
know they can call up to 7 days in advance. It is never stated as a
requirement to call 7 days in advance. We are letting customers know
that the vans fill up quickly and if they want a very specific time,
they should call as early as possible.

In practice, we accept reservation calls for the next day up to 4:30 pm
the day before service. We also accept same-day calls for service and
provide them if there is time and space available for the requested
trip. We will clarify that reservations are taken through the close of
business of the prior day in the next printing of the above documents
and the website will be updated when the new printed materials are
available.

For reasons cited above, Metro does not plan to take further action with
reference to this finding

***2. At the time of the review team's on-site visit, Metro regularly
denied trip requests for ADA complementary paratransit service due to
capacity constraints. The proportion of denials was generally two
percent of total demand on weekdays. Of these denials approximately 20
percent were for next day service requests and 80 percent were for
service requests two or more days in advance of the service day. Metro
managers said that many of the riders who have their trip requests
denied call back on a subsequent day and get a trip. However, Metro has
not tried to document this number, and it is not without significant
effort on the part of the rider.***

The data as presented here is not a completely accurate description of
the denials on the service. It also includes denials from the general
public -- which are not ADA denials and should not be included in these
statistics.

At the present time, the software used to schedule trips is not able to
determine if **a *trip is ADA required or not***. That is, if the trip
origin and destination requested is within ¾ mile of a bus or rail line
at the time the bus/train is running. All we can do at the present time
is determine if the person requesting a trip is ADA eligible. Since our
service is open in certain areas to non-ADA eligible individuals, some
of the denials noted by the Review Team are not even ADA related. And
some of the denials for ADA-eligible customers are not true ADA eligible
trips.

For all of FY2006, there approximately 18 one-way trip denials per day
by ADA-eligible customers. That was 0.8% of all requested trips, not 2%
as noted above by the Review Team. Additionally, we have no way to
determine how many of those 18 trips were actually ADA-eligible trips.

At this time trip denials for ADA-eligible individuals are less than 1%.
When we are able to determine trip eligibility, we expect to see that
percentage drop even further. When we are able to determine trip
eligibility we will be able to screen out ineligible trips and determine
what steps, if any, remain to get down to zero ADA-eligible trip
denials.

***3. Many trips denied early in the scheduling period can be scheduled
later in the scheduling period as a result of trip cancellations and/or
route modifications made by proofers. Denial of such trip requests
precludes them being served unless the customer calls again at a later
time to request the trip.***

Unfortunately our Cancellation & No-show Policy is so lenient that most
customers wait until the night before or the day of service to cancel
their trips. Data for the last six months shows that 60-65% of all
cancellations came in on the day of service or the day/evening before.
This does not provide the capacity needed to work in trip denials.

Proofers are "optimizing" routes to eliminate backtracking, long ride
times, trips in the middle of workshop routes and so forth. Proofing the
routes rarely, if ever, creates more capacity. In fact, it generally
results in trips that don't fit well on routes and are assigned to the
clean-up vans for the next day. And proofing is not done until the day
before when the trips are largely known. Customers needing trips for
important appointments do not wait until the night before to firm up
their travel plans. They have generally made alternative arrangements.

This is just not an operational recommendation for trip denials. Our
plan is to determine how many denials are actually ADA-eligible trips
before we determine what additional steps, if any, are still required.

***4. The Metro scheduling software does not include a function to
schedule trips to meet appointment times. Reservationists record
appointment times requested by callers in the software system and can
attempt to place the trip on the run they feel is most appropriate.
However, Metro has not set up PASS to schedule by appointment time.***

This is not an accurate description of the appointment time capabilities
of our current software.

Our scheduling practice is to attempt to provide every customer with a
ride time of 45 minutes or less depending on the length of the trip. If
the customer has a work or medical appointment, having sufficient travel
time is even more important because traffic and other customer delays
are inevitable.

The practice is to enter the customer's appointment time in the trip
request and then back up the pickup time 45 minutes. This will ensure
that if the van arrives in the late +/-15 minute window, the customer
will still have sufficient time to make the appointment time. If the
trip will take longer than 45 minutes, the software will show this
during the scheduling process -- the appointment time will be coded red
indicating that the van will be late for the appointment. Then the
reservationist will work with the pickup time on different routes, or
back up the pickup time, until we find a route that can make the trip
and get to the appointment on time.

We have found this to be a much more reliable means of scheduling trips
with appointment times. It ensures that there is sufficient time to
actually meet the appointment time.

For reasons cited above, Metro does not plan to take further action with
reference to this finding

**E. Service Performance**

***1. Metro's policy standard for service denials does not appear to
consider all denials. Metro's policy standard is zero denials for
requests made the previous day. Metro accepts service requests seven
days in advance of the service day, and "Metro Call-A-Ride Easy Trips"
brochure encourages customers to call early to make trip reservations.
Denying a trip more than one day in advance of the service day, thereby
requiring multiple calls to schedule a trip, appears to limit access to
the service and constitute a capacity constraint.***

The ADA Regulations are very specific about what constitutes a trip
denial. Only next-day trip denials are discussed in the ADA Regulations.
Transit properties should not be penalized for attempting to make the
service as convenient as possible by allowing customers to make travel
arrangement more than one day in advance.

We have discussed this subject with the disabled community before. We
could implement a service plan that only allows next-day reservations
and scheduling. It would probably cut down on cancellations and no-shows
and possibly reduce denials. It would probably be easier and more cost
effective for the transit system. When given this choice, however,
customers have indicated a very strong preference for the advance
scheduling convenience over next-day scheduling. They were willing to
accept a few advance-day denials for the convenience of advance-day
scheduling.

For reasons cited above, Metro does not plan to take further action with
reference to this finding

***2. The review team's analysis of a one-day sample indicates that 64
(2.5 percent) of trip requests for service on February 9, 2005 were
denied. During the period June through December 2004 Metro reported next
day denials of 0.6 percent. Metro indicated that some customers who are
denied service more than one day in advance of the service day call back
and eventually reserve their requested trip.***

This is a simple mistake on the part of the Review Team.

As noted earlier, Metro's Call-A-Ride service is *open to the general
public* in certain areas and on certain days. Some of the trip requests
from the general public also result in denials. When reviewing the data
on denials, one must also look at the ADA eligibility of the customer
whose trip was denied.

ADA eligible customers have a fare code of P (Plus fare) or D (Double
Zone fare). All other fare codes are for the general public. If the
Review Team analyzes the Trip Denials by Fare Code they will see that
trip denials for ADA eligible customers for next day trips are indeed as
reported. The data being reported by the Review Team is in error -- it
is denials for ALL customers *including the general public*.

It is further important to note that these denials may not be ADA
eligible trips -- we cannot determine those at this time. As such, true
ADA denials are most likely much less than reported at present.

For reasons cited above, Metro does not plan to take further action with
reference to this finding

***3. Metro appears to have no policy for missed trips.***

That is not accurate -- our policy is to have NO missed trips. The
Review Team spent a considerable amount of time in our Dispatch Center
where we showed them how "missed trips" are handled.

Missed trips result from several operational events. One such problem is
a customer calls us stating that they are not ready yet -- they are
still in the doctor's office or wherever and they will need a later
ride. The dispatcher unschedules that trip and marks it a "will call" so
it can be scheduled later when the customer calls back. Very frequently
these customers do not call back. They have been admitted to the
hospital, a family member came for them or some other such event
occurred.

Sometimes the customers call and ask us to come back in an hour. We
reschedule, come back and still can't find them. Again, they are marked
as a will call since we are hoping to hear from them again.

If we are late beyond the 15-minute window and cannot find the customer,
we mark these trips as System No-Shows and they are not charged to the
customer. These are missed trips. This is just not a very frequent
occurrence. If we are running late, the dispatch center staff normally
calls the customer to tell them so, or the customer calls in to find out
where their van is. We rarely have "missed trips" because our
communication with the customers is generally very good.

The table below shows ALL customer no-shows, late cancellations, no
fault no-shows, system no-shows, and erroneous trips for the last three
years. As shown, we have very few system no-shows or missed trips per
year. The average is about 2 or 3 per day. They represent about 1% of
all no-show/late cancel/no fault no-show/ system no-show type trips.

  --------------------- ------------ ---------- ------------ ---------- ------------ ----------
  NS_TYPE               2004         2004%      2005         2005%      2006         2006%

  CNS Client No-Show    11,609       16%        10,989       17%        7,769        16%

  LAT Late Cancel       38,642       54%        32,785       51%        24,131       50%

  NNS No Fault No-show  19,004       26%        18,170       28%        14,611       30%

  SNS System No-show    951          1%         764          1%         600          1%

  XXX Erroneous Trips   1,812        3%         1,778        3%         1,112        2%

                                                                                     

                        **72,018**   **100%**   **64,486**   **100%**   **48,223**   **100%**
  --------------------- ------------ ---------- ------------ ---------- ------------ ----------

***4. Based upon a review of Call-A-Ride data reports for February 9,
2005, it appears that Metro does not record missed trips as a category
for performance monitoring purposes. Missed trips appear to be grouped
with customer no-shows and late cancellations.***

Metro has found that 2 or 3 missed trips per day are a statistically
insignificant number of trips to attempt to report in a separate
category.

***5. Analysis of data for the sample day indicated that for 14 trips
(0.7 percent of the 2,019 trips dispatched on the service day) that were
not completed, the vehicle arrived at the pickup address more than 15
minutes after the scheduled time. For 57 trips (2.8 percent) that were
not completed, there was no vehicle arrival time. All of these trips
could be missed trips---resulting in as many as 71 (3.5 percent) missed
trips. Some of these trips could also be late cancellations.***

As shown from the table above, for the last three years, missed trips or
system no-shows have averaged less than 3 trips per day. Erroneous trips
are not charged to anyone. Sometimes we have a trip for a customer who
insists they never booked that trip. Or, a customer whose subscription
is "on hold" for a temporary illness that comes back on the schedule and
they are still not riding due to illness or such and the customer forgot
to call again. They are many ways to get erroneous trips in the
schedule. We just mark these off the schedules so customers are not
charged with these types of trips.

***6. Metro has two standards for on-time performance. For the customer,
the standard for on-time is a vehicle arrival between 15 minutes before
and 15 minutes after (-15/+15) the scheduled time. For performance
measurement and reporting the standard is 15 minutes before and 20
minutes after (-15/+20) the scheduled time. Use of one standard for the
customer and a more generous standard for performance measurement
overstates the level of service being provided to the customer.***

This is not an accurate representation. When a customer is booked for a
trip on our service, they are given an "approximate pickup time" -- not
a guaranteed pickup time. The Scheduling Software will move that
scheduled trip up and down in the scheduling window to accommodate other
trips that are added to the route. This is absolutely essential to
enable productive cost-efficient scheduling.

The important point is that the actual pickup time on the day of service
could be at the very end of the 15-minute window depending on how the
system has scheduled all of the trips for a given route. On our bus and
rail service, on-time performance is measure as:

-   0 -- 59 seconds early; and

-   0 -- 5 minutes late

If the bus/train arrives at the designate stop within those parameters,
it is measured as "on-time" by our internal standards. This is a very
common standard around the transit industry as well.

We measure our van service with the same standards. Since the Scheduling
Software can move the trip to the very end of the 15-minute window, the
trip is measured on-time as long as it is within 0-5 minutes late of the
scheduled time -- in this case the end of the 15 minute window.

Since the van will sit at a location until the beginning of the early
window, and customers only need come out when they are ready, there is
no penalty for being early. Unlike the bus or rail service -- we never
leave customers stranded for being too early. Drivers are not allowed to
go in and get customers before the early window and dispatchers will
never call before the early window.

For reasons cited above, Metro does not plan to take further action with
reference to this finding

***8. On the sample day, there were 306 (16.1 percent of completed
trips) picked up early. Of that number, 35 (1.8 percent of completed
trips) were picked up more than 16 minutes early; of those trips, 11
(0.6 percent of completed trips) were picked up more than 30 minutes
early. Very early pickups could indicate that customers are being
pressured to accept early departures.***

That is not the case. Drivers are not allowed to go in and get customers
before the early window and dispatchers will never call before the early
window. We have no complaints from customers about being pressured to go
early, indeed, many customers welcome the opportunity to depart "early"
if they are ready for the trip. We do have drivers that know their
customers -- and they know if they will appreciate going early or not.

***9. Of 833 trips with scheduled drop-off or appointment times, 710 (85
percent) were early or on-time and 123 (15 percent) were late. Of these
late drop-offs, 34 (4.0 percent) were more than 15 minutes late; of this
number, 18 (2.1 percent) were more than 30 minutes late. These late
drop-offs, potentially resulting in late arrivals for work, school, or
medical appointments, could be considered a constraint to use of the
service by paratransit eligible individuals.***

As noted by the Review Team we go to great lengths to ensure on-time
performance for our customers. Scheduling parameters by time of day are
used to approximate running times throughout the day. MDTs are used to
monitor service in real time and move trips. Five vehicles and 10
drivers are kept clear all day every day to use in keeping trips on
time. There is very little else that can be done. Some trips on some
days will be delayed -- it is unavoidable.

It is unfortunate -- but traffic and customers themselves are the single
biggest cause of service delays. However, 52 late trips out of 2,100+
scheduled trips is a small number (less than 2.5%). We get very few
complaints about late trips. It does not appear to be a constraint at
this time.

For reasons cited above, Metro does not plan to take further action with
reference to this finding

***10. From a sample of 29 long trips on February 9, 2005, 21 (1.1
percent of the completed trips) exceeded Metro's standard of 90 minutes
for intra-zonal trips. 15 (0.8 percent) of the 29 long trips sampled
were more than 30 minutes longer than a comparable fixed route trip and
7 (0.4 percent) were more than 46 minutes longer. Five of the trips that
were more than 30 minutes longer than a comparable fixed route trip were
to or from the same location. This appears to be a pattern of
significantly long trips.***

Seventeen of the 29 trips on the Review Team's spreadsheet were
sheltered workshop trips under contract for the Department of Mental
Health or other contract trips. These routes were developed in concert
with the DMH staff since they are paying for the service. We have
offered to add routes but they do not want to pay for them in some
instances. In others, the long ride times are due to parental/guardian
requirements as to when the client must be picked up and/or how early
they can be brought home. The van is being used, on occasion, as a
safety net for some individuals under "protective oversight" until they
can be delivered to an authorized adult.

As noted earlier by the Review Team, we have a scheduler review and
proof all of the trips and routes every day before service. One of the
reports we routinely run is a Ride Length report, which shows every
single trip longer than 45 minutes. The Scheduler will make every
attempt to shorten non-contract trips and is generally successful. We
have very few complaints about ride length. The scheduler is not allowed
to make modifications to these contract routes.

**E2. Transportation Operations**

***3. Metro has a "no strand" policy for riders with return trips. If a
rider calls after the vehicle has left, Metro will not record this as a
passenger no-show, but will re-classify the trip as a will-call for
later pickup.***

We have tried various methods for tracking missing customers, including
the one suggested by the Review Team. The method we are using now is
operationally the best.

Marking a customer a no-fault no-show and rescheduling ANOTHER TRIP is
very time consuming. The address and such all needs to be typed again
and the dispatch center may be quite busy when the customer calls back.
Having the original trip on Route 0 as a will-call makes this so much
simpler. The dispatcher just changes the time and reschedules with one
keystroke.

Additionally, scheduling ANOTHER trip exaggerates the number of trips
that were actually scheduled that day. It makes the number of no-shows
look larger and the number of scheduled trips larger than they actually
were. We have enough of these trips throughout the day given the large
number of medical trips we provide, that this practice would actually
result in very misleading statistics.

***4. Metro appears to have the capacity to accommodate some trips that
could not be scheduled before the service day by assigning those trips
to "Route 0," as well as using capacity made available from
cancellations and available on the "clean up" runs. This capacity could
be used to reduce or eliminate trip denials.***

While we agree that there is some limited capacity during the day to
accommodate some trips, we disagree with this recommendation. Our
service is at capacity most of the time and the clean-up vans are needed
to maintain on-time performance, respond to passenger emergencies,
respond to operational issues like road calls or traffic conditions, and
cover operator absences. We cannot fill these vans with denials.

We may be able to implement this recommendation for ADA Eligible
customers taking an ADA Eligible trip when our new software is
implemented. Only next day trips that meet these strict ADA conditions
would count as a true ADA denial. We anticipate that these will be quite
small and we may be able to work these in. We will examine this
recommendation in more detail when we are able to identify qualifying
ADA trips.

***7. Drivers cited illogical routing and tight schedules as a
concern.***

Sometimes trips just don't fit well into any route. This is especially
true of long-distance trips that cross several zones. But our job is to
serve all of the trips no matter how "illogical" they may seem. Drivers
dislike these long distance trips and complain about them; however, such
trips are necessary to provide the required service. We will continue to
proof our schedules prior to service and move trips when possible on the
day of service. No additional action is planned.

**F. Resources**

***1. Staffing of the Call-A-Ride call center appears to limit access by
customers to reserve trips. New reservations software and procedural
changes to reduce call volume should increase efficiency of the
reservations process, but additional staffing will likely be required to
reduce hold times to a level that does not significantly impeded access
to service.***

We disagree. Average wait times in the queue are quite good for a public
agency. Abandoned call times indicate customers are confident of getting
through the phone lines. There are no customer complaints about the
phone system. There is no impeded access to the service due to the call
center.

We currently have 12-14 people assigned to the Reservation lines on
weekdays. This is approximately the same schedule as when the Review
Team was on site. The schedule currently in effect is in the table on
the next page. As shown, there is very adequate staffing including a
relief dispatcher.

We have also made a concerted effort to improve staff attendance, which
is not as good as van operator attendance at present. This will address
some of the vacant seats that the Review Team noted due to missing staff
during the review. We are also utilizing temporary help in the call
center to ensure that we have adequate staffing at all times.

***3. Increased demand for service may require an increase in the number
of runs and associated increases in the number of drivers and
vehicles.***

We anticipate being able to perform trip-by-trip ADA eligibility
determinations with our new software. We are fairly confident that this
analysis will confirm that we are providing some trips that may not be
required by the ADA regulations. Demand for true ADA trips may actually
be lower than anticipated. Since 2001, the paratransit van fleet has
doubled and Metro will continue to budget to meet anticipated demand.

![](media/image4.wmf){width="6.2243055555555555in" height="7.875in"}

**Attachment B**

On-Site Review Schedule

+---------+--------------------------------+------------+--------------+
| *       | **Activity**                   | **Who**    | **Where**    |
| *Time** |                                |            |              |
+---------+--------------------------------+------------+--------------+
| **      |                                |            |              |
| Monday, |                                |            |              |
| April   |                                |            |              |
| 11,     |                                |            |              |
| 2005**  |                                |            |              |
+---------+--------------------------------+------------+--------------+
| 9:00    | -   Opening Conference         | All        | Board Room,  |
| a.m.    |                                |            | 6^th^ Floor  |
|         |                                |            |              |
|         |                                |            | 707 North    |
|         |                                |            | First St     |
+---------+--------------------------------+------------+--------------+
| 10:00   | -   Review policies &          | All        | 707 North    |
| a.m.    |     procedures information     |            | First St     |
|         |     provided, & additional     |            |              |
|         |     data requests with Metro   |            |              |
|         |     Managers                   |            |              |
+---------+--------------------------------+------------+--------------+
| 11:00   | -   Review service area        | Knight     | Planning     |
| a.m.    |                                |            | Dept.        |
|         | -   Review Call-A-Ride/Metro   | Kidston    |              |
|         |     budget process             |            | ADA Office   |
|         |                                | Chia       |              |
|         | -   Review eligibility process |            | Customer     |
|         |     & records                  | Regan      | Service      |
|         |                                |            |              |
|         | -   Review complaints          |            |              |
+---------+--------------------------------+------------+--------------+
| 1:00    | -   Review Call-A-Ride demand  | Kidston    | ADA Office   |
| p.m.    |     equipment & staffing       |            |              |
|         |                                | Chia,      | ADA Office   |
|         | -   Review eligibility records | Knight     |              |
|         |                                |            | Customer     |
|         | -   Review complaints          | Regan      | Service      |
+---------+--------------------------------+------------+--------------+
| 2:30    | -   Review service area        | Knight,    | Planning     |
| p.m.    |                                | Kidston    | Dept.        |
|         | -   Summarize observations of  |            |              |
|         |     complaints                 | Regan      | 707 North    |
|         |                                |            | First St     |
|         | -   Interview eligibility      | Chia       |              |
|         |     assessors & review records |            | 4444Forest   |
|         |                                |            | Park Ave.    |
+---------+--------------------------------+------------+--------------+
| 3:00    | -   Analyze and document Metro | Knight     | []{.mark}    |
| p.m.    |     service area, fares &      |            |              |
|         |     hours                      | Kidston    | 707 North    |
|         |                                |            | First St.    |
|         | -   Analyze & document Metro   | Regan,     |              |
|         |     resources                  |            | 4444Forest   |
|         |                                | Chia       | Park Ave.    |
|         | -   Continue to summarize      |            |              |
|         |     complaints                 |            |              |
|         |                                |            |              |
|         | ```{=html}                     |            |              |
|         | <!-- -->                       |            |              |
|         | ```                            |            |              |
|         | -   Continue to review         |            |              |
|         |     eligibility assessors &    |            |              |
|         |     review records             |            |              |
+---------+--------------------------------+------------+--------------+
| **T     |                                |            |              |
| uesday, |                                |            |              |
| April   |                                |            |              |
| 12,     |                                |            |              |
| 2005**  |                                |            |              |
+---------+--------------------------------+------------+--------------+
| 7:00    | -   Tour Facility              | All        | 3300 Spruce  |
| a.m.    |                                |            |              |
+---------+--------------------------------+------------+--------------+
| 9:00    | -   Observe call takers;       | All        | 3300 Spruce  |
| a.m.    |     record trip request        |            |              |
|         |     information                |            |              |
+---------+--------------------------------+------------+--------------+
| 9:30    | -   Interview schedulers,      | Chia,      | 3300 Spruce  |
| a.m.    |     observe scheduling         | Kidston    |              |
|         |                                |            |              |
|         | -   Interview Drivers          | Knight     |              |
|         |                                |            |              |
|         | -   Interview Call Center      | Regan      |              |
|         |     Manager & Records          |            |              |
+---------+--------------------------------+------------+--------------+
| 11:00   | -   Interview Dispatcher       | Chia,      | 3300 Spruce  |
| a.m.    |                                | Kidston    |              |
|         | -   Interview Drivers          |            | []{.mark}    |
|         |                                | Knight     |              |
|         | -   Review telephone system    |            |              |
|         |     and performance            | Regan      |              |
+---------+--------------------------------+------------+--------------+
| 1:00    | -   Analyze scheduling &       | Chia       | 3300 Spruce  |
| p.m.    |     Dispatch Procedures &      |            |              |
|         |     Practices                  | Kidston    |              |
|         |                                |            |              |
|         | -   Analyze operator manifests | Regan      |              |
|         |     & service performance      |            |              |
|         |     reports                    | Knight     |              |
|         |                                |            |              |
|         | -   Analyze telephone system   |            |              |
|         |     performance & reservation  |            |              |
|         |     procedures & practices.    |            |              |
|         |                                |            |              |
|         | -   Interview Drivers          |            |              |
+---------+--------------------------------+------------+--------------+
| 3:00    | -   Observe call takers;       | Regan,     | 3300 Spruce  |
| p.m.    |     record trip request        | Knight     |              |
|         |     information                |            |              |
|         |                                | Chia,      |              |
|         | -   Observe Dispatch           | Kidston    |              |
+---------+--------------------------------+------------+--------------+
| **Wed   |                                |            |              |
| nesday, |                                |            |              |
| April   |                                |            |              |
| 13,     |                                |            |              |
| 2005**  |                                |            |              |
+---------+--------------------------------+------------+--------------+
| 6:45    | -   Interview drivers          | All        | 3300 Spruce  |
| a.m.    |                                |            |              |
+---------+--------------------------------+------------+--------------+
| 8:00    | -   Analyze Eligibility,       | Chia       | 3300 Spruce  |
| a.m.    |     Scheduling & Dispatch data |            |              |
|         |     & procedures               | Kidston    |              |
|         |                                |            |              |
|         | -   Analyze operator manifests | Regan      |              |
|         |     & service performance      |            |              |
|         |     reports                    | Knight     |              |
|         |                                |            |              |
|         | -   Document & analyze driver  |            |              |
|         |     interviews, telephone      |            |              |
|         |     access & reservations      |            |              |
|         |     procedures & practices     |            |              |
|         |                                |            |              |
|         | -   Document & analyze service |            |              |
|         |     area, hours & fares        |            |              |
+---------+--------------------------------+------------+--------------+
| 1:00    | -   Continue analysis          | All        | 3300 Spruce  |
| p.m.    |                                |            |              |
+---------+--------------------------------+------------+--------------+
| Th      |                                |            |              |
| ursday, |                                |            |              |
| April   |                                |            |              |
| 14,     |                                |            |              |
| 2005    |                                |            |              |
+---------+--------------------------------+------------+--------------+
| Morning | -   Complete preliminary data  | All        | 707 North    |
|         |     analysis & remaining       |            | First St.    |
|         |     detail work                |            |              |
|         |                                |            |              |
|         | ```{=html}                     |            |              |
|         | <!-- -->                       |            |              |
|         | ```                            |            |              |
|         | -   Prepare materials for      |            |              |
|         |     debriefing session         |            |              |
+---------+--------------------------------+------------+--------------+
| 1:00    | -   Exit Conference            | All        | Board Room,  |
| p.m.    |                                |            | 6^th^ Floor  |
|         |                                |            |              |
|         |                                |            | 707 North    |
|         |                                |            | First St     |
+---------+--------------------------------+------------+--------------+

**Attachment C**

**Metro Call-A-Ride Brochure**

**Attachment D**

[]{.mark}

**ADA Paratransit Application**

**Attachment E**

[]{.mark}

**Metro Unconditional Eligibility Letter**

**Attachment F**

[]{.mark}

**Metro Conditional Eligibility Letter**

**Attachment G**

[]{.mark}

**Metro Not Eligible Letter**

**Attachment H**

[]{.mark}

**Metro Temporary Eligibility Letter**

**Attachment I**

[]{.mark}

**Metro Mobility Aid Not Eligible Letter**

[]{.mark}

**Attachment J**

[]{.mark}

**Call-A-Ride Plus Identification Card**

**Attachment K**

[]{.mark}

**"Public Transit Options for Customers with Disabilities"**

**Attachment L**

[]{.mark}

**ADA Paratransit Eligibility Appeals Process**

**Attachment M**

[]{.mark}

**Call-A-Ride Service Zones**

**Attachment N**

[]{.mark}

**Analysis of St. Louis Metro Data**

**for**

**Trip Disposition**

**On-Time Performance**

**and**

**Trip Duration**

The project team chose Wednesday February 9, 2005 as a sample day for
analysis of Metro Call-A-ride performance in providing ADA complementary
paratransit service. Metro provided their trip data in an Excel
spreadsheet for that day on a compact disk. The data has been used to
perform an independent analysis of trip disposition and service
performance.

Table N.1 -- Trip Data Fields

  ------------ ---------------------- ------- ------------ ---------------------
  **COLUMN**   **LABEL**              ** **   **COLUMN**   **LABEL**

  A            BUS                            AN           BDY

  B            LAB                            AO           CALLDATE

  C            RIDERS                         AP           FS

  D            EQUIP                          AQ           NETNODE

  E            ID                             AR           AIDES

  F            CALL                           AS           REASON

  G            ETA Negotiated                 AT           PROVIDER

  H            ETACALC Estimated              AU           TRACKER

  I            APPTTIME Requested             AV           SPEEDFCTR

  J            PD (Pickup/Dropoff)            AW           ORIGETA

  K            ADDRESS                        AX           SATISFIED

  L            APARTMENT                      AY           NEGETA

  M            CITY                           AZ           PURPOSE

  N            BUSCOLOR                       BA           FAREAMT

  O            DATESTAMP                      BB           AREAS

  P            ADDLOADTIM                     BC           MAPGRID

  Q            COLLECT Actual Time            BD           VERIFIED

  R            XCOORD                         BE           DOOR_CURB

  S            YCOORD                         BF           FARE_COLL

  T            ROUTER                         BG           ARRIVE

  U            VEHICLE                        BH           PHONE

  V            DRIVER                         BI           EARLYTIME

  W            COMMENTS                       BJ           FAREBDY

  X            Disposition                    BK           AVLUPD

  Y            CAPCALC                        BL           INADA

  Z            CAP1CALC                       BM           DATEFIELD

  AA           CAP2CALC                       BN           ZIP_CODE

  AB           CAP3CALC                       BO           AUTHORIZED

  AC           CUSTNUM                        BP           AUTHO_CODE

  AD           CUSTNAME                       BQ           REFERRAL

  AE           SLACK1                         BR           CONTACT_N

  AF           PX                             BS           CONTACT_P

  AG           PY                             BT           CONTACT_F

  AH           TRIPTYPE                       BU           CONTACT_PA

  AI           FARETYPE                       BV           WEIGHT

  AJ           ODOMETER                       BW           CONTACT_E

  AK           TRIED                          BX           CONTACT_FA

  AL           ETAEARLY                       BY           STATE

  AM           NEXTLAB Stop Order                           
  ------------ ---------------------- ------- ------------ ---------------------

The spreadsheet contains 5,597 rows representing records of trip
information and 77 columns representing characteristics of each trip.
The 77 characteristics measured for each trip are labeled as presented
in the preceding table.

**[ADA Complementary Paratransit Trips]{.underline}**

Since Metro Call-A-Ride is a member of a TMA it serves both ADA
complementary paratransit trips and non-ADA trips. To distinguish
between the two Metro uses the fare codes assigned to each trip.

A table of the codes as provided by Metro in November 2006 appears
below:

  ------- ------------------------------------------ ---------------------
  FARE    DESCRIPT                                   Appears in the Feb 9,
  TYPE                                               2005 database

  A       ADA TRANSFER TO                            Yes

  B       ADA TRANSFER FROM                          Yes

  C       COMPANION                                  

  D       CAR PLUS DOUBLE ZONE CHARGE                Yes

  E       NON-ADA COMPANION DBL ZONE                 Yes

  F       FULL FARE                                  Yes

  G       NON ADA WITH FF PASS/TICKETS               Yes

  H       NON ADA WITH REDUCED PASS/TCKT             Yes

  I       ADA TRIP WITH FF PASS/TICKET               

  J       ADA FARE W REDUCED PASS/TICKET             Yes

  K       CHESTERFIELD CONN E/H FARE                 

  L       CHESTERFIELD FULL FARE                     

  M       NO FARE -- AMBULATORY                      Yes

  N       NO FARE - DISABLED ONLY                    Yes

  O       ADA TRANSFER TO BUS                        Yes

  P       ADA ELIGIBLE FARE                          Yes

  Q       CHESTERFIELD E/D + TRANSFER                

  R       ADA MULTI ZN W RED PASS/TICKET             Yes

  S       FULL FARE TRANSFER TO BUS                  

  T       CHESTERFIELD CON FF + TRANSFER             

  U       FULL FARE STUDENT TICKET                   

  V       TMA WHEELCHAIR ADDITIONAL PAX              

  W       TMA WHEELCHAIR/MILE                        

  X       TMA AMBULATORY/MILE                        Yes

  Y       TMA AMBULATORY ADDITIONAL PAX              
  ------- ------------------------------------------ ---------------------

Metro managers indicated that they use the shaded fare codes for
analysis of ADA service. The column on the right side of the table
identifies those categories that appear in the data set for the sample
day. Metro managers also indicated that category N includes trips paid
for by a party other than the passenger such as Medicaid, training
centers or others. Some passengers who use these services have been
certified as eligible for Call-A-Ride ADA services while others have not
been. Metro indicate many of the passengers who use this fare code and
are not certified would be eligible for ADA complementary paratransit
were they to apply. Accordingly Metro managers indicated that they
include this category when performing ADA service analysis. In addition,
Metro managers thought that attendants were sometimes included in this
fare category.

Metro managers indicated that category M, like category N, includes
trips paid for by a third party. Unlike category N, trip makers in
category M are ambulatory. Metro manages felt that most of the category
M passengers would not likely be eligible for ADA complementary
paratransit service. Category M accounted for 3.9 % of requested trips
on the sample day whereas category N accounted for 49.5%. If some
category M trip makers were ADA eligible, some category N trip makers
may not be eligible. Absent more detailed information on customer's
eligibility status it is assumed that over or undercounting of
eligibility in these two categories would be somewhat off-setting and
that inclusion of category N and exclusion of category M should provide
a representative indication of service performance for the sample day.

In addition to the fare categories included on the list there were
several other fare categories included in the data sample. These were:

  -----------------------------------------------------------------------
  FARETYPE

  blank

  010

  063

  DE

  FF

  FG

  GC

  Z
  -----------------------------------------------------------------------

The number of trips in each of these fare categories, except for blank
and Z were 1 or 2 trips. The total number of trips involved is so small,
whether included in the analysis or not, is likely to have little impact
on how well the analysis represents performance of ADA service.

There were 13 trips identified as category Z for the sample day. A
definition for category Z provided at the time of the review by Metro is
as follows:

*ADA STD TKT/MULTI ZN W FF PASS*

[]{.mark}

This definition is appears to be similar to that of Fare Type I in the
above list. Accordingly it is assumed that trips in fare type Z are ADA
trips.

There is a discrete record in the data base for each trip origin and
destination. Accordingly, "no fare" is typically recorded for one record
(usually destination) for each trip. For the sample day there were 5,597
trip records. Of this number 3,031 were categorized as no fare. Included
in these no fare records are non-revenue activities such as driver's
return "dead head" to the garage at the end of the work day or driver's
breaks. Removing these records from the analysis, results in 5,030
records of 2,515 unique trip requests. The resultant number of no fare
pick-ups for trips performed is 19. Metro managers indicated that
passenger attendants are included in the no fare category.

"ADA FARE WITH FF PASS/TICKET" was categorized as "I" in the November
2006 fare table. This is a change from the fare table used on the
February 9, 2005 sample day. At that time this fare type was categorized
as "H." Accordingly, category "H" fares are included as ADA trips and
Category "I" are not.

 

Based on the foregoing for the purpose of providing indicators of
service performance for ADA complementary paratransit customers, trip
records with the following fare types have been considered in the
analysis of ADA complementary paratransit service and all other fare
types were deleted from the data files.

Table N.1a -- ADA Fare Codes

  ---------- ------------------------------------------------------------
  **Code**   **Description**

  A          ADA TRANSFER TO

  B          ADA TRANSFER FROM

  D          CAR PLUS DOUBLE ZONE CHARGE

  H          ADA FARE WITH FF PASS/TICKET

  J          ADA FARE W REDUCED PASS/TICKET

  N          NO FARE - DISABLED ONLY

  O          ADA TRANSFER TO BUS

  P          ADA ELIGIBLE FARE

  R          ADA MULTI ZN W RED PASS/TICKET

  Z          ADA STD TKT/MULTI ZN W FF PASS
  ---------- ------------------------------------------------------------

Deleting all records except those with fare types listed in Table N.1a
resulted in 2,169 records representing ADA complementary paratransit
trips on February 9, 2005.

**Trip Disposition**

Column X represents trip disposition. The codes contained in this column
are as shown in Table N.2.

**Table N.2 -- Disposition Codes**

  --------------- -------------------------------------------------------
  **Code**        **Trip Disposition**

  P               Performed

  C               Early Cancel

  W               No Show

  N               Late Cancel & Missed Trips

  Blank           Refused & Denied Trips
  --------------- -------------------------------------------------------

Since most trips are coded in pairs in the spreadsheet (one row
represents pick-up and another row represents drop-off in Column J for
the same ID appearing in Column E), and most drop-off records have a
non-ADA fare code of blank, the 2,169 rows or records actually represent
2,116 unique trip pick-up requests. Table N.3 shows the breakdown by
trip disposition as coded in the report.

**Table N.3 -- Recorded Trip Disposition**

  ----------------------- --------------- --------------- ----------------
  **Trip Disposition      **Number of     **Number of ADA **% of Total ADA
  Codes**                 Rows or         Trip Pick-up    Trip Pick-up
                          Records**       Requests**      Requests**

  P = Performed           1634            1634            77.2%

  C = Early Cancel        358             348^1^          16.4%

  W = No Show             0               0^2^            

  N = Late Cancel &       91              91^2^           4.3%
  Missed Trips                                            

  Blank = Refused and     86              43^3^           2.0%
  Denied                                                  

  **TOTAL**               **2169**        **2116**        **100.0%**
  ----------------------- --------------- --------------- ----------------

NOTES:

-   ^1^Although most drop-off records coded with trip disposition code C
    have a non-ADA fare of blank, there are 10 drop-offs with an ADA
    fare of N. Therefore the 358 records of early cancel ADA trips
    actually represent 348 unique trip pick-up requests.

-   ^2^Records coded with trip disposition codes W and N were found to
    represent drop-offs and pick-ups respectively for the same scheduled
    set of trips, and so count as one set of 91 trips. Although no
    disposition code W records appear in this analysis because they have
    a non-ADA fare of blank, they are nevertheless represented by their
    pick-up counterparts with disposition code N having valid ADA fare
    codes as listed in Table N.1a. For further discussion, see section
    *Late Cancel, Missed Trips, and No Shows* below.

-   ^3^Records coded with a blank trip disposition code were found to
    have both a pick-up record and a corresponding drop-off record with
    the same fare. Hence the 86 records of refused and denied ADA trips
    actually represent a set of 43 unique trip requests.

**Refused and Denied Trips**

[]{.mark}

There were 86 records in the spreadsheet where the trip disposition code
was left blank. For these records, all had a zero value for BUS in
Column A, indicating that the trips were not taken. This represents 43
trip requests (pick-up/drop-off pairs as coded with a "+/-" in Column
J), or 2.0% of all 2,116 trip pick-ups requested on February 9, 2005.

[]{.mark}

To further analyze the refused and denied trip request data, subtotals
by TRIPTYPE in Column AH were calculated, as displayed in Table N.4.

Since the spreadsheet contained no data on pick-up time requested, it
was not possible to determine the responsiveness of the service offers
with respect to pick-up requests.

[]{.mark}

The review team's analysis also noted that 13 of the capacity denial
trips did have an appointment time request in Column I. Since there was
no corresponding column in the spreadsheet measuring estimated or
promised drop-off time, there was no way to calculate whether the offer
was responsive with respect to drop-off time.

**Table N.4 -- Trip Denial by Type**

  -------------------------- ---------------------------- ----------------
  **Trip type code**         **Number of denied trips**   **% of denials**

  A = Adversarial denial     1                            2%

  C = Capacity denial        42                           98%

  TOTAL                      43                           100%
  -------------------------- ---------------------------- ----------------

[]{.mark}

Based on the foregoing review, on the sample day of 2,116 trips
requested, 42 or 2.0% were denied. This exceeds the 0.6% of next day
denials reported by Metro. As indicated by Metro some of the customers
whose trip is denied more than one day before the service day may
successfully schedule their trip at another time. Others may opt not to
make the trip or travel by other means.

[]{.mark}

**Scheduled Trip Requests -- Not Completed**

[]{.mark}

Deducting the 43 denied trips from the total 2,116 trips requested
results in 2,073 scheduled trips for the sample day.

Trips that have been scheduled are either completed (performed) or not
completed. Trips that are not completed can result from the action of
the customer or the operator. Trips not completed because of the
customer's action are cancellations and no shows. Customer cancellations
are typically categorized as early or late. Early cancellations permit
the operator to reallocate manpower and equipment with some
inconvenience. This inconvenience is often offset by making available
service capacity on the service day to address unforeseeable needs. Late
cancellations (an hour or two before the scheduled time) severely limit
the operator in reusing scheduled resources to serve other customers. As
with customer no shows, late cancellations are usually discouraged by
the operator.

Trips not completed because of the operator's failure are missed trips.
DOT ADA regulations (49 CFR §37.131(f)(3)(B)) prohibit transit entities
from limiting service availability through patterns or practices that
result in substantial number of missed trips. For purposes of measuring
performance against the regulatory criteria, missed trips are defined as
trips that were not served when the customer was available for the trip
throughout the pick-up window (-15/+15). That is, the vehicle did not
arrive in the pick-up window and the trip was not completed.

[]{.mark}

**Early Trip Cancellations.** Trip disposition code C represents trips
cancelled early. There were 358 records in this category. However, 10
records were drop-offs ("-" in Column J) for corresponding trip pick-ups
(same ID in column E). Eliminating these records from this category, we
tabulated 348 trip pick-up requests that were cancelled early. This
represents 16.4% of all 2,116 trips requested on February 9, 2005.

[]{.mark}

Because the spreadsheet contained no column for cancellation time, it
was not possible to verify that these trips were indeed early
cancellations. In fact, 9 of the 348 early canceled trips contain a
vehicle arrival time in column BG of the spreadsheet, suggesting that
the cancellation may not have been "early enough" to avoid an attempted
pick-up trip or the cancellation was not communicated to the driver in
timely manner. 6 of the 9 cancelled trips with a vehicle arrival time,
list the bus number as "0," thereby calling some of the recorded
information further into question.

[]{.mark}

**Late Cancel, Missed Trips, and No Shows.** Deducting the 348 early
cancellations from the 2,073 scheduled trips leaves 1,725 trips
dispatched.

Trip disposition code N represents both trips cancelled late and missed
trips. There were 91 records in this category. All of the records were
coded with a "+" for pick-up in Column J.

[]{.mark}

Trip disposition code W represents no-show trips. There were no records
in this category containing a valid ADA fare. All of these records in
the Excel spreadsheet from Metro were coded with a "-" for drop-off in
Column J and a blank fare in Column AI.

[]{.mark}

When trips with disposition codes N and W were combined and sorted by ID
(Column E), each pick-up record for a late cancel/missed trip had a
corresponding drop-off record coded as a no-show. The disposition data
in Column X appears to make no distinction between late cancel, missed
trips, and no-shows. These records together represent one set of 91 trip
requests that were either: late cancels, missed trips, or no-shows, or
4.3% of all 2,116 trip pick-ups requested on February 9, 2005.

[]{.mark}

To distinguish among the three categories, the review team examined the
data in columns G (ETA Negotiated) and BG (ARRIVE). Variances between
actual vehicle arrival time and promised arrival time enabled us to sort
the 91 trip requests by intervals within targeted ranges and categorize
them as follows:

-   If the trip contained a vehicle arrival time within +/- 15 minutes
    of the promised arrival time, the trip was assumed to be a customer
    "no show."

-   If the trip contained a vehicle arrival time outside the +/-
    15-minute window of the promised arrival time, the trip was assumed
    to be a "missed trip."

-   If no vehicle arrival time was recorded for the trip, it was assumed
    that either the trip was cancelled in time to avoid the vehicle
    traveling to the pick-up location or the vehicle simply never
    arrived at the pick-up location. These trips could be either late
    cancellations or missed trips.

The results of the analysis of late cancel, missed trips, and no shows
appear in Table N.5.

Of the 1,725 trips dispatched, 34 or 2.0 % were no shows, 0 to 47 or 0 %
to 2.7 % of the trips were late cancellations, and 10 to 57 or 0.6% to
3.3% were missed trips.

**[Table N.5 -- No Shows and Missed Trips]{.mark}**

+---------------------+--------------+--------------+-----------+-----+
|                     | **No shows** | **Missed     | **Late    | **T |
|                     |              | trips**      | Cancel    | ota |
|                     | (Arrival     | (Arrival     | /Missed   | l** |
|                     |              | outside      | Trip**    |     |
|                     | +/-15 min.   | +/-15 min.   |           |     |
|                     | of           | of           | (No       |     |
|                     | Negotiated   | Negotiated   | arrival   |     |
|                     | ETA)         | ETA)         | data)     |     |
+---------------------+--------------+--------------+-----------+-----+
| Number of trips     | 34           | 10           | 47        | 91  |
+---------------------+--------------+--------------+-----------+-----+
| \% of trips with    | 77%          | 23%          | 0%        | 1   |
| arrival data        |              |              |           | 00% |
+---------------------+--------------+--------------+-----------+-----+
| \% of all late      | 37%          | 11%          | 52%       | 1   |
| cancels, missed     |              |              |           | 00% |
| trips, and no shows |              |              |           |     |
+---------------------+--------------+--------------+-----------+-----+

**On-Time Performance**

[]{.mark}

Deducting the 91 trips that were not completed from the 1,725 trips
dispatched results in 1,634 completed trips on the sampled day, or 77.2%
of all 2,116 trips requested on February 9, 2005. Trip disposition code
P represents trips performed.

For the 1,634 completed, or performed, passenger trips on the sample
day, to identify on-time, early, and late pick-ups, the promised pick-up
or drop-off time in column G (ETA Negotiated) was compared to the actual
pick-up time in columns Q (COLLECT Actual Time) and BG (ARRIVE).

[]{.mark}

Column BG contained vehicle arrival time data for 934 (57%) of the 1634
completed pick-ups. All the records contained an actual collect time in
column Q. On-time, early, and late pick-ups were calculated as follows.

-   For completed trips with no vehicle arrival time listed, the
    difference between promised pick-up time and the actual "collect
    time" was calculated.

-   For completed trips with both arrival time and actual collect time
    data, the difference between promised pick-up time and the earlier
    of arrival time or actual collect time was calculated.

As indicated in Table N.6, for the sample day, 77.8 percent of trips
were picked up within 15 minutes of the scheduled time or on-time. 93.7
percent of trips were picked up either early or on-time, while 6.3
percent of trips were picked up late.

Table N.6 -- Calculated On-Time Performance: February 9, 2005

  ----------------------- ----------- ------------ ------------ ------------
                          **On Time** **Early**    **Late**     **Total**

  **Number of Completed   1,271       260          103          1,634
  Trips**                                                       

  **% of Completed        77.8%       15.9%        6.3%         100%
  Trips**                                                       
  ----------------------- ----------- ------------ ------------ ------------

For early pick-ups, the concern is whether customers are pressured to
accept early pick-ups by drivers or dispatchers. To the extent that
customers find the early pick-ups convenient and have no objection,
early pick-ups do not represent a constraint to use of the service.
Table N.7 presents the distribution of early pick-ups from the beginning
of the pick-up window. For example, "1-5 minutes early" is 16 to 20
minutes before the scheduled time and one to five minutes before the
beginning of the -15/+15 pick-up window. As indicated in the table, 89.2
percent of the early pick-ups were within 15 minutes of the window.
Pick-ups more than 15 minutes early could be considered untimely
pick-ups if the time were not convenient for the customer.

Table N.7 -- Early Pick-ups

  --------------------- ----------- ----------- ----------- ----------- -----------
                        **1-5       **6-15      **16-30     **\>30      **Total**
                        minutes**   minutes**   minutes**   minutes**   

  **Number of early     147         85          18          10          260
  trips**                                                               

  **% of early trips**  56.5%       32.7%       6.9%        3.9%        

  **Cumulative % of     56.5%       89.2%       96.1%       100.0%      
  early trips**                                                         
  --------------------- ----------- ----------- ----------- ----------- -----------

[]{.mark}

With late pick-ups, the service and regulatory concern is whether or not
there are a substantial number of significantly late pick-ups.
Accordingly, late trips were reviewed to identify how late the pick-up
was relative to the -15/+15 pick-up window.

[]{.mark}

As shown in Table N.8, 81.6 percent of late pick-ups on the sample day
are within 30 minutes of the scheduled time and 15 minutes of the end of
the -15/+15 pick-up window. Three pick-ups, or 0.2 percent of all trips,
were more than 30 minutes late. These trips could be considered
significantly late, but 3 trips of 1,634 trips do not appear to be a
substantial number of significantly late trips.

Table N.8 -- Late Pick-ups

  -------------------------- ----------- ----------- ----------- ----------- ------------
                             **1-5       **6-15      **16-30     **\>30      **Totals**
                             minutes**   minutes**   minutes**   minutes**   

  **Number of Late Trips**   45          39          16          3           103

  **% of Late Trips**        43.7%       37.9%       15.5%       2.9%        

  **Cumulative % of Late     43.7%       81.6%       97.1%       100%        
  Trips**                                                                    

  **% of Completed Trips**   2.8%        2.4%        1.0%        0.2%        6.4%
  -------------------------- ----------- ----------- ----------- ----------- ------------

For the sample day, 93.7 percent of trips were performed early or
on-time. Including trips with arrival times no more than five minutes
after the pick-up window---as Metro does in its performance
measurement---would result in early or on-time performance of 96.5
percent for the sample day. This is comparable to Metro's reported
on-time performance of 97 percent. An on-time performance rate of 95
percent equates to one late trip every two weeks for a traveler who
makes one round trip 5 days a week. This is a relatively high level of
on-time performance for an urban ADA complementary paratransit service.

**Drop-offs.** To retrieve corresponding drop-off data for the 1634
records of performed ADA pick-ups, the team went back to the original
spreadsheet and matched the ID in Column E of the performed ADA pick-ups
(Pickup/Drop-off code of "+" in column J) to records with the same ID in
Column E with a PD (Pickup/Drop-off) code of "-" in column J.

To determine the number of on-time, early, and late drop-offs, the
appointment time requested in column I (APPTTIME requested) was compared
to the arrival time in columns Q (COLLECT Actual Time) and BG (ARRIVE).
This permitted calculation of the difference between scheduled and
actual drop-off times and categorization of times by intervals within
targeted ranges. The following data protocols impacted the data analysis
of on-time, early, and late drop-offs:

[]{.mark}

1.  Column Q (COLLECT time) contains a pick-up time when the PD
    (Pickup/Drop-off) code in column J is "+," and a drop-off time when
    the PD (Pickup/Drop-off) code in column J is "-".

2.  739 (45%) of the 1634 completed trip drop-offs contained appointment
    time requests in column I. This data formed the base for the
    analysis.

3.  173 (23%) of the 739 completed trip drop-offs with appointment time
    requests contained arrival time data in column BG. However, all the
    records contained an actual collect time in column Q.

We calculated on-time, early, and late drop-offs as follows:

-   For completed trips with no arrival time listed, we calculated the
    difference between appointment time requested and the actual collect
    time.

-   For completed trips with both arrival time and actual collect time
    data, we calculated the difference between appointment time
    requested and the earlier of arrival time or actual collect time.

[]{.mark}

Based on this analysis, of the 739 drop-offs, 617 (83.5 percent) were
early or on-time, while 122 (16.5 percent) were late. Both early and
late drop-offs were analyzed to identify the number of significantly
early and significantly late drop-offs.

Table N.9 shows the distribution of early (before the appointment time)
drop-offs. Of the 617 early drop-offs, 59.4 percent were on-time or less
than 30 minutes early. Another 21.5 percent were 31 to 60 minutes early,
and 2.6 percent were more than an hour early. The 19 trips more than an
hour early are potentially a substantial number of trips that are
significantly untimely. Drop-offs more than one hour early can result in
customers left waiting on the sidewalk for the facility at their
destination to open. Drop-offs more than an hour before appointments can
be a constraint to use of the service by individuals who have
disabilities.

Table N.9 -- Distribution of Early Drop-offs

  ----------------- ----------- ----------- ----------- ----------- -----------
                    **0-15      **16-30     **31-60     **\>60      **Total**
                    minutes**   minutes**   minutes**   minutes**   

  **Early           233         206         159         19          617
  Drop-Offs**                                                       

  **% of Completed  31.5%       27.9%       21.5%       2.6%        83.5%
  appointments**                                                    

  **Cumulative % of 37.8%       71.2%       96.9%       100%        
  early drop-offs**                                                 
  ----------------- ----------- ----------- ----------- ----------- -----------

[]{.mark}

Late drop-offs for appointments can cause the customer to miss medical
appointments, or classes, or cause late arrivals for work. As shown in
Table N.10, for all trips with appointments, 16.5 percent of the
drop-offs were late. 4.6 percent were more than 15 minutes late and 2.4
percent more than 30 minutes late.

Table N.10 -- Distribution of Late Drop-offs

  ------------------ ----------- ----------- ----------- ----------- -----------
                     **1-15      **16-30     **31-60     **\>60      **Total**
                     minutes**   minutes**   minutes**   minutes**   

  **Late drop-offs** 88          16          17          1           122

  **% of Completed   11.9%       2.2%        2.3%        0.1%        16.5%
  appointments**                                                     

  **Cumulative % of  72.1%       85.2%       99.2%       100%        
  late drop-offs**                                                   
  ------------------ ----------- ----------- ----------- ----------- -----------